Environmental Monitoring in Food Processing
Introduction: Environmental Monitoring Program
As food processor’s grow and face increased scrutiny from auditors and inspectors, they begin to wonder about environmental monitoring and whether they should implement this type of program in their facility. This section aims to answer those questions.
What is environmental monitoring in food processing?
What is environmental monitoring in food processing?
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.g. cutting blades, tables, conveyers) for pathogens and sending those samples out to a lab for analysis.
The goal is to determine whether any pathogens (e.g. listeria, salmonella) are living in facility and to respond accordingly if a positive result is found.
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.
It’s important to recognize that a clean test result doesn’t confirm that your food is safe, rather it verifies that your cleaning processes are effective.
Do I need an environmental monitoring program in my food facility?
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.
An easy way to determine whether you need an environmental monitoring program is to answer the following questions (a “yes” would suggest that you may need one)
Does your process have a kill-step (e.g. cooking)
Is your product exposed to the environment after the kill step and before packaging?
Is your product a collection of ready-to-eat products combined to produce a ready-to-eat food that doesn’t include a kill-step?
If your product is refrigerated, is it one that is conducive to the growth of listeria monocytogenes (e.g. deli meat, raw cheese/milk, seafood, sprouts)
Because ready-to-eat foods are typically not processed by the consumer before consumption, it’s important to know that there’s no chance they might be contaminated by pathogens in an unclean facility.
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.
Am I ready to implement an environmental monitoring program?
If you’ve already confirmed that you should have an environmental monitoring program, consider the following questions before diving into a plan:
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? Once you launch your program, it’s important to follow it. If you doubt your ability to adhere to the program you’ve created or respond appropriately to a test result, then you should address those gaps prior to implementing the program.
What pathogens should I test for in my environmental monitoring program?
The most common pathogens which can be found living in the nooks and crannies of a facility are
listeria monocytogenes
salmonella
E. coli.
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.
What does an environmental monitoring program actually consist of?
Environmental monitoring program typically includes the following components:
A risk assessment of the hazards you’ve identified: Looking at your ingredients and the nature of your operation, you should be able to identify the specific pathogens that may exist in the environment. You may have started this in your hazard analysis.
Your methodology
A map of your facility separated into hygienic zones (e.g. Zone 1 is the highest risk part of the production process and Zone 4 is the office)
A process for exactly how you will collect your samples
A description of how often you will conduct your environmental monitoring (see below)
A description of where you will swab. These should be the highest risk areas where bacteria may be hiding and could get into your product.
A description of how you will have the tests analyzed (most likely by an external party, but it also may be in an in-house lab). You must list the specific lab conducting the analysis and confirm they’re properly accredited.
Corrective Action procedures, i.e. how you will respond if you receive a positive result.
How often should I conduct environmental monitoring?
The frequency of environmental monitoring is determined by your process and the hazards you identified in your hazard analysis.
Raw Foods Example: Let’s say your facility produces snack packages of raw carrots and ranch dressing. Since the product will be consumed raw, you’ll want to have extremely high standards of hygiene in your space. After conducting initial, pre-operation environmental monitoring, you may choose to conduct monitoring activities weekly in high risk zones (e.g. blades, conveyers, tables) and monthly in lower risk zones (walls, floors, drains). Ultimately, the decision of “how often” is up to you — you simply have to be able to justify that your frequency of sampling and testing is sufficient to determine that your sanitation efforts are effective.
Still not sure? Consider researching industry standards for environmental monitoring in plants producing products similar to yours. Start with that and then you can use historical data from your own site once your program is operational.You may only have to conduct environmental monitoring one time, such as when you move into a new facility and after you’ve completed a deep clean. This result would just be to confirm that you’re starting with a clean, pathogen-free space.
What happens if a pathogen is discovered in the test result?
If you get a positive hit in your environmental monitoring you will enact the corrective actions you’ve outlined in your plan. Depending on the type of result received, this may include re-cleaning, re-testing, holding product, and possibly a product recall. Check out This article to learn about hygienic zoning in an EMP and developing corrective actions
