Improving Environmental Controls

The ability of pathogenic microorganisms to gain entry into food supply systems remains a major public health challenge, and concern. Each year, foodborne illness outbreaks affect millions of people and kill thousands. Additionally, these outbreaks undermine consumer confidence in affected products, and diminish market demand. A substantial amount of these outbreaks results from poor environmental controls and/or hygiene practices. It is critical to maintain and monitor the hygienic environment in the food processing facility for the production of safe food products.

An environmental monitoring program (EMP) collects information about the specific environmental conditions and provides vital information about indicator microorganisms as well as pathogens in a timely manner. Additionally, EMP will evaluate the effectiveness of a plant’s hygienic practices. The EMP is not designed to validate the effectiveness of cleaning and sanitizing methods, but is more focused on validating cleaning and sanitizing frequencies, and other Good Manufacturing Practices (GMPs) (21 CFR).

Objectives and Corporate ­Commitment

It is important to clearly state EMP objectives. The EMP team should have clarity on target indicator microorganisms and pathogens to determine sanitation cleaning frequency, to initiate appropriate corrective actions, and to reinforce employee training programs. Also, corporate management needs to understand and support the EMP by supplying all the required resources to ensure that it is an essential part of the food safety program. The objectives, risks, and associated corrective actions should be properly communicated to all the employees or at least to the EMP monitoring team.

Components of an Effective EMP

An EMP should be carefully designed after evaluating the facility, the type of processing, raw materials, pathogens of concern, finished products, packaging, and shipping. Some key components that should be a part of the EMP are an environmental monitoring team, zones, sampling, selection of indicator and pathogenic microorganisms, sampling tools, labeling and shipping, baseline/target, trends and corrective actions, and mapping (Figure 1).

EMP Team

The first task in the implementation of an effective EMP is to bring together individuals familiar with the operation to help identify potential areas of risk and concern in a facility. This group will be the EMP team and may include the plant quality manager, the plant or corporate microbiologist, line supervisors or operators, and sanitation supervisors or workers. If the facility does not have a food safety microbiology expert experienced in the development and implementation of an EMP, it is strongly recommended that the facility contact an experienced outside expert for guidance. Once the team is assembled, the process flow should be evaluated to include the zones posing the most microbiological risk to the finished product. The team should walk the plant floor to identify areas where the product may be vulnerable to contamination.

Zones

The best way to identify sampling points is to use the zoning concept, which divides facility operations into four zones based on the levels of risk. It is vital for the environmental monitoring team to define zones 1 to 4. Once the zones are determined, carefully consider which specific tests are going to be used before beginning sampling.

Zone 1 refers to all direct food-contact surfaces in the plant (e.g., blenders, conveyors, utensils, work tables, etc.). It is not recommended to swab for pathogens in zone 1 because it is not an effective way to capture product contamination. Non-pathogen or indicator microorganism swabs should be used on product surfaces that are not always cleanable, like the underside of a conveyor or a filling chute that is stationary.