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Environmental Monitoring Program - SQF Ed. 8


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#1 kbraswe2

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Posted 02 January 2018 - 06:23 PM

I am way behind on getting our SQF manual updated to Edition 8. Currently, I am working on section 2.4.8 - Environmental Monitoring. Right now, the only environmental monitoring we do is ATP Swabs. We do not swab for any pathogens or indicator organisms. In our plant, we manufacture acidified foods, with most of the foods being in the 2.5-3.9 pH range. (Sauces, pickled items, dressings, etc.). These foods are thermally processed and we have certain CCPs that are checked on a regular basis (pH, temp, etc.). We also send off samples from every run of acidified product to a laboratory to be tested for APC, E.Coli, Yeats, Molds, Salmonella, and Lactic Acid Bacteria.

 

According to the new SQF Module 2 Guidance Document "An environmental monitoring program must be in place for food processes that are handled, exposed, stored, processed or packed. This program should be included for food processes of all risk levels." It then goes on to say "An environmental monitoring program (EMP) is a program which includes pathogen swabbing to detect risk in the sanitary conditions of the processing environment and is a verification of the effectiveness of the pathogen controls that a management site has in place for high risk foods (refer Appendix 2: Glossary of Terms).

 

According to the Appendix 2: Glossary of Terms - 

 

High Risk Food Food or food product with known attributes for microbiological growth, physical or chemical contamination, 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.

 

Low Risk Food A food containing high acid that is not known to support the growth of pathogens; a food that is subject to a full cook prior to consumption.

 

So, my question is, do we have to swab for pathogens/indicator organisms or can I do a risk analysis saying that the food we produce is low risk? Or am I looking at this completely wrong. I am still new to this field and am still learning. 



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#2 Timwoodbag

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Posted 02 January 2018 - 06:45 PM

In a similar situation as you, our consultant said that what it means is you need to have an EMP regardless of product, but only high-risk foods are currently forced to pathogen test to meet this requirement.  That said, she believes that low-risk companies still have to prove that the environment does not pose a risk of pathogen introduction, which is very hard to do without pathogen testing.  We are going to argue the low risk status of our industry, combined with zero pathogen findings in the history of our products industry (coffee) leads to us not having to test for pathogens.

 

We will see if that is acceptable or not come September!



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#3 sqflady

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Posted 04 January 2018 - 01:12 PM

I think even though you have a low risk product, you have to consider risks from your environment and the potential for cross-contamination.  Do any of your raw materials come in with potential pathogens?  What is the potential for cross-contamination of finished product?  You could probably take a couple of swabs per week which might be easier than trying to argue your product is low risk. 



#4 Bradley

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Posted 10 January 2018 - 10:34 PM

I agree with SQFlady. I would rather be safe than sorry. We have a 30,000 Sqft building and deal with dry spices, we do 15 sites per week based off of the 4 zones. We test for listeria, Salmonella, E.coli and indicator organisms. You might not need to start with that many but we started out doing 30 per week and then we were able to justify going down on the number of swabs based off of our findings. The big key area to hit is that you have identified your zones (1-4) and have a master list of swab sites that you hit and then you randomly hit every site in a certain time frame. It does make me feel a lot better knowing that we are checking everything from the front office, trench drains, walls all the way to the food contact surfaces to try to find it. If SQF doesnt get you on it then the FDA will. I know they are going to go into your facility and do a "swabathon". I want to find it first if we have any issues. Good luck!



#5 SQFconsultant

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Posted 11 January 2018 - 03:06 AM

I agree with Timwoodbag's consultant. 

 

Follow the code requirements and  you won't go wrong, it's not an area that you want to get hit with a major come audit time.

 

So many people want to do risk analysis's and so many of them are not objective. It is difficult to do a risk analysis objectively when  you want the outcome to be in your favor... and that makes the outcome subjective very often.


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#6 fsweet

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Posted 16 January 2018 - 05:59 PM

Question on this topic... 

 

I'm sorry I'm aware that this may be a completely dumb question, but I really do not know. Is swabbing something you send off to a lab, or is it an immediate test that I can buy? If it's an immediate test, where can I buy them?

 

Thank you!



#7 FurFarmandFork

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Posted 16 January 2018 - 07:08 PM

Question on this topic... 

 

I'm sorry I'm aware that this may be a completely dumb question, but I really do not know. Is swabbing something you send off to a lab, or is it an immediate test that I can buy? If it's an immediate test, where can I buy them?

 

Thank you!

It depends on what organisms you're sampling for, how sensitive the method is, and how much you're willing to pay.


Austin Bouck
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Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

#8 Charles.C

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Posted 16 January 2018 - 09:04 PM

Question on this topic... 

 

I'm sorry I'm aware that this may be a completely dumb question, but I really do not know. Is swabbing something you send off to a lab, or is it an immediate test that I can buy? If it's an immediate test, where can I buy them?

 

Thank you!

