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Environmental Monitoring for Listeria in dry food manufacture

listeria environmental monitoring spices dry food sqf

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#1 redhotchillipeppers

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Posted 17 June 2019 - 05:17 PM

Hello all,

 

I have a question relevant to environmental monitoring...I've been reading through a ton of forums on here about this standard (2.4.8) in SQF Edition 8 and there seems to be a lot of discussion, and dare I say, confusion around it...and I'm one among the many. 

 

So, here's the deal:

 

Company Context:

We're a dry spices and dry blends "manufacturing" and packaging company. I put "manufacturing" in quotes, because we're not really manufacturing anything. All we do is just bottle spices (and only select few) from the pallet loads of spices we get from our suppliers. We're actually primarily a distribution company. All our spices come in pre-sterilized from our suppliers and have COAs with them. 

 

We have a dedicated packaging room for packaging-of-spices process, which we basically maintain as a clean room with rigorous SSOPs, sterilewear requirements, etc. We have Ecolab supplying us our sanitation products. We ATP swab the food-contact surfaces before and after each packaging run. 

 

Our process is a dry process and facility--in fact water is a no-no for our process. We have 2 drains on the floors of our packaging room and they have caps on them (we can remove the caps for cleaning and sanitation of the room which is done when there is no food around, and just really for mopping). 

 

With regard to RTE, it's tricky because spices can either be an RTE or a non-RTE depending on who the end-user is. Our customers though are generally food manufacturers or food service companies for  and my guess is at least 80% of the time most of these spices, especially the ones we package, are going to undergo another kill step (i.e. cooking), but we operate under the assumption that they may not. 

 

EMP Context:

Last year we implemented an Environmental Monitoring program, and really our biggest pathogenic risk is Salmonella. However, we included swabbing for Listeria  for the drains. 

 

In our most recent swabbing, we got a positive hit for Listeria spp.  (not specifically mono) for one of our drains, as drains are to wont to have. We did not get any positive hits for listeria on any other surface though.

 

Just to be on the safe side though, we cleaned and sanitized the entire room like crazy, and added extra precautions (more quat sanitizers, an additional chlorine cleaning step for the drains specifically), spraying various surfaces with isopropyl alcohol (food contact surfaces, rims of the drains--the ones already with caps on them, shoes--even though we wear boot covers on top) , etc. We also promptly held and sent several products for testing for Listeria and all came back negative (thank goodness!). Of course, after cleaning and sanitizing like crazy, I went on a Listeria swabbing frenzy (of all zones 1-4) and all came back negative, including the ones for the drains (thank goodness!)

 

Basically, short of burning the building down (which is what I sometimes feel these standards seem to call for!  :headhurts:) , we did whatever we could reasonably do to make sure Listeria wasn't a threat to our products (and it really isn't, given that it's dry spices and low pH). 

 

 

My Questions/Concerns:

We have our re-cert SQF audit coming up very quickly in a few days, and I don't know if this is just my pre-audit jitters and stress, but I was hoping the community could help shed some insight as to...:

 

1) Did we do all the right things in terms of responding to Listeria in the drains? Am I/we missing something? I mean, from what I'm reading it seems basically inevitable and as long as it's contained there (which it is), it should be fine, yes?

 

2) Since we're a dry environment and our products have a low pH and spices are not likely to foster the growth of listeria mono, my analysis of this risk is actually low. We're just swabbing for listeria in the drains honestly just based on a passing comment from our auditor last year. Anyone disagree or see something I might be missing? i.e. just shed some light on this?

 

3) I suppose I'm just worried that if our auditor sees a record of a positive hit for listeria in our drains, he's going to freak out, even though we have documentation and measures in place to show that it's controlled for and taken care of...and frankly, not really a risk for our products (I mean for crying out loud, spices were the FIRST food safety mechanisms of antiquity. Just saying!)

 

Mind you, we're a small business so already SQF, and all of this for the environmental monitoring alone, has costed a pretty penny and a pretty minute... 

