Implementing an environmental monitoring program to provide food manufacturers a general view of the overall “health” of a facility is always important, but a new year is a particularly good opportunity to evaluate your procedures and start the year fresh by establishing a process that works for your facility.
An effective environmental monitoring program helps in the monitoring of your surfaces and equipment, helping to identify potential problem areas that can be addressed before it’s too late. Read on for a 10-step plan to establish an environmental monitoring program, recommended by industry subject matter expert Dr. Martin Wiedmann, Gellert Family Professor in Food Safety at Cornell University. Dr. Wiedmann shared his plan as part of our Health Care Academy webinar series on Environmental Monitoring. You may access the complete recording of the session with Dr. Wiedmann here. (Registration required.)
- Assemble a team. This would ideally be a cross-functional team including representatives from food safety and quality assurance, laboratory, operations and plant management, sanitation, maintenance/engineering and even brand owners. Good communication among key stakeholders is crucial.
- Conduct a risk assessment to identify what environmental pathogen hazards you are trying to control. Considerations include the type of food being manufactured, the manufacturing process and the intended or expected use of the food. Guidance from regulatory agencies, such as the U.S. Food and Drug Administration (FDA) or United States Department of Agriculture Food Safety and Inspection Service (USDA FSIS), and other industry organizations such as the Grocery Manufacturer’s Association (GMA) can help to identify these hazards. The World Health Organization (WHO) and the Food and Agriculture Organization of the United Nations (FAO) also provide food safety risk analysis tools.
- Obtain a floor plan of your plant to understand the layout and identify areas you need to sample. Mapping sampling sites to environmental sampling zones (defined based on relative potential for finished product contamination) will help to define your sampling plan. Sampling is typically conducted on both food contact surfaces (e.g., slicers, peelers, conveyor belts, work tables, etc.) and non-food contact surfaces (e.g., floors, walls, tubs, carts, floor mats, drains, etc.), including niches for bacterial growth and transfer points.
In most countries and regions, sampling sites in processing facilities are assigned to one of four zones (see Figure 1), with Zone 1 representing food contact surfaces (i.e., surfaces directly contacted by an exposed ready-to-eat (RTE) food) and Zone 4 representing areas outside of the RTE area (such as locker rooms and loading docks).
- Review previous environmental monitoring data over the last 4 – 5 years, including results from ATP, indicator and/or pathogen tests, and map them to the plant to identify where there may be issues.
- Map the potential sampling sites to the floor plan.
- Determine sampling frequency. This can range from daily/multiple times a day to weekly, or even monthly in very small operations. Sampling sites are typically pre-determined but may be randomly rotated so that not all sites are sampled every time. For example, only 15 of 30 predetermined sites may be sampled every time (with replacement). Sampling frequency and sample numbers should be determined through a risk-based approach (e.g., 1 sample for every 100 m2). The USDA FSIS provides guidance for minimum sampling frequencies for food contact surfaces in their guidance document on controlling Listeria monocytogenes in RTE meat and poultry products.
- Determine sampling time. For example, verification sampling typically occurs during processing (at least three to four hours after the start of processing). Days should be randomly selected. Using a random number generator can avoid biasing the sampling time toward more convenient or less busy days where positive results would be less likely to occur.
- Develop a flow chart or plan of corrective actions. A written plan should be developed prior to collecting samples, so you know how to react to positive results. You should not collect samples until you know what to do with positive results.
Corrections based on positive samples should be plant-specific and may differ by the location, or sampling zone, where the positive was found. Positive samples should be followed up with additional investigations and root cause analyses. Corrective actions should go beyond intensified cleaning and sanitation and may include:
- Cleaning and sanitation procedures and changed Sanitation Standard Operating Procedures (SSOPs)
- Maintenance and an improved preventive maintenance program
- Modified or replaced equipment
- Temporary shutdown of problem areas
- Modified master sanitation schedule
- Design and implement a record keeping system. Organize testing results in one location (folder, three-ring binder or, ideally, electronically). Documentation of corrections should also be kept in the same location.
- Regularly reevaluate the program and develop a plan for validation.
Inspired to take a deeper dive into environmental monitoring?
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