Environmental Sanitation Programs

In my career, advising food plants on the priority to control the environmental parameters increasingly has become paramount for processors. Environmental Sanitation and EM (Environmental Monitoring) has become a keystone in a plant’s internal EM programs as well as with the Global Food Safety Initiative (GFSI) and federal regulations. In my previous articles “Hygiene Monitoring Strategies that Hit the Mark” (April/May 2013) and “Be Ready to Beat Listeria” (April/May 2008), while food contact surfaces are a high priority, the environmental niches/zones have increasingly had a profound impact and role on a facility’s food safety-sanitation hygiene programs.

There are a multitude of studies that have demonstrated the ability of pathogens like L. monocytogens and Salmonella spp. to not only survive but flourish in a multitude of problematic environmental niches inherent in a wide range of food processing plants. While both types of pathogens survive via their vegetative state, not relying on spores for survival, both have their own modes for survival, persistence and biofilm formation.

As is well documented, Listerial species will persist and flourish in moist environments, and will out compete other species in temperatures below 40 degrees Fahrenheit (less than 4 degrees Celsius) being a bonafide psychrotroph gram positive, soil borne opportunist. While being a gram negative pathogen, Salmonella species have exhibited a marked tolerance for dry environs persisting in niches with lower moisture levels than Listerial species require. While not precluding the sporeforming opportunistic pathogens like B. cereus, or C. perfrigens, the other group of microbes that post persistent issues to a plant’s environment impacting food quality are the fungal species. Since most result in quality concerns rather than food safety concerns, these opportunistic environmental contaminants can profoundly impact shelf life and form biofilm alliances with a variety of bacterial pathogens. While some environmental niches are similar between vegetative pathogens and spoilage fungi, some are distinct for each group. Below is both a discussion of these environmental niches and their control measures.

Regulatory, GFSI, Product Type Perspectives

The Food Safety Modernization Act (FSMA) cornerstone is prevention akin to the proactive preventative philosophy of Hazard Analysis and Critical Control Points (HACCP). FSMA has expanded prevention to include HACCP principles to implement preventive controls. One of the key segments is sanitation controls with mandated verification and validation of the sanitation processes inherent in the operation. Preventive controls include an EM program to verify pathogen control effectiveness which includes not only food contact but environmental zones. In addition, the revision of Good Manufacturing Practices, or GMPs, to incorporate allergen cross-contact controls via preventative procedures is critical and directly involves a facility’s environmental sanitation program.

The current focus by FSMA on ready-to-eat (RTE) produce products, the fresh cut, and commodity RTE produce products is that they must rely on sanitation controls both on food contact and environs of a plant or packing house in order to control pathogens and spoilage microbes (to enhance shelf life). The cantaloupe and other produce pathogen outbreaks underscore the need for environmental sanitation as a critical preventive control.

The USDA FSIS 9 CFR Part 430 (2003 onwards) program emphasizes Lm control in RTE meat and poultry products. Alternatives 2 and especially 3 rely on sanitation measures and mandated validation and verification to demonstrate pathogen control of high-risk RTE products.

The GFSI programs, and specifically BRC and SQF, emphasize the mandatory development of environmental sanitation and validation programs. Not only do clauses 4.4, 4.7, and 4.10 deal with issues and parameters involving environmental sanitation, namely Building Fabric, Maintenance, and Filters & Sieves, but clause 4.ll on Housekeeping & Hygiene is one of BRC’s Fundamental Clauses. 4.11.1 clearly states that “documented cleaning procedures shall be in place and maintained for the building, plant, and all equipment.” Also, 4.11.2 focuses on the cleaning and disinfection procedures and frequencies shall be validated. Furthermore, in the BRC appendices, the emphasis of RTE environmental sanitation is very clear in the Guideline on Defining Production Risk Zones by delineation of High Care (Appendice 2.2) and High Risk (Appendice 2.3) in open product areas. “High-care” areas are practices inclusive of environment to minimize pathogen contamination of chilled/frozen RTE products with a high standard. High-care product examples include smoked fish, fresh prepared meals and salads, and uncooked garnishes on RTEs. This is inclusive of both FDA and USDA RTE products. “High-risk” open areas also involve RTE fully cooked products that are susceptible to cross-contamination by Listerial spp. High-risk areas are “designed to a high standard of hygiene where practices relating to…environment aim to prevent contamination by pathogenic microorganisms. High-risk product examples consist of fully cooked meats, meals, and dairy products.