Listeria, Salmonella and E. coli related recalls, USDA ready to eat (RTE) requirements, the new upcoming FSMA proposals—it is becoming clear that all food and beverage businesses need to have an effective Environmental Monitoring program. Pathogen Environmental Monitoring (PEM) programs are often considered a prerequisite program within your HACCP plan. Basically it helps to verify that your sanitation and cross-contamination prevention efforts are effective. It can help to identify and locate any pathogenic hazards within your facility. Once identified, you can put a plan in place to mitigate this risk. While the ultimate goal is to keep foodborne pathogens out of your facility and out of your product, we know this can be very challenging. Therefore, implementing a PEM program in order to find any rogue pathogens hiding out in your facility is critical to your food safety program. So, what makes up a good PEM program?
Zoning = Sampling Locations
The first step is to look at your facility and all the different areas that pathogens can hide out. Remember, you cannot see or smell a pathogen so you need to do your research and understand how they work (where do they come from, what makes them grow, where are their favorite hiding places). You will need to map out your facility into 4 zones:Once you have broken your facility into zones, you will want to pick all the sites that you want to sample. This most likely will be pretty extensive but keep in mind you won’t be sampling every site every day but on a rotational basis.
Once you have identified your zones and sampling sites you will need to set up a sampling plan. Most sampling will be completed with swab/sponge methods but you can also use water and air sampling. You will start with a sampling program that helps to establish your baseline, then you can move to routine sampling.
Baseline sampling: More intensive to establish baseline—it is not uncommon to sample 25-50 target areas in each zone every day for a month. You are looking for both what is acceptable and unacceptable under normal operating conditions.
Routine sampling: Once you have established your baseline you will move to routine sampling which includes rotating sites so that you test each site at least 4 times per year.
- Pathogen Monitoring: Usually Salmonella and/or Listeria spp., used to identify and mitigate potential bacteria harborage locations.
- Aerobic Plate Count (APC): Used for sanitation verification of food contact surfaces—detects general microflora that is on a surface.
- Adenosine Triphosphate (ATP): Determines overall cleanliness of surfaces—detects any organic material that is present.
Sampling plans should always include: sampling sites, frequency of sampling, number of samples, sampling procedures, test method(s), and corrective action.
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Tracking & Trending
Once you have started your sampling plan, you will need a tool to track and trend all the testing results you are generating. This can be as simple as an Excel spreadsheet or you can use an automated software tool. The point here is to have a tool in which you can:
- Record the test results
- Track acceptable and unacceptable results
- Identify and highlight any unacceptable results
- Take corrective/preventive action on unacceptable results
Investigations & CAPAs
In the event that you do find unacceptable results, you will want to investigate the root cause and come up with a corrective AND preventive action. This may include completing multiple follow-up tests, more intensive sanitation or even repair or replacement of equipment/facilities. Don’t forget to look beyond the obvious source—pathogens are tricky and can get into areas that are not always obvious.
Lastly, you should be using your PEM data to assess the overall risk within your facility. Where do you have regular hot spots that may indicate equipment or facility issues? Are there areas or pieces of equipment that appear harder to clean and may need a change to the sanitation process or chemical used? Are there areas that indicate pathogens are being tracked in by personnel or raw material components (i.e. pallets)? Use your data to look at the big picture and identify where you can add preventive measures.
Environmental Monitoring is a key component of your Food Safety Management System. If you don’t have a PEM program in place yet, start working on one. We’ve seen too many food and beverage companies struggling through recalls because they didn’t make the best use of this great food safety tool.