 

I can't help but sometimes feel that all of these nit-picky GFSI standards are sometimes ridiculous and unreasonable (i.e. not practical) or are designed to be inhibitory to business (i.e. a big-corporation scheme to crush competition from small businesses, knowing that the latter would have to really stretch thin by way of finances and personnel to meet standards like this). (Sorry, this last bit is a bit rant-y, but it's really frustrating!)


Edited by spiceprincess, 17 June 2019 - 05:21 PM.


#2 SQFconsultant

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Posted 17 June 2019 - 05:38 PM

One question - what do you use to treat your drains? Regardless of cleaning and sanitizing like crazy, it all boils down to the drains, how do you treat them?   Are they free flowing? Do they ever back-up? Are the covers vented, or solid?  Have you ever seen a residue around the drains at morning start-up?  

 

I brought this back up for editing to add this...  you said...

 

) I suppose I'm just worried that if our auditor sees a record of a positive hit for listeria in our drains, he's going to freak out, even though we have documentation and measures in place to show that it's controlled for and taken care of...and frankly, not really a risk for our products (I mean for crying out loud, spices were the FIRST food safety mechanisms of antiquity. Just saying!)

 

Mind you, we're a small business so already SQF, and all of this for the environmental monitoring alone, has costed a pretty penny and a pretty minute... 

 

I can't help but sometimes feel that all of these nit-picky GFSI standards are sometimes ridiculous and unreasonable (i.e. not practical) or are designed to be inhibitory to business (i.e. a big-corporation scheme to crush competition from small businesses, knowing that the latter would have to really stretch thin by way of finances and personnel to meet standards like this). (Sorry, this last bit is a bit rant-y, but it's really frustrating!)

 
///////
 
As a former long-term SQF Auditor this is not something that "freaks out" Auditors - but, it will result in wanting to see every single piece of documentation, corrective action, etc that you have. Testing result itself, who was it reported to, are drains on your pre-op, are drains in your internal auditing system, lab results, etc. Listeria an amazing thing even in dry operations such as spices and tea for instance in that it can move very easily from drains to floors to things in contact with the floor, etc. Most times the travel (or drift) is human error, somebody puts a box on the floor in error, picks it up and doesn't notice residue from the drain on it an then puts the box on top of a piece of equipment and bam there it goes into everything.
 
So your Auditor is going to take a very very close look at documented steps you took, how you handled the situation and if reporting was neccessary how you went about that. etc.
 
Being safe does cost money, whether small or large - the SQF process and certification most certainly retains and gains customers, it is a relatively small investment to make.
 
As a former SQF Auditor and now an SQF Consultant there have been some times when I felt there was nit-picky stuff, but in the bigger picture it all makes perfect sense to me.  I have to admit your rant was kinda funny.
 
One thing I have found over the years is make everything simple, a document for instance - I was in a plant that was struggling with ensuring they hit on every point, but each document was 1000% bigger than it had to be. We were able to show them how to turn the unpractical into easy peesy.  Most documents were on average 5-10 pages long, we handled their development from scratch and reduced everything to abut 1-3 pages with 3 being only for a couple of things.
 
We have found the smaller the client (not the person, but the business) the bigger they make things because of fear of failure at audit time - instead we apply a simple approach to everything, it works out well.
 
Just make sure you got all your documention in order with nothing done on a verbal basis as that will cause issues.
 
Hopefully that helps some.

Edited by SQFconsultant, 17 June 2019 - 06:10 PM.

Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 


#3 redhotchillipeppers

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Posted 17 June 2019 - 06:12 PM

One question - what do you use to treat your drains? Regardless of cleaning and sanitizing like crazy, it all boils down to the drains, how do you treat them?   Are they free flowing? Do they ever back-up? Are the covers vented, or solid?  Have you ever seen a residue around the drains at morning start-up?  

 

Hi SQF Consultant,

 

We use a multi-quat sanitizer provided by Ecolab (I think it's Oasis 146--and the label says it is effective for treating listeria mono). So we flush the drains with that, then flush it with a bleach solution, then spray IPA in and around it (with a dedicated spray bottle just for the drains). I'm also going to get some chlorine tablets to put down the drains.

