22 replies to this topic

[Parkz58]

Hello Fellow Food Safety Colleagues,

 

I am looking for some help in determining whether or not our facility really needs an Environmental Pathogen Monitoring Program or not.  We are going to be seeking SQF Level 2 certification in the near future, and our facility is somewhat unique, I believe.  We are processing grain (oats), and the only two functions we'll be performing are de-hulling (to create oat groats, an entirely dry process), and then steam-rolling oats (steaming oats in a special chamber for 15 minutes at over 200 degrees F.

 

The facility will only be dry cleaned, with the exception of cleaning the chamber and a short cooling conveyor after the steaming process.

 

These are both very shelf-stable products, with very little (almost none) inherent risk for pathogenic contamination.

 

With other controls in place, like a captive boot program (footwear used at work is kept on-site and not allowed to be worn off the premises), I'm struggling to see how we would need to have an environmental monitoring program.

 

Thoughts?  I would appreciate any and all input on the matter!

 

Thanks,

 

Brian

[QAGB]

Hello Fellow Food Safety Colleagues,

 

I am looking for some help in determining whether or not our facility really needs an Environmental Pathogen Monitoring Program or not.  We are going to be seeking SQF Level 2 certification in the near future, and our facility is somewhat unique, I believe.  We are processing grain (oats), and the only two functions we'll be performing are de-hulling (to create oat groats, an entirely dry process), and then steam-rolling oats (steaming oats in a special chamber for 15 minutes at over 200 degrees F.

 

The facility will only be dry cleaned, with the exception of cleaning the chamber and a short cooling conveyor after the steaming process.

 

These are both very shelf-stable products, with very little (almost none) inherent risk for pathogenic contamination.

 

With other controls in place, like a captive boot program (footwear used at work is kept on-site and not allowed to be worn off the premises), I'm struggling to see how we would need to have an environmental monitoring program.

 

Thoughts?  I would appreciate any and all input on the matter!

 

Thanks,

 

Brian

 

 

Hi Brian,

 

I could see an environmental pathogen monitoring program being used in the steam area of your process (possibly even your cooling conveyor as well). I don't know how much moisture pooling you would have there. However, I could see swabbing of equipment and any areas where moisture may pool and possibly be a concern (drains, condensation on walls/ceilings, etc.). Moisture and heat can create a good breeding ground for pathogenic bacteria, so you should take a look at your setup to determine whether the monitoring would be necessary.

 

QAGB

[Charles.C]

Hello Fellow Food Safety Colleagues,

 

I am looking for some help in determining whether or not our facility really needs an Environmental Pathogen Monitoring Program or not.  We are going to be seeking SQF Level 2 certification in the near future, and our facility is somewhat unique, I believe.  We are processing grain (oats), and the only two functions we'll be performing are de-hulling (to create oat groats, an entirely dry process), and then steam-rolling oats (steaming oats in a special chamber for 15 minutes at over 200 degrees F.

The facility will only be dry cleaned, with the exception of cleaning the chamber and a short cooling conveyor after the steaming process.

These are both very shelf-stable products, with very little (almost none) inherent risk for pathogenic contamination.

With other controls in place, like a captive boot program (footwear used at work is kept on-site and not allowed to be worn off the premises), I'm struggling to see how we would need to have an environmental monitoring program.

Thoughts?  I would appreciate any and all input on the matter!

 

Thanks,

 

Brian

Hi Brian,

 

Not a user of SQF myself so apologies if i have misunderstood yr OP.

 

Not sure what module this is related to?  10 ?

 

Regardless, I cannot see any references in SQF to Environmental Monitoring Programs  other than EMP being mandatory for those processes related to  "high risk food"  ? eg  para. 11.7.4.v in GMP and other module-specific entries, eg 10.7.3

 

High risk food is food that may contain pathogenic microorganisms and will support the formation of toxins or growth of pathogenic microorganisms, and has a significant likelihood of growth causing illness or injury to a consumer if not properly produced, processed, distributed and/or prepared for consumption.  It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak (refer SQF Code, Appendix 2: Glossary).

 

 I assume "food" refers to the output. Typical SQF precision. I note the glossary definition includes allergenicity which i presume this product may/may not have ?

 

So does yr risk assessment / other elements in above definition,  consider that yr finished product is a high risk food ?

