Raw, RTE, fresh produce processing is microbiologically complicated. Particularly due to the absence in the typical process of any microbial pathogen “elimination” stage.
I agree with the previous post that you are going to have to perform some risk assessment.
I get the impression that there is currently no microbiological EMP in yr facility. I presume yr production falls within the jurisdiction of FDA so one logical step would be to determine FDA’s specific requirements, eg as discussed in the attachment below (this is 2013 file so necessary to check if still up-to-date). Offhand, I think, that Primus also offer a highly detailed Q/A document to support the audit questions in their FS Standard for Produce Packinghouses. It’s available somewhere on this Forum (I’ll post back if I can find it).
As an example of the complications associated with a RTE manufacturing facility here is a FSIS quote regarding listeria env. monit. progs. –
In most circumstances a LEMP should not extend into raw processing areas (e.g., ingredients, raw meat and fish, and unpasteurized dairy products) as it is assumed these areas are likely contaminated. Some facilities may not have truly defined raw and RTE areas, in this case the all production room with exposed at-risk may be included (e.g. fresh cut produce, salad assembly).
This is not my product area but the attached US Fresh Produce Manufacturer’s Guidance Manual looked quite comprehensive and useful. I noticed this comment regarding drains –
Drains provide a convenient monitoring point in wet areas or areas where equipment is washed down during cleaning and the water is likely to carry Listeria from harborage points to a drain. When swabbing drains, it is important to perform the swabbing prior to use of any sanitizing treatments that may mask the presence of Listeria. Sampling inside drains during operations is not recommended as the activities involved, such as removing the drain cover, drain basket and reaching down inside a drain to sample, may create an pportunity to spread any contamination into the product handling area. If sampling drains during operation, swab the cover and exposed surfaces around the drain.
There is considerable disagreement over whether drains should be included in an environmental sampling program due to the difficulty that arises in determining how to interpret the relationship between a positive drain sample and the potential for product contamination. It is sometimes better to maintain a strong program to control Listeria in and around the drains through use of a sanitizer applied during operations, and by controlling traffic and minimizing the use of water and air hoses that potentially can spread contamination during operations. Greater emphasis should be placed on sampling floors in coolers, near packaging lines and near drains when they are located under or near packaging lines. Sampling drains may be beneficial during investigations and source tracking.
Guidance on Environmental Monitoring and Control of Listeria for the Fresh Produce Industry (2013).pdf 646.46KB
Offhand, I cannot recall ever seeing any general micro. specification proposed for a drain within a fresh raw material process area. But I can appreciate fresh produce is tricky as noted above.
Interesting to hear what any fresh produce operators here are actually doing.
PS - googling "listeria control in fresh produce production" will immediately show some other useful references/guidances, eg -