When FSIS receives a sample result positive for STEC in raw beef product, and the establishment either diverted the product for cooking or tested the same lot and got a negative result, IPP are to

• A. Discuss the results with the establishment, issue an NR, verify corrective actions
• B. Instruct the establishment to divert the affected lot of product for cooking
• C. Discuss the discrepancy with establishment management and document an MOI
• D. Instruct the establishment to submit additional samples from the affected lot

Answer: (C)

When there’s a discrepancy in STEC testing for a raw beef lot—a positive result followed by the establishment diverting the product for cooking or obtaining a negative result on retesting—the key step for IPP is to discuss the discrepancy with the establishment’s management and document it with a Memorandum of Interview (MOI). This approach creates a formal, traceable record of what the establishment reported, what actions were taken, and why the results appear inconsistent. It also clarifies responsibilities, preserves evidence for any regulatory follow-up, and guides subsequent actions, such as further testing, corrective actions, or communication plans.

Documenting with an MOI focuses on capturing the discussion, the factors the establishment cites for the discrepancy, and the proposed or agreed-upon next steps, without prematurely initiating other actions that might bypass this reflective recording. In contrast, other options either push for a specific action without documenting the discussion, or involve additional steps that aren’t the immediate priority when a discrepancy is present. The MOI is the formal mechanism to ensure the discrepancy is properly reviewed and tracked.