 

If so, it appears you need an EMP with scope as, for example, in the Guidance although a "minimum" requirement is mentioned in the Code.

 

If not, apparently not.

[Parkz58]

Thank you both for your responses.  Charles, I believe you are right - the SQF code doesn't specify that an EMP is needed unless it's a high-risk operation (which ours definitely is not...our operation is about as low-risk as you can get, I believe), but I just wanted to see if anyone out there knew something I didn't, because I'd rather be safe than sorry.

[Charles.C]

Thank you both for your responses.  Charles, I believe you are right - the SQF code doesn't specify that an EMP is needed unless it's a high-risk operation (which ours definitely is not...our operation is about as low-risk as you can get, I believe), but I just wanted to see if anyone out there knew something I didn't, because I'd rather be safe than sorry.

 

Hi Brian,

 

How about the allergenic aspect ? From a quick look on the Net, "Oats" seemed to be in a grey area. But perhaps not from SQF's POV.

[Parkz58]

Good question, Charles...oats themselves are not considered an allergen, but they have been known to end up with wheat or soy mixed in to them at times (carelessness, or simple ignorance, at the grain elevator is usually the cause - storage and handling techniques that don't take allergen cross-contamination into account).  Therefore, some people consider oats to be enough of a "wild card" that they'll just lump them in as a potential allergen for people who are gluten-sensitive.

 

So, the most effective way to prevent that from being an issue is to be careful how you source them (Approved Supplier program), and ensure your sampling and inspection procedures are rigorous at the time of receiving (with clear RME specifications).  There is even a certification process out there whereby you can have your oats and oat process certified as "gluten-free", just to satisfy those people who feel they can't trust regular oat processing.

 

I wasn't even considering allergens in the scope of this question, because I was referring only to pathogenic testing at the environmental level.  Our Allergen Control program has completely separate swabbing/sampling/testing protocol.

 

Brian

[Charles.C]

Hi Brian,

 

I only picked it up via the Glossary definition of high risk food -

 

Food or food product with known attributes for microbiological growth, physical or chemical contamination or a known food allergen, or which due to a process type may allow for the
survival of pathogenic microbial flora or other contamination which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk
by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak.

 

For some reason the "allergen" bit seems to be lost in  defs given  of "high risk food" in other places in the Code/Guidance.

 

But, as i understand, yr input/output is certified/validated allergen free so the ambiguity not relevant anyway.

(It might also be interesting as to whether SQF are only focussed on "labelling" allergens for this context)

 

TBH, I'm not sure what the red text actually means.

 

PS - Actually i find this non-requirement for low risk foods rather odd since my own (wet) experience is also low risk for BRC but implements micro. indicator monitoring for cleaning verification (could be done via ATP though). Maybe that is the purpose of the red text, post-steaming for example as Post2. Too many options for comfort.

[RMAV]

IIRC, "High Risk" would be defined by your food sector category *or* if a customer has deemed your operation "high risk."  I'm going by memory so verify this with the code before taking my word for it.

[jweitzel]

Hi Brian,

I work as the Food Safety Manager at a dry product company that cleans dry beans and packages many products including oats. We buy our oats already processed out of an outfit in Canada. I had a consultant in from BRC as that is the GFSI certification that we are pursuing. He provided us with a HACCP template for dry beans that argues that biological hazards do not need to be considered as the beans will be cooked to a temperature above the kill level for the major 8 pathogens found in our type of plant. This is an alternative approach that would argue environmental testing is not needed. I spoke to another expert that told me that environmental testing after dry cleaning would be a mistake as dry cleaning would not be able to remove any pathogens. I have provided below a sample of the HACCP section discussing biological hazards for your review.

Biological: Dry beans/peas do not have any inherent pathogens to cause illness. It is possible, however, for
external pathogens (such as E Coli, Salmonella, etc.) to become attached to beans/peas at the farm or,
in some cases, at this facility.


