Conducting micro tests without fully understanding why?

We are doing some micro testing, but no one seems to know why we are doing certain tests. We are sending them out for analysis at a lab. We are doing a water test (total coliforms and E Coli), finished product testing of cakes( E Coli, Salmonella, and Listeria), and we are doing some swabs around the plant (salmonella and listeria). We are a low risk facility and I was trying to find documents validating what auditors may want. This is a plant in the US.

Thanks!

We are doing some micro testing, but no one seems to know why we are doing certain tests. We are sending them out for analysis at a lab. We are doing a water test (total coliforms and E Coli), finished product testing of cakes( E Coli, Salmonella, and Listeria), and we are doing some swabs around the plant (salmonella and listeria). We are a low risk facility and I was trying to find documents validating what auditors may want. This is a plant in the US.

Thanks!

I am an auditor and speaking as one I can tell you it is not "what the auditors may want"... it is what the audit they are doing calls for.

As an example XYZ Grocery chain wants all facilities to do micro testing for the big items that you mention, they have built it into their audit that the auditor then rates your facility based on the criteria in tbe audit.

Now, if folks don't know why certain tests are being called for - go to the source that is asking for the testing to be done, whether that is a grocery chain or another concern.

With that said I know of many so-called "low risk" facilities that are conducting tests on a routine basis for EC, Salmonella, and Listeria.

Dear hsalazar,

Your post appears to imply that nobody in the facility has a level of microbiological knowledge such as to understand the significance of the items you mention. and presumably the subsequent results also.

Practically (and auditorially), this is not exactly a vote of approval for yr QA department ?

Or is this an additional (remote) function of yr external laboratory ?

Rgds / Charles.C

I agree with Charles. Your post shows the lack of knowledge and the lack of professionalism. If you don't know why the tests are done, go back and find out when they started, investigate who started them and why. If you are unable to find this out, verify where are you sending results: to clients, government representatives, or just keeping them on file? If you are doing tests and only filing results, without submitting them to anyone, you are wasting some serious money. I know that in my facility we have to do micro tests that are required by a government (on any level) and required by customers (some customers are very specific for micro tests).

I recently help set up a new production facility and verification microbiological testing came up as a topic. I had to decide what to test for and at what levels I would get concerned.

To be honest, what helped me in the end was looking at the retailers' standards for what they'd expect (even though we were branded). Not only did that give us some idea of what to test for but also how often.

In crude terms, you're checking for pathogenic organisms but perhaps they aren't the best idea. You could look at testing for TVC / aerobic count (which will then give you an idea things are moving out of control before you have a pathogen positive.)

I suspect Listeria is unlikely on your finished product so it might be you can reduce the frequency of testing for that?

Also I would be tempted to swab for TVC / Enterobacteriacae (which will give you some indication if you have potential for an E Coli / Salmonella issue), yeasts and moulds. I would probably stop swabbing for Salmonellae and Listeria altogether.

As PP have said, your contract laboratory can be a great source of advice for this kind of thing too.

Dear hsalazar,

Slightly OT

If one goes back to the reasons which drove the introduction of haccp, a major item was the ubiquitous global existence of nonsensical microbiological specifications and the associated routine mass testing of end products.
This is more politely reiterated in the classic 2003 Codex hygiene document.

However I guess retailer’s may have little choice from a legal protection point of view, especially in the current litiginous climate, plus IMEX many processor MDs will cheerfully sign off on the most ridiculous micro. specs just to avoid hassle. And we all know where any later problems get dropped on.

Some countries may have their own micro.culture also. The OP is apparently in USA which I believe has an official tradition of “Listeria” hunting for all types of food process, regardless of whether the finished product is raw or RTE, wet or dry. This perhaps was a derivative of their Salmonella inspection scheme, containing by far the highest routine sample size procedure in the world AFAIK.

Accordingly, although I stick to my belief that without knowledge your risk is unlimited, the 2nd/3rd posts may (sadly) spell out the practical necessities, regardless of any risk assessment or cost factors. Of course, the results may verify a blanket attack. Presumably you have some idea about this already ?

Rgds / Charles.C

Oh - so torn. I understand hsalazar's confusion but I adore psunjka's spunk!!

From my perspective in Ireland, legally, you are only required to test your water to ensure it is fit for human consumption. After that it's all based on risk analysis - enough swabbing of surfaces for TVC and listeria to ensure your cleaning is effective, enough sampling of product to ensure your personal hygiene, purchasing and process controls are effective. Alot of companies make the mistake of asking "what auditors want" instead of "what we want". Look at your ingredients (bacillus survives in flour, maybe you could test final product to ensure baking is capable of killing it, do you add milk or eggs to your cakes - could these be a listeria or salmonella risk), look at your staff (could they be a hazard and introducing Staph Aureus to the product - test and find out. Are they washing their hands after using the toilets? test for entero) and look at your process (how do you cool the product? Could there be a risk of yeast and mould contamination?).
"What auditors want" is a good kicking from time to time (sincere apologies to all auditors on the boards - you know it's true though!). They will try to convince you that you need more and more testing, but if you have your systems written up properly, either though the microbiological hazard analysis of your HACCP or as part of a risk assessment, you can just go "psunjka" on their asses!