 

No questions are dumb. :smile:

 

"swabbing" in the context of EMP usually means sampling (eg touching/wiping over) a small area of a surface of "something in the Environment" with the intention of evaluating/measuring some characteristic of that surface, eg the presence of an allergen or microorganism.

 

The tool used for "swabbing" is known as a "swab", eg a Q-tip, or an absorbent cotton pad, or a Petrifilm "plate".

 

can try link in this post -

 

http://www.ifsqn.com...ap/#entry120706


Kind Regards,

 

Charles.C


#9 kbraswe2

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Posted 23 January 2018 - 07:16 PM

I have started creating my EMP now, and have us swabbing for Listeria in zones 2-4 and APC in zone 1. I have done tons and tons of reading and am still confused as to which pathogen(s) I should be swabbing for. We produce acidified products (sauces, dressings, pickles, relishes) as well as preserves, jellies, coffee syrups, fruit  butters, etc. Our environment is a wet environment. Should I be swabbing for Listeria or Salmonella? If Listeria, what is the difference between Listeria Spp and L. Monocytogenes? Any guidance would be helpful.



#10 Charles.C

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Posted 24 January 2018 - 01:44 AM

I have started creating my EMP now, and have us swabbing for Listeria in zones 2-4 and APC in zone 1. I have done tons and tons of reading and am still confused as to which pathogen(s) I should be swabbing for. We produce acidified products (sauces, dressings, pickles, relishes) as well as preserves, jellies, coffee syrups, fruit  butters, etc. Our environment is a wet environment. Should I be swabbing for Listeria or Salmonella? If Listeria, what is the difference between Listeria Spp and L. Monocytogenes? Any guidance would be helpful.

 

Hi kbraswe,

 

I assume the SQF guidance did not nominate specific requirements.

 

Listeria spp means the Group (Genus) of Listeria species. Within this group,  L.monocytogenes is, IIRC, the only common human pathogen.

 

It's relatively easy to detect that a member of the Group is present but only further testing for L.mono confirms that this pathogenic species is present.

 

Regarding choice of monitoring, there may be a US regulatory requirement for yr product (particularly L.mono) - no idea. Sorry.

 

Generally EMP opinions can vary but typically the pathogenic focus is on Listeria/L.mono for wet environments, Salmonella for dry. But see the documents attached in these posts for a range of situations (eg AIB/others have generic tables) -

 

http://www.ifsqn.com...ls/#entry100060

 

http://www.ifsqn.com...am/#entry119334


Kind Regards,

 

Charles.C


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#11 NancyVnz

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Posted 24 January 2018 - 04:04 AM

Hi all,

 

We produce ready to eat food with low pH (sushi) and we have a testing verification program in place that verifies the effectiveness of the minimization of Listeria contamination. We do swabs every month for Listeria spp. For product testing, we send samples every quarterly to lab and test for Listeria.monocytogens, Salmonella, Campylobacter, Fecal Coliforms, E.Coli, TPC, Staph., Bacillus cereus. 

 

Now I understand that these testing are to verify that we have had an effective Food Safety Program that supports our production to produce safe food. We self-set our Food Safety Program from a long time ago and now I want to review the frequency of the tests. Can we reduce the frequency cause we had absent and under criteria all the time. I think ICMSF may have a standard on the frequency for these test but I could not find.  



#12 Liz Estrada

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Posted 17 October 2018 - 03:45 PM

No questions are dumb. :smile:

 

"swabbing" in the context of EMP usually means sampling (eg touching/wiping over) a small area of a surface of "something in the Environment" with the intention of evaluating/measuring some characteristic of that surface, eg the presence of an allergen or microorganism.

 

The tool used for "swabbing" is known as a "swab", eg a Q-tip, or an absorbent cotton pad, or a Petrifilm "plate".

 

can try link in this post -

 

http://www.ifsqn.com...ap/#entry120706

 

 

Hi!

 

Thank you for the information because when EMP was mentioned, I assumed that only "plate" could be used for the environment, but a "swabbing" can also be used.


Edited by Liz Estrada, 17 October 2018 - 03:47 PM.


#13 Sweet_Lew

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Posted 26 October 2018 - 06:20 PM

I am working with a client who produces low risk product. The EMP we put in place check for indicator organisms with verbiage stating if an indicator is detected an additional test which will include a specific pathogen will be conducted. Because you are low risk and the product you produce does not provide an ideal environment for pathogenic growth this EMP should be find. Also your frequency can be annual.



#14 Charles.C

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Posted 27 October 2018 - 08:30 PM

I am working with a client who produces low risk product. The EMP we put in place check for indicator organisms with verbiage stating if an indicator is detected an additional test which will include a specific pathogen will be conducted. Because you are low risk and the product you produce does not provide an ideal environment for pathogenic growth this EMP should be find. Also your frequency can be annual.

 

Hi Sweet Lew,

 

Thks yr input but do note that this is a relatively "young" SQF8  thread. Some of its content has been overtaken by history. Can compare to other more recent threads.

 

I think perhaps you omitted a "not" in the penultimate sentence.


Kind Regards,

 

Charles.C





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