Drain EM
Hi Everyone,
I recently accepted a position in a frozen fruit and veg repack facility and was wondering how best to perform plant EM. The last facility I worked at manufacture gummie vitamins, so it was really easy. It was just ATP swabs and drains for listeria and Enterobacter once per week. Our enterobacter was allowed to be <10 cfu/plate, and we had a zero cfu for listeria.
I wanted to do the same thing here with our drains, but for coliforms/ e.coli, and listeria. Would the limits be the same? Is it acceptable to have <10 cfu of e.coli and coliforms in your drains?
Thanks all, and sorry i'm sure this was asked before. I'm pretty new to the site.
Welcome to the site NickDeeFFD
There are pretty in-depth discussions on IFSQN on this subject here: http://www.ifsqn.com...ts-in-the-fsma/
Someone else who's a produce manufacturer: http://www.ifsqn.com...se-some-advice/
Discussing floor drains: http://www.ifsqn.com...d-floor-drains/
FDA has guidance for environmental monitoring for listeria: http://www.fda.gov/F...P/ucm073110.htm
(LINK BROKEN / Charles.C,080719)
AIB has a pretty good document discussing how to set up your initial limits and some examples for zoning: https://www.aibonlin...ningHazards.pdf
You're in a tough industry for this right now, I would highly recommend reading the warning letters for CRF frozen foods, Oregon Potato Company, Blue Bell (including form 483's), Aspen Hills, and anyone else with warnings for environmental listeria. Look at where FDA is swabbing and set-up your program with zones and similar locations to hold your plant to the same standard as a goal (you're probably not there yet).
Make sure that if you ramp up testing that your management team is ready to deal with results and eliminate the pathogen from the area. "Clean and test again" isn't a satisfactory control method anymore if it keeps showing up periodically. The goal needs to be pathogen elimination, which will result in things like captive footwear, floor improvements, construction, etc. Playing the double standard of "if it's in a drain it's in the room, but because it's in the drain it doesn't affect the product" is also not in line with FDA's current thinking.
Your program should celebrate finding a pathogen as an opportunity to eliminate it, but if you don't yet have management commitment or resources identify your highest risk areas and start there with risk assessment, expanding outward as you gain control of your highest risk areas.
As always, don't test equipment/areas until you have control of any implicated products/materials or are prepared to initiate a recall of implicated materials.
Hi Nick,
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).
http://www.ifsqn.com...ns/#entry102854
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 156 downloads
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 -
addendum -
The Primus document is in this post (see "agri1") together with various other fresh produce files -