Time and temperature kills pathogens according to the following:
Temp F° Time Where Source
Norovirus 194 >90 sec. Internal New Zeeland Food Safety Authority
Salmonella 160 <10 sec. Internal FSIS, USDA 9 CFR 381.150(b)
Hepatitis A 185 <10 sec. Internal J.V. Parry, Virus Ref Lib, London, Eng.
Shigella 149 <10 sec. Internal New Zeeland Food Safety Authority
E Coli 160 <10 sec. Internal FSIS, USDA 9 CDR 381.150(b)
Clostreidum botulinum 180 10 min. Internal Colorado State Univ. Botulism Fact Sheet
Campylobacter 160 <10 sec. Internal FSIS, USDA 9 CFR 381.150(b)
Listeria 160 <10 sec. Internal FSIS, USDA 9 CFR 381.150(b)

The University of Nebraska, Lancaster County Extension Education, states that to properly cook
beans/peas, the beans/peas are to (212°F) and then be simmered (defined by several publications as 185°F plus) for 1.5-2.0 hours. Such cooking will inactivate all the above mentioned pathogens. Since all beans/peas processed at this facility will be cooked after they leave this facility, no biological factors are considered to be hazards at this facility.

This is my first reply to anyone on the forum, but I felt your pain with this as guidance for raw dry products has been scarce.

Good Luck,
Jeremy

[Charles.C]

Hi Jeremy,

 

Thks yr input and Welcome to the Forum 

 

I have to admit I'm a little confused over the "Environmental Testing" being discussed in this thread.

 

Basically the justification for doing ET is typically a result of the possibility of the environment contaminating the product after cooking since there are no subsequent bacterial elimination steps unless the product is further cooked by the consumer which i assume is not the case.

 

So the necessity for ET is logically dependent on the hygienic/pathogenic condition of the relevant environment. This is often closely related to factors like (a) the micro. status of the raw material, for example various dry nuts are a classic Salmonella carrier, (b) the process layout, (c)  transport flows, (e) equipment etc

 

Offhand I would have anticipated a situation more like Post 2 but perhaps oats/beans processes somehow represent a special case. I hope so.

 

Thks again for yr post.

[jweitzel]

Hi Charles,

Thank you for the feedback! I was assuming his oat process was like our bean process in that the customer would be performing the kill step of cooking as we do not cook any product here or package any ready to eat product. Everything is a dry raw product.

My suggestion to Brian was based upon my observation that guidance for HACCP and Food Safety in general has been less available for low risk foods such as ours.

Thank you,
Jeremy

[Parkz58]

Wow, some great and helpful discussion on this thread - thanks to all of you who have chimed in!

 

Jeremy, I believe our operation is VERY similar to yours, and the inherent risks with oats (as we are processing them, anyway) would be very much in line with beans - they are designed to be cooked prior to consumption.

 

So, we're producing a product that does not have significant inherent pathogenic risks, and we're producing food that is not only NOT RTE, but requires boiling (or other cooking) that would be at boiling temperature (or greater), thereby clearly constituting a kill step at the consumer level.

 

Based upon all of this, plus the GREAT information that Jeremy has shared (I can't thank you enough, Jeremy!), I believe my question has been answered...ultra low risk process and product + consumer kill step = no need for pathogenic environmental testing.

 

Brian

[Charles.C]

Wow, some great and helpful discussion on this thread - thanks to all of you who have chimed in!

 

Jeremy, I believe our operation is VERY similar to yours, and the inherent risks with oats (as we are processing them, anyway) would be very much in line with beans - they are designed to be cooked prior to consumption.

 

So, we're producing a product that does not have significant inherent pathogenic risks, and we're producing food that is not only NOT RTE, but requires boiling (or other cooking) that would be at boiling temperature (or greater), thereby clearly constituting a kill step at the consumer level.

 

Based upon all of this, plus the GREAT information that Jeremy has shared (I can't thank you enough, Jeremy!), I believe my question has been answered...ultra low risk process and product + consumer kill step = no need for pathogenic environmental testing.

 

Brian

 

Hi Brian,

 

As I now understand, yr output is NRTE.

 

I'm curious - so why do you heat process it ? To make it softer ?

 

Do also note that to qualify as NRTE, the final consumer boiling step must usually be stated on the label.

[Parkz58]

Hello Charles,

 

Yes, the steam process is primarily to soften the oat groat before rolling it, allowing it to roll uniformly and without breakage.  It still needs to be cooked before eating (think oatmeal), so it is NRTE, as you mentioned.

