Is Your Environmental Monitoring Program Effective?

For many smaller businesses environmental pathogens may be a new term. These pathogens may cross contaminate ready to eat and high-risk foods during post lethality processing and packing. Severity of consequences associated with pathogens is high including death in some cases.

The two most common environmental pathogens associated with food processing / manufacturing are Salmonella and Listeria Monocytogenes. These are responsible for over half of all food safety issues.

Global Food Safety Initiative certification schemes and Preventive Controls for Human Food Rule require that companies have risk – based Environmental Monitoring Programs.

Companies developing EMP must start with risk assessment to determine organism / organisms of interest. Wet processing facilities would look for Listeria, dry for Salmonella. In some operations pathogenic E. coli may also be considered as a major threat.

Food Safety Certification standard and regulations do not require testing directly for pathogens. Companies may decide to test for indicator organisms of the major environmental pathogens.

Another important part of your EMP must be the determination of swabbing sites.  Industry standard requires swab testing in 3 zones – Food Contact, Indirect Food Contact & Non – Food Contact. This will give you a better understanding where cross contamination may be coming from.

Results of swab testing will be used to adjust your sanitation practices and focus more efforts in problematic areas.

Another important element is deciding on swabbing frequency. This also must be based on historical data or base line testing if you are implementing a new Program. With baseline testing the key factor would be positivity (or out of limit) ratio you got from your mass swabbing.

Acceptable limits must be established for indicator organisms where results are communicated in numerical values. With direct pathogen testing the only acceptable result is “negative”.

Finally, corrective actions procedures must be established for all out of limit results. Typical corrective action process involves investigation to the root cause of the non – conformance, re-cleaning, re-training or adjusting sanitation procedures and practices. Every time your swab comes back with non – compliant result you need to re-swab to demonstrate your corrective actions were effective.

In some cases where the problem is more complex (i.e., repeating positive results from the same area) an investigation may involve vector swabbing to determine the actual surface, object or structure that causes contamination.

Your Environmental Monitoring Program must always be based on risk and EMPs vary between facilities and food sector categories.

BD Food Safety Consultants can assist with development of an effective Program to keep your food safe. Contact us today to make an appointment.