Each establishment under "Equal To" must conduct testing for important food safety bacteria. Some sampling and testing must be conducted and paid for by the plant. Other sampling and testing is routinely conducted by the inspector. Additional product testing may be required to test things such as water activity or pH.

The "Equal To" program will collect routine samples for analysis in the Minnesota Department of Agriculture's laboratory for the following bacteria:


Performed on both raw product samples and Ready-To-Eat samples.


Performed on Ready-To-Eat samples.

E. coli O157:H7

Conducted in plants that process beef carcasses or ground beef.

Plants in the "Equal To" program must also collect and pay for sampling of their products for certain pathogens. These include:

Generic E. coli testing

All plants with slaughter operations must collect Generic E. coli tests, about 13 per year, and have them tested at an accredited laboratory on routine basis.  A written plan describing how sampling is conducted and showing the plant's results is also required.  For more information on the specific requirements, review the Generic E. coli Testing Requirements Checklist.

Listeria testing

Plants that produce Ready-To-Eat product must develop a Listeria testing plan.  The plant must develop a written plan to address the number, location and frequency of sampling as well as identifying how they will handle positive tests. Sampling must be done on a routine basis (at a minimum of 12 post-lethality food contact surfaces per year). For more information on the specific requirements for the Listeria plan, review the Listeria Checklist. More information on the general requirements for Listeria testing can be found in 9 CFR 430 or the USDA’s Compliance Guidelines for Listeria.