 

They are free-flowing in that they lead directly to the ground drain, if I'm not mistaken. They've never backed up and we haven't seen residue around them, especially not from water or other kind of gunk. 

 

The drain caps are solid and have no vents. Again, we don't use water, aside from just mopping our floors and washing our food-packaging utensils (which have their own dedicated sink). 

 

 

But again, would this still matter if the rest our equipment (like the actual food contact surfaces and zone 2s) are testing negative?  

 

How would you treat/assess something like this, as an SQF consultant?



#4 MsMars

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Posted 17 June 2019 - 06:14 PM

 

3) I suppose I'm just worried that if our auditor sees a record of a positive hit for listeria in our drains, he's going to freak out, even though we have documentation and measures in place to show that it's controlled for and taken care of...and frankly, not really a risk for our products (I mean for crying out loud, spices were the FIRST food safety mechanisms of antiquity. Just saying!)

 

 

The point of an environmental program is to find it if it's there.  Personally my stance on EMP is if you never find ANYTHING, then you're not looking hard enough.  In regards to your situation - you found it, you took care of it.  Any reputable auditor is not going to "freak out" if your EMP program found what it was looking for. 



#5 SQFconsultant

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Posted 17 June 2019 - 06:25 PM

Hi SQF Consultant,

 

We use a multi-quat sanitizer provided by Ecolab (I think it's Oasis 146--and the label says it is effective for treating listeria mono). So we flush the drains with that, then flush it with a bleach solution, then spray IPA in and around it (with a dedicated spray bottle just for the drains). I'm also going to get some chlorine tablets to put down the drains.

 

They are free-flowing in that they lead directly to the ground drain, if I'm not mistaken. They've never backed up and we haven't seen residue around them, especially not from water or other kind of gunk. 

 

The drain caps are solid and have no vents. Again, we don't use water, aside from just mopping our floors and washing our food-packaging utensils (which have their own dedicated sink). 

 

 

But again, would this still matter if the rest our equipment (like the actual food contact surfaces and zone 2s) are testing negative?  

 

How would you treat/assess something like this, as an SQF consultant?

I had the good fortune to work for a division of Johnson Wax out of Racine, Wisconsin - the division was Johnson-Diversey, now know as Diversey and I think Cintas owns this brand now. But, JD came out with a Listeria killer, even though at the time they could not say openly that it killed Listeria - it had to go thru trials first - but that is what it did and does.  The product is  ElimineX  - and each time an application with this foam dispenser is completed it is followed up with a sanitizer - no bleach, etc.  Take a look at it, it is really great stuff.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 


#6 Charles.C

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Posted 17 June 2019 - 08:05 PM

Hi SP,

 

As a sort of corollary to Post 4, the likelihood of Listeria being present in yr process room derives typically from the raw materials and the environment/workers.

 

How much testing do you do on yr sterilized input ? End product ?

 

My experience is mainly with other pathogens however I was rather amazed to recently read that swabbed food samples for Listeria are often only tested to a "Presumptive" level rather than "confirmed". Might be worth verifying which variety generated  the "positive" result/tumultuous activity you mentioned.

 

PS -  the likelihood to get an (isolated) hit for pathogens from swabbing surfaces is generally regarded as very low from a sampling/testing POV. Nonetheless a positive can only be interpreted as proving that "something" is there. Repeated negative results are clearly better than positive but unfortunately only hint that there is likely no gross contamination.


Edited by Charles.C, 17 June 2019 - 08:24 PM.
edited, missed the raw material comment

Kind Regards,

 

Charles.C


#7 Jacqui

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Posted 19 June 2019 - 12:11 AM

I note you mentioned the use of mops when cleaning drains.  Personally I am not a fan of mops for cleaning as they can be the cause of a micro issue if not properly maintained.  I would review the use of mops especially with regards to how they are cleaned and stored.  You cannot clean the drain / floor with a dirty mop.  You just spread the problem.  Make sure the mops themselves are cleaned, sanitised and stored so they are able to dry.  There are single use mop heads out there for this purpose.







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