Getting Candid about Environmental Monitoring Programs

Recently, I had the opportunity to sit down with Cliff Coles, president for over 20 years of Clifford M. Coles Food Safety Consulting, Inc., to discuss the topic of what makes an effective environmental program. Here’s how the conversation went:

Richard Stier: Should every company put together a hygiene monitoring program? Why or why not?

Cliff Coles: A hygiene monitoring program should reflect the risk assessment on the product being made. Certainly, a ready-to-eat product such as a salad or a cold-cut sandwich should and would have a more in-depth significance, whereas a beverage facility producing shelf-stable juices would be concerned with economic spoilage organisms, such as yeast, molds, and perhaps Lactobacillus or Alicyclobacillus. Whatever the case, it becomes the report card that justifies the efforts and dollars being spent by a company to remain in the marketplace. With respect to food safety, keep in mind that regulatory officials do not need to prove that a product is contaminated. They simply need to show that the product is being manufactured in an environment whereby it may become contaminated. This is a big difference, and if a company fails to monitor and control the environment, it could fail the test.

RS: Do you have a preference for the type of tests used?

CC: A company needs to decide how it will set up an environmental swab program. Will the program include Zone 1 swabs (direct food contact surfaces) or Zone 2, Zone 3, and Zone 4 only? Those who choose to include Zone 1 areas may opt for testing for “indicator” organisms, such as coliforms, as their choice over the other options. Several companies have chosen non-specific genetic testing (performance testing) to gauge the effectiveness of the sanitation on Zone 1 and Zone 2 environmental areas.

The options for monitoring an environment are plentiful, each has its own pros and cons, and each can be used to support the other. While plate counts and other counting methods require incubation time and can be cumbersome, counts can be used to determine levels of a specific organism and identify indicator organisms. Adenosine triphosphate (ATP) is a longstanding technique that is sometimes misunderstood. ATP results do not equate to the microbial load on a surface being sampled but do reflect the presence of organic material that can be the source of bacterial contamination, or at least be a food source for bacteria. A word of caution however: If the sanitation chemicals contain phosphates (the “p” being “phosphate” in ATP) and the chemicals are not sufficiently rinsed off of equipment surfaces, then the ATP swab results will naturally be consistently over the action limits that a company has deemed as acceptable.

Allergen swabbing is not a measure of microbial sanitation, but again, if the cleaning for microbial contamination is insufficient it’s pretty much a guarantee that the allergen proteins, if present, will remain. Environmental monitoring has to include the presence of allergens within the facility if allergenic ingredients are used. If gluten is the allergen of concern for example, the monitoring program needs to include ancillary areas of the production zones like walls, overhead structures, air ducts and air filters, and other product contact surfaces on adjacent equipment and in Zones 1 and Zone 2.

RS: If a company gets positives in its hygiene monitoring, what do you suggest as a corrective action?

CC: How a company reacts to a positive should be dictated by where the positive is found. Unless the company is doing ATP swabs, non-specific genetic performance testing, indicator organism swabs, or protein swabs on Zone 1 sites, finding a positive swab implicates finished products, while a Zone 2 or Zone 3 positive may not have a direct impact on the finished product. A Zone 1 positive for a pathogen should at a minimum indicate that the finished products manufactured since the last break-and-clean should be placed on hold.