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Environmental Monitoring, determining pathogens and test frequency?

EMP Environmental monitoring swabs

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#1 paulinewoo333

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Posted 22 January 2019 - 02:57 PM

Hi all, I just need some help in refining my Environmental monitoring program as I am not sure which pathogens and what frequency should we be testing.

 

We are a bakery that produce cookies and cupcakes etc. Are we considering high risks because we are RTE products/Shelf stable?

We currently do weekly ATP swabs, and we swab for TPC, Listeria spp. salmonella, generic E coli, yeast and mold quarterly, I was wondering if it is necessary to do it quarterly or can we reduce the frequency?

 

Is swabbing for just TPC, generic E coli, yeast and mold sufficient to meet the requirements for CIFA and FDA(FSMA)?

 

Please help!!!



#2 Scampi

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Posted 22 January 2019 - 04:08 PM

CFIA has zero requirement for you to test. Your goods do not fall into any of the high risk categories (scientifically once baked pathogens are destroyed; cross contamination should be handled in your PRP)

http://www.inspectio.../1528201904208 

 

(if you haven't already seen this document have a read)

 

 

As per SQF for your FSC:

 

13 Bakery and Snack
Food Processing
ElV: Processing of
Ambient Stable
Products
System elements
Module 11: GMP for processing of
food products
Applies to the processing, transport and
storage of extruded snack foods and cake
mix formulations and extends to all bakery
operations.
Includes baked items such as meat
pies, custard pies, bread, cookies, cakes
and mixes and all varieties of snack
food.
Some high risk
process knowledge
required  (the high risk process knowledge portion will depend on the finished goods (e.g. whether or not meat included/ or say a non refrigerated custard pie that's made with dairy (for example only))

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#3 StevieP

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Posted 23 January 2019 - 01:10 PM

Hi Scampi, could you resend the link you've posted? Its currently not working. This is useful for me.

 

Thanks,



#4 Scampi

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Posted 23 January 2019 - 02:20 PM

that is so weird, it wouldn't open for me either

 

try this one--same info but from health canada, not CFIA

 

https://www.canada.c...foods-2011.html


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#5 PieGuy191

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Posted 23 January 2019 - 02:42 PM

Pauline,

 

In the FDA world under FSMA, baked products are considered Ready to Eat and you are required to have an EMP program.  We produce pies some of which are baked that can be kept at room temperature and some are cream/custard type pies that require refrigeration after bake/cook.  We had our FSMA Preventive Controls audit from FDA in February 2018.  They stated that since we use flour in our product and it has been found to have Salmonella we have to test the environment for it.  We also have to test the environment for Listeria since we produce cream/custard pies that are required to be refrigerated once thawed.  We conduct our environmental pathogen testing quarterly.

 

Hope that is of some help.



#6 StevieP

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Posted 23 January 2019 - 03:14 PM

Hi Pauline, we run a low risk ambient bakery e.g. flapjacks, cookies etc. None of which support the growth of pathogens. We sample the environment for Listeria on a monthly basis, are you suggesting we should be sampling for Salmonella to?



#7 Scampi

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Posted 23 January 2019 - 03:43 PM

The salmonella testing depends on your ingredients and kill step in the actual bake

 

If you are using liquid pasteurized egg, then you could probably swab once or twice a year for salmonella and be sufficient

 

If your using shell eggs, you need to sample for salmonella more frequently.


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#8 PieGuy191

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Posted 23 January 2019 - 03:50 PM

Scampi,

 

I agree with you 100%.  We only use pasteurized eggs for a couple of custard pies, pumpkin, pecan, and sweet potato.  I told the FDA people and they didn't care about the eggs.  They were specifically focused on the fact that we had flour dust and it could be a carrier of Salmonella, hence the testing of the environment.  We were fine with just doing quarterly testing as it fit in with some other things that we do quarterly.  



#9 StevieP

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Posted 23 January 2019 - 04:07 PM

Sounds reasonable. We currently purchase dried egg and so I guess quarterly for flours would probably be enough then given the products we make.



