Almost every food manufacturer must manage a food safety program that includes an environmental monitoring program (EMP). Initially, it might sound straightforward—pick some testing sites, take some sponges/swabs, and run pathogen testing—but, as you build a program or start to analyze your data, you may realize that running an EMP is not as easy as it seems.
There is no one-size-fits-all approach to starting an environmental monitoring program. Most regulation or auditing bodies are not going to give the best testing details on how much, how often, when, or sometimes even what to test for. Most of the time you are only required to have an environmental monitoring program that matches your hazard risk. This vagueness is because there are thousands of food product types, and the ingredients you use and how you make the product can be different, even in similar products. On top of that, even if you make the exact same product using the same ingredients, your people, facilities, equipment, and traffic patterns are different and can introduce different risks. Because there are so many moving parts to developing an environmental monitoring program, it’s difficult and risky for regulatory groups to provide a specific process without knowing your facility.
As a consultant, I find that, most of the time, companies struggle just to get started. My first piece of advice is to just dive in. An environmental monitoring program isn’t set in stone and, in fact, should grow and be flexible so you can adjust it as needed based on collected data. The main goal of any environmental monitoring program is to search and destroy: Find the bacteria niches in your facility and address them. Getting into the details of how to do that and what practices are going to work best is where complication come in. In addition, running a hazard analysis can be complicated and time consuming.
Here are steps you can take to build an effective EMP from the ground up that’s specific to your product and company.
Determine Your Product Process
The first piece of information you need to figure out is what you do with your product after you make it. It’s in your best interest to test all areas of contact, both food and non-food, so you have a better idea of the risk level and cleanliness of your facility. You must be careful because presumptive positive environmental monitoring results can indicate that a product could also be contaminated. Do you hold your product for a few days and have the time to wait for results from your environmental monitoring program to come back? Or are your products made, packaged, and out the door in just a few hours?
If you’re able to hold the product, then you can complete pathogen testing in the highest-risk, food contact sites. If something comes back positive for Salmonella, Listeria, or pathogenic E. coli, then you can catch the implicated product before it leaves the facility. However, if your product is out the door as fast as you can make it, then a presumptive positive sponge/swab on a contact surface can cause you to pull back the product or issue a recall, which is a can of worms you want to avoid.
Zone Your Facility
Next, select where you’re going to test, so you should define what the high-hygiene area is. For RTE products, this area starts where the raw product exits the cooking step as fully cooked, and extends to the point in the process where the product is fully enclosed in a sealed package. Everything prior to the cook step would be considered the raw area and the post cook hygiene area must be strictly off limits to personnel and equipment from the raw side. Personnel access to the high-hygiene area must be controlled and monitored to ensure the strict procedures for entering and leaving this area are followed.