Environmental monitoring program food plant

Do I need an environmental monitoring program in my food facility? Am I ready to implement an environmnetal monitoring program? What pathogens should I test for? How often should I conduct environmental monitoring activities? What happens if I get a positive result?

Environmental monitoring is a process used in facilities that produce ready-to-eat RTE foods that assesses how effectively the plant is being cleaned. This typically means swabbing various surfaces e. The goal is to determine whether any pathogens e. Another form of environmental monitoring is ATP Testing — a type of test that can be performed immediately onsite and will demonstrate the efficiency of your sanitation activities.

Legally, the FDA leaves this decision up to the food processor. GFSI-aligned 3rd party audits typically require environmental monitoring programs to be in place for producers of ready-to-eat food that are exposed to the environment post-kill step. Is your product exposed to the environment after the kill step and before packaging?

If your product is refrigerated, is it one that is conducive to the growth of listeria monocytogenes e. While testing the product itself can may inform you about the safety of that sample, testing the facility verifies that your cleaning activities are working and that each batch is being produced in a pathogen-free environment.

Do you have a thorough sanitation program? Your environmental monitoring program is a test of your cleaning, so if you have doubts about the thoroughness of your sanitation practices, address those first. Do you have the resources to enact it faithfully? The most common pathogens which can be found living in the nooks and crannies of a facility are.

You may test for these directly or indicator microorganisms that represent each pathogen. Additionally, you may conduct environmental monitoring for specific allergens to confirm that there is no allergen residue in your space. This would only be a consideration if you were processing both allergen containing and non-allergen containing products on the same equipment. Commodity-Based Assignments. The FDA initiates commodity-based assignments to gain insights into how widespread certain harmful bacteria may be in the manufacturing environment s across an industry, to assess conditions and practices, and to gauge compliance with food safety regulations.

The FDA may use the findings from such assignments to inform guidance to industry or to conduct further risk-focused targeted sampling, in addition to responding immediately to any food-safety hazards identified. Risk-Based Prioritization. The FDA has developed a process for considering establishment-specific potential risk to the public health. Establishments may be identified for environmental sampling using this process, which employs criteria related to food-hazard pairs e.

Some plants will periodically rotate sanitizers to avoid resistant strains of bacteria from developing, Reeder said. For example, he said, a plant may use a quaternary compound, then switch to a peracetic acid, then use an alcohol-based sanitizer, then start over again with the quat. Use dry cleaning and sanitizing as a preventive system in between zones, in areas where employees are taking a break, and on shared items that cross zones—such as radios, shoes, and even incoming delivery vehicles.

With the prevalence of food allergies continuously rising in the U. See Legislative Update, page 6. During the period , labeling problems accounted for 34 percent of recalls due to undeclared major food allergens.

In a follow-up review, labeling problems accounted for 43 percent of recalls due to undeclared major food allergens. Because there is no cure, the only option for those with food allergies is to avoid the food, and to do so, they have to rely on food labels being complete, clear, and accurate. Thus, for consumer safety, manufacturers need to have controls to ensure that labels declare all the food allergens that are intended to be present, the correct label is applied to the product, and cross-contact of unintended food allergens is prevented.

Additionally, the rule proposes the revision of several provisions of cGMP part to explicitly address cross-contact, make it clear that cGMPs require protection against cross-contact, and ensure that they continue to address health concerns related to allergens. To identify the cGMP to be revised, detail the proposed requirement, clarify the reasoning for the requirement, and explain the proposed revisions and associated action s , FDA created a table outlining these for each proposed revision.

Although FDA notes that the table does not include all requirements for allergen controls, stating that readers should visit www. The table is available at www. Following are nine key areas of allergen risk in plants and best practice methods for reducing risk in each.

Pests of grain and other stored products have been around for a long time. Recorded control efforts go back as far as B. Such fumigants and other alternative methods are still used today to rid stored products of insects.

See Fumigant Options, page But the real key to control and prevention is knowledge. Pests have varying food preferences and habitats; differing life cycles, feeding stages, and adult lifespans; and dissimilar temperature thresholds and abilities for flight and package penetration, Mueller said, all of which are important in selecting the best method of control, and in reducing conducive conditions by which the insects live and breed.

Even among similar insects, there are differences. For example, the granary weevil can survive temperatures as low as F, while the red flour beetle will die if temperatures fall below F for a period of time. Additionally, some insects feed from the outside of grains or seeds, while others burrow inside to lay eggs which will then develop and feed from the inside. Some feed only as larvae, while others feed as adults. Additionally, different pests are attracted to different products, and understanding the specific insects that would be attracted to your plant and product is key to control, said Trece Marketing Manager Donna Lingren.

For example, the cigarette beetle is primarily a pest of spices, tobacco, and cocoa; while the Indian meal moth infests a vast array of dry products from flours to nuts and cereals to beans and chocolate. Despite their differences, the pests also have some things in common, one of which, Mueller said, is that their presence is a symptom of a condition. The condition may be an unsanitary environment, excessive temperature, or moisture content, or other pest-attracting issue. When an infestation appears in a stored product, the first thought is often that it came in with delivery of the raw product.

