Is it true that IPP are to automatically issue an NR when generic E. coli testing results indicate a lack of process control?

• A. Not sure
• B. False
• C. True
• D. N/A

Answer: (B)

A finding like generic E. coli indicating a lack of process control is a signal to investigate, not an automatic trigger to issue a noncompliance report. Issuing an NR depends on whether there is a verified noncompliance with regulatory requirements and the establishment’s HACCP plan. The correct approach is to review the data, confirm the result’s validity (and retest if needed), evaluate the context (which lot, timing, equipment, sanitation records, and corrective actions), and determine if there is proven loss of process control that constitutes a regulatory violation. Only after this assessment should an enforcement action be taken.

If the lack of control is confirmed and represents a regulatory noncompliance, an NR may be issued; if not, the finding may be managed through corrective actions and further monitoring. In short, you don’t automatically issue an NR based solely on a single test result.