Written by Shawnil Guiles, Food Safety Auditor
Do you have anxiety about the Food and Drug Administration (FDA) coming into your facility and finding little organisms that could potentially lead to a major recall of product? As many know, when it comes to food safety, there is little to no room for unpreparedness. The best defense is always a good offense, and that is where your food safety plan comes in.
One of the pillars of a strong food safety plan is a robust Environmental Monitoring of Pathogens (EMP) program. But, where to begin? If you are building your EMP from scratch or trying to figure out how to make your program stronger, then you have come to the right place. With this article, you can begin to evaluate your EMP program and find tips to get you started on the right path.
Environmental Monitoring First Steps
First things first, an environmental monitoring program is a program that assesses your facility’s hygienic practices and prevents microbial contamination of food. For example, this program searches for pathogens like Salmonella, E.Coli, and Listeria. A successful EMP program first determines the level of risk for the food products in question. It assesses the environment (all the surfaces and spaces used) of the production process, in other words, a risk assessment. You base a risk assessment on two things: the likelihood of an event happening and its severity.
It is important to remember that every food product reacts differently to its environment, each with a unique set of factors that determine the level of risk. During your audit, you may be asked risk-based questions specifically about EMP programs. Which is why, environmental monitoring is never a one-time deal, but instead a way of life.
Questions to ask yourself when assessing the risk of your food facility and developing your EMP Program:
- Do you produce ready to eat products? Do you sell your products for further processing?
- What pre-requisite programs are in place to limit cross-contamination/ potential adulteration?
- What processing steps are in place to limit cross-contamination/ potential adulteration?
- Do you know your Zones within your facility?
- Does your process need treatment to reduce pathogens, sometimes referred to as a ‘kill step?
- How are the process steps managed after a kill step?
- Are any of your products potentially at risk for pathogen growth, based on their chemistry and physical factors’?
- Which pathogens may be most likely to occur with your products and your facility?
- Does your facility perform cleaning, and is it a wet or dry environment?
- Does your facility have drains present that could create a cross-contamination issue?
- What kind of testing do you need for your facility’s EMP program? (e.g., swabs, air plates, water samples, air samples) Which pathogens and which indicator organisms should be tested for?
- How sufficient is your current EMP? Do you swab multiple areas in your plant? Are the same areas being swabbed repeatedly?
- Do you have acceptable thresholds defined for each analysis, and defined corrective actions that are implemented when an unacceptable result is obtained?
- Does your program need a special event swabbing, for example, if there are roof leaks after a rain?
Answering the Hard Questions
To start answering the above questions about your facility, it is essential to look for information from government agencies along with industry guidance (industry associations and food commodity boards). Food safety guidance can also be provided by companies like Safe Food Alliance. Our organization can help create a pathway for developing a strong EMP program.
- FDA on Environmental Sampling
- FDA Draft Guidance: Control of Listeria monocytogenes in Ready-To-Eat Foods
- Food Safety Inspection Services
- Commodity Boards
- UC Davis Food Safety
- Unite Fresh Listeria Environmental Monitoring Information
- Produce Marketing Association: Listeria Information
Food Safety Guidance
- The Benefits of Environmental Monitoring
- Consulting Services
- Environmental Monitoring & How It Relates to FSMA Online Course
Embracing the EMP “Swab-A-Thon”
Another helpful tip to understanding your facility and the need for an EMP program is to perform a baseline. The word “Swab-a-thon” is most often associated with FDA onsite inspections. If you have never heard of the term, we suggest you do some research. During a “Swab-a-thon”, the FDA collects environmental samples, normally while investigating a foodborne illness outbreak. However, they can also conduct swabbing as part of a routine inspection of a food facility. The FDA is particularly famous, or infamous, for their unannounced on-site inspections, where they can collect several hundred swabs from various locations, including food contact surfaces. They swab food contact surfaces, counters, floors, door handles, tools, and anything else that may pose a contamination risk to products.
To limit anxiety and help ensure your company is prepared for a situation like this, the best thing to do is perform your own “Swab-a-thon” event and work closely with a third-party lab to understand what you need for your EMP program. That way, when the FDA comes knocking, you are prepared.
It is always good to remember that the purpose of the EMP program is to find any microorganisms and destroy them, significantly reducing any potential product contamination. By doing so, we can ease the stress of a recalled product or the horror of facing the FDA unprepared.