#10 Scampi

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Posted 23 January 2019 - 05:47 PM

Scampi,

 

I agree with you 100%.  We only use pasteurized eggs for a couple of custard pies, pumpkin, pecan, and sweet potato.  I told the FDA people and they didn't care about the eggs.  They were specifically focused on the fact that we had flour dust and it could be a carrier of Salmonella, hence the testing of the environment.  We were fine with just doing quarterly testing as it fit in with some other things that we do quarterly.  

 

1 recall for Coconut flour contaminated with salmonella and the FDA falls apart!!!!

https://www.foodsafe...ows-salmonella/

 

don't you love when the "experts" know less than you but consider their knowledge as gospel!


Because we always have is never an appropriate response!


#11 MsMars

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Posted 23 January 2019 - 08:02 PM

Pauline,

 

In the FDA world under FSMA, baked products are considered Ready to Eat and you are required to have an EMP program.  We produce pies some of which are baked that can be kept at room temperature and some are cream/custard type pies that require refrigeration after bake/cook.  We had our FSMA Preventive Controls audit from FDA in February 2018.  They stated that since we use flour in our product and it has been found to have Salmonella we have to test the environment for it.  We also have to test the environment for Listeria since we produce cream/custard pies that are required to be refrigerated once thawed.  We conduct our environmental pathogen testing quarterly.

 

Hope that is of some help.

 

 

1 recall for Coconut flour contaminated with salmonella and the FDA falls apart!!!!

https://www.foodsafe...ows-salmonella/

 

don't you love when the "experts" know less than you but consider their knowledge as gospel!

 

I'm surprised they narrowed in on a supposed salmonella risk when there was a much larger outbreak linked to E. coli in flour a few years ago... but I digress.



#12 paulinewoo333

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Posted 24 January 2019 - 11:58 AM

Thank you very much for all your responses. I am more clear now on what to expect for CFIA and FSMA. I have heard that If I have a positive with salmonella on a FCS, I will need to initiate a recall according to the new FSMA. But it doesn't make sense, I thought it was only for product sampling, not swabs???



#13 Scampi

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Posted 24 January 2019 - 01:38 PM

this should hopefully clarify that for you (ps have not read it fully)

 

 

https://www.fda.gov/...a/ucm295271.htm


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#14 MsMars

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Posted 24 January 2019 - 02:23 PM

Thank you very much for all your responses. I am more clear now on what to expect for CFIA and FSMA. I have heard that If I have a positive with salmonella on a FCS, I will need to initiate a recall according to the new FSMA. But it doesn't make sense, I thought it was only for product sampling, not swabs???

 

Best practice is to test and hold when dealing with both product sampling and food contact surfaces. Even if you perform product sampling after a FCS+  and products come back negative, your FCS swabs have proved that the right conditions are there for growth or that you've had contamination at some point in the process and product should be considered for disposal.



#15 MsMars

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Posted 24 January 2019 - 02:45 PM

I'm surprised they narrowed in on a supposed salmonella risk when there was a much larger outbreak linked to E. coli in flour a few years ago... but I digress.

 

And as of today, I stand corrected...

http://www.generalmi...nbleached-Flour



#16 Charles.C

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Posted 24 January 2019 - 03:19 PM

And as of today, I stand corrected...

http://www.generalmi...nbleached-Flour

 

Hi MsMars,

 

Perhaps some "blowback" from US(?) cooks' / associates' tendency to savour raw dough while cooking. IIRC a significant number of Salmonella events have been ascribed to this trait.


Kind Regards,

 

Charles.C


#17 Scampi

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Posted 24 January 2019 - 03:59 PM

Given that the FDA is being furloughed............we all need to be cautious when buying flour...........remember just how large the ecoli flour recall was?????????   

 

Hey Donald.................I guess you don't see just how intertwined the food industry is and how vital the FDA's role in maintaining food safety and investigating outbreaks

 

 

How will we know if this went into a million finished goods without the FDA doing the legwork??????????????


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#18 MsMars

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Posted 24 January 2019 - 04:40 PM

Hi MsMars,

 

Perhaps some "blowback" from US(?) cooks' / associates' tendency to savour raw dough while cooking. IIRC a significant number of Salmonella events have been ascribed to this trait.

 

Until now, majority (perhaps falsely) attributed to raw egg.







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