Establishments under "Equal To" may be required to conduct certain environmental and product sampling in order to test for pathogens that can affect food safety. Some sampling and testing must be conducted and paid for by the plant. Other sampling and testing is routinely conducted by the establishment’s MDA meat inspector. Additional product testing may be required to measure properties such as water activity or pH.

Routine Sampling Conducted by the MDA

An MDA meat inspector will collect samples on a routine basis to test for the following pathogens:


Testing for Salmonella is performed on raw product samples such as poultry carcass rinses.


Testing for Campylobacter is performed on raw product samples such as poultry carcass rinses; this may be done as companion testing with Salmonella.


Testing for Listeria is performed on ready-to-eat (RTE) samples; this may be done as companion testing with Salmonella.

E. coli O157:H7

Testing for E. coli is conducted for establishments that process beef carcasses or ground beef. In some cases, both the establishment and the MDA meat inspector will sample and test products for E. coli O157:H7. In addition, companion testing may be done for other Shiga toxin-producing E. coli (STEC): O26, O45, O103, O111, O121, and O145.

Sampling That Must Be Conducted by the Establishment

An establishment’s sampling and testing requirements may vary and will depend on their production processes and HACCP categories (RTE, raw beef, slaughter, etc.). An establishment must have procedures in place to collect samples to test for the following pathogens or indicator organisms:

Generic E. coli

Establishments with slaughter operations collect samples (typically 13 per year) for generic E. coli testing to be done at an accredited laboratory. A written plan describing how sampling is conducted and records showing the establishment's results are also required. Establishments that slaughter more than one type of livestock or both livestock and poultry must sample the type of livestock or poultry slaughtered in the greatest number. Establishments that slaughter swine as their predominant species may test for generic E. coli or may choose to use another sampling scheme that is more appropriate for their process. Establishments that slaughter a predominant species other than beef may elect to test for aerobic plate count (APC), Salmonella, or other indicator organisms in place of Generic E. coli.

Written procedures for the plan must include:

  • Sample collection procedures
  • Procedures for handling and shipping samples
  • Testing method and procedures for reporting results


Listeria monocytogenes can contaminate RTE products that are exposed to the environment after having undergone a lethality treatment. Establishments that produce RTE product must develop a Listeria testing program. The establishment must develop a written plan to address the number, location, and frequency of sampling as well as identify how they will handle positive results. Sampling must be completed on a routine basis (at least 12 post-lethality food contact surfaces sampled per year). More information on the general requirements for Listeria testing can be found in 9 CFR 430 or the USDA Compliance Guidelines for Listeria.