While this is a common means of entry, which makes it critical that plants inspect incoming goods and reject any deliveries that have any sign of stored products such as webbing, cast skins, larvae, eggs, or adults , these insects also can come in from the outside, said BASF Market Development Specialist Jason Meyers. This is particularly true if the plant is near a field or dump site that attracts pests and the plant structure is not well-sealed—providing entry points for the pests.

Because of this, a moth or two in a trap does not necessarily indicate an infestation, and pest management companies will have differing thresholds for action. Although a single pest does not mean an infestation, that single pest can begin an infestation if conditions are right. It is for that reason that preventive controls are critical. Periodic, intensive cleaning is of particular importance in areas of equipment and warehousing where dust, debris, crumbs, etc.

Another commonality among stored product pests is the innate need for survival, not only of the individual insect but for the survival of its species as a whole, thus the drive not only to feed but also to mate and breed. For this reason, trapping provides an effective means of both monitoring and control. But because most traps for stored product pests are pheromone based and insect specific, Lingren said, it also provides further reason for the need to know the most likely pests of your product.

Based on trap capture, and location of the trap, you then can zero in on hot spots and identify the location of an infestation. This can you help determine where the infestation originated e. As monitors, traps provide an early warning system that a problem is developing in the plant.

As with so many aspects of food safety, most important for both prevention and control is understanding the risk: the pests that are most likely to infest your product and facility, the most destructive life stages and means of entry, and the most effective methods of prevention and control. Once beetles, weevils, or moths infest stored products, they can be difficult to eliminate.

The most traditional process of elimination is fumigation, but there are also non-chemical and natural alternatives. Fumigants are specialized pesticides that act as a gas to kill a pest, explained Tom Phillips, professor of entomology at Kansas State University. All fumigants are toxic, and proper safety precautions must be taken by applicators to manage the risk.

In the U. Alternatives to fumigants include heat, controlled atmosphere, insect growth regulators, and biological controls such as predators, parasitoids, and pathogens. Following are overviews of each, as provided by Phillips:. EMP Benefits Some of the key benefits of EMP are that it: Measures the overall effectiveness of sanitary design, personnel practices, and operational methods. Acts as an early warning system for microbiological hazards in both the production and post-production environment when well-developed and effectively implemented as an integral component of prerequisite programs.

Helps to identify harborage niches and hot spots in a plant that may act as a source of contamination. Is a critical aspect of documenting the overall sanitary state of the facility. Validates the sanitation program and helps in determining the frequency required for cleaning and sanitation. An Effective EMP The first task in the implementation of an EMP is to bring together individuals familiar with the operation to help identify potential areas of risk and concern in a facility.

Indicator Microorganisms Indicators are non-pathogenic microorganisms that may be naturally present in food or the environment.

The following reasons explain some of the advantages of using indicator organisms in an EMP: They are less expensive and save time compared to pathogens. Low prevalence of pathogenic microorganisms limits the practical significance of direct pathogen testing. Indicator microorganisms are high in numbers and can be easily enumerated.

Indicator microorganisms are a valid representative of pathogens of concern since indicators use nearly the same pH, nutrients, temperature, water, etc. Stop product. Thoroughly examine the area, both visually and through vector swabbing. Breakdown production lines for inspection and take appropriate corrective actions e.

Thoroughly clean affected site foot radius and swab site and adjacent areas zones 2 and 3. Increase sampling frequency e. Scenario II: Positive zone 2 Breakdown production lines for inspection. Restrict traffic flow in these areas to the extent possible.

Take appropriate corrective actions e. Collect swabs after thorough cleaning zones 2 and 3 in a foot radius Increase sampling frequency e. Scenario III: Positive zone 3 and negative zone 2 This is an early indication that the cleaning and sanitation programs need to be more robust or redesigned. Thoroughly examine the area. Collect swabs after thorough cleaning zone 3 in a foot radius. Scenario IV: Positive zones 2 and 3 Break down production lines for inspection.

Thoroughly examine the area both visually and through vector swabbing. Collect swabs after thorough cleaning zones 2 and 3 in a foot radius. Initiate root-cause investigation. What happened? Increase cleaning and sanitation frequencies or modify method. Reexamine employee traffic patterns and redirect, if feasible. Make repairs e. Audit production handling practices e. Increase the swab frequencies. Verify the effectiveness.

Monitor and document. Mapping A map of all sampling locations on a facility design diagram is an effective way of identifying hot spots to take appropriate corrective actions. Summary In recent years, it has become increasingly critical for food industries to implement effective hazard control programs as both USDA and FDA have become far more aggressive in implementing risk-based preventive control procedures even before FSMA is fully implemented.

A Pest Power Bar. Downstream Education. The PetSmart Story. When developing a pest control program, managers from each department should be involved along with the internal or external pest control provider, Ramos said. Each can contribute a different expertise; and buy-in, ongoing support, and follow through will be more successful when all are involved in the discussion and understand their roles and responsibilities. The Program.