 

Brian

[trubertq]

I would have thought your cleaning efficacy needs to be verified. I'm sure you have people working in your facility, and they can carry in all sorts. Is it a closed air system?

 

Anywhere you have moisture and warmth can promote pathogen growth, and it doesn't take much to introduce a pathogen into a facility, on packaging for example. I don't suppose you'd need a huge amount of environmental monitoring but I would think some would be necessary.

[trubertq]

and what I forgot to add to the previous post... risk assess and document, then you have your reasoning on paper if you are ever questioned about your decision.

[biljaa]

Hello Brian, I realize this is the old post but I hope you are still monitoring it ...anyways, I have a similar problem as you regarding EMP , I am struggling with EMP program in dry cleaning environment. I work for low-risk dry corn mill facility very similar to oats- I  am attempting to establish an EMP program to satisfy new SQF 4.8 requirement.  I was wondering if you had any suggestions regarding this or how did you handle this requirement in your facility, if you are willing to share. Thank you

[Charles.C]

Hello Brian, I realize this is the old post but I hope you are still monitoring it ...anyways, I have a similar problem as you regarding EMP , I am struggling with EMP program in dry cleaning environment. I work for low-risk dry corn mill facility very similar to oats- I  am attempting to establish an EMP program to satisfy new SQF 4.8 requirement.  I was wondering if you had any suggestions regarding this or how did you handle this requirement in your facility, if you are willing to share. Thank you

 

I daresay Parkz58 (Brian) will respond but I might add that IIRC other threads here have noted that SQF does mandate a risk assessment but, based on the RA results, not necessarily an operational EMP program (see the Guidance).

 

PS - i assumed you meant 2.4.8

[Joseah njuguna]

Hello Brian.

I believe there is a specification for your final product especially on Microbial Limits.

From where I sit I want to believe that you can even get a stringent requirement from the client.

The cooking bit should be a plus on safety.The ability to control your environment establishes your commitment towards food safety.

In my experience I have always set out to test raw materials from low risk areas and I have found that they tend to be a bit careless.

 

Have an EMP do the swabs and environmental monitoring bi annually for testing the effectiveness this is a workable frequency for low risk areas.

 

 

Whats your take?

[FurFarmandFork]

Hi Brian,

 

Agree with the above, if you are specifically calling the product NRTE and not treating your steam treatment as a kill step, probably no need for an EM program because presumably the material itself might contain those pathogens as an expected input.

 

I'm a bit curious about the captive footwear program. Did you implement for personal safety or food safety? An obvious auditor question would be if you don't think pathogens on the floor would be an issue, then why do the boots?

[Parkz58]

Hello Brian.

I believe there is a specification for your final product especially on Microbial Limits.

From where I sit I want to believe that you can even get a stringent requirement from the client.

The cooking bit should be a plus on safety.The ability to control your environment establishes your commitment towards food safety.

In my experience I have always set out to test raw materials from low risk areas and I have found that they tend to be a bit careless.

 

Have an EMP do the swabs and environmental monitoring bi annually for testing the effectiveness this is a workable frequency for low risk areas.

 

 

Whats your take?

Hi Joseah,

 

No, we don't have a microbiological finished product specification, because our product is NOT RTE, and it's only used for further manufacturing of animal feed.  Our customers don't have any want or need for micro specs or testing.  I have a third-party scientific study showing that in the top 25 most commonly found genotypes of Salmonella in oats, which comprise over 99% of all genotypes found in oats, none of them are pathogenic to any of the species of livestock that our product would feed.  Salmonella is really the only micro that is of any concern in oats; therefore, we have no need for micro testing or specifications.

 

We also have a dry processing environment, so our risk for environmental pathogens is incredibly low.

 

Charles.C, you are right in your assessment of my likely response, hahaha...that's exactly what I would have said!

 

FurFarmandFork, our captive footwear program is to protect from external contamination only.  We have no concerns about contamination within the plant itself; however, it could become a problem if contamination is brought in from the outside environment.

 

Brian

[biljaa]

Hi everybody, thank you so much for all your answers -- it really clarifies things for me in our mill that is food non rte. biljaa

[Scampi]

I want to add that the risk assessment portion is mandatory, but an actual EMP is not (depending on RA)

 

None of the known pathogens can survive in my finished goods so testing for them is redundant (plus we are on farm so I know there is listeria around)