15 replies to this topic

[Alfiebru]

Hi

 

I am currently creating a risk assessment for environmental swabbing for our food site which produces mainly sausages and is an all raw site - and so low risk. At the moment the only environmental swabbing we preform is ATP swabs which verify cleaning has been preformed correctly. 

 

My question is what hazards/ controls shall I include in the risk assessment. Starting with microbial hazards - is this broken into specific pathogens such as Listeria/ Salmonella? With regard to Listeria, this is quite inherent in raw meat and so if we was to swab for it we will enviably receive positive results regardless of hygiene standards - (We micro test our meat weekly, some of which coming from suppliers of Tesco and Morrison's and they have shown positive for Listeria). Could I make the case that as this is a raw product which has to be cooked, and Listeria is so prevalent that it becomes redundant to test for it? 

 

I am quite new to Food safety - this is the first risk assessment I have done so any help will is appreciated.

 

Thanks

Alfie

 

[Charles.C]

Hi

 

I am currently creating a risk assessment for environmental swabbing for our food site which produces mainly sausages and is an all raw site - and so low risk. At the moment the only environmental swabbing we preform is ATP swabs which verify cleaning has been preformed correctly. 

 

My question is what hazards/ controls shall I include in the risk assessment. Starting with microbial hazards - is this broken into specific pathogens such as Listeria/ Salmonella? With regard to Listeria, this is quite inherent in raw meat and so if we was to swab for it we will enviably receive positive results regardless of hygiene standards - (We micro test our meat weekly, some of which coming from suppliers of Tesco and Morrison's and they have shown positive for Listeria). Could I make the case that as this is a raw product which has to be cooked, and Listeria is so prevalent that it becomes redundant to test for it? 

 

I am quite new to Food safety - this is the first risk assessment I have done so any help will is appreciated.

 

Thanks

Alfie

 

Hi Alfie,

 

This recent  thread appears to answer yr query regarding necessity for EMPG (= Probably Yes).

 

https://www.ifsqn.co...ng/#entry142570

 

The micro. objective of a cleaning/sanitizing program is to minimize/"eliminate" pathogens from food contact surfaces. Unfortunately ATP swabbing does not confirm the achievance of such micro. requirements. Hence the use of EMPG..

 

The risk-based implementation of an EMPG involves Zoning, eg -

 

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

 

PS - the typical advice in most of the above-linked EMPGs to refrain from pathogen swabbing in Zone 1 is a semi-fudge and sort of relates to yr observation about the relative likelihood of achieving a positive hit.

[LSB]

Advice from someone in the raw meat industry.

 

i instituted APC/ Generic coliforums/ Ecoli swabs done in conjunction with ATP swabs. so within 12 hours on generic ecoli/ coliforum and 24 for APC we have results and know if sanitation corrective action is working. from a frequency standpoint you could set it to match your pre op areas or take a certain percentage of equipment in specific areas.

We do before and after swabs to show the elimination of indicator organisms. 

 

you could always state that product is intended for further processing. since l mono is not considered an adulterant in non RTE products i dont think you have much to worry about in that regard. 

 

i would not test for pathogens in the environment if you are not required to. all the product you produced on that surface would be subject to recall if it came back positive for an adulterant. 

[Charles.C]

Advice from someone in the raw meat industry.

 

i instituted APC/ Generic coliforums/ Ecoli swabs done in conjunction with ATP swabs. so within 12 hours on generic ecoli/ coliforum and 24 for APC we have results and know if sanitation corrective action is working. from a frequency standpoint you could set it to match your pre op areas or take a certain percentage of equipment in specific areas.

We do before and after swabs to show the elimination of indicator organisms. 

 

you could always state that product is intended for further processing. since l mono is not considered an adulterant in non RTE products i dont think you have much to worry about in that regard. 

 

i would not test for pathogens in the environment if you are not required to. all the product you produced on that surface would be subject to recall if it came back positive for an adulterant. 

 

Hi LSB,

 

As per the link in Post 2, a specific BRC requirement for pathogen testing  is  textually rather ambiguous, ie "risk-based". Offhand one would think not but for BRC prediction is a risky business.

Perhaps BRC's  I.G. offer clarification on the matter.

[pHruit]

Perhaps BRC's  I.G. offer clarification on the matter.

Alas I'm not sure that the IG is much help with this one, Charles - in terms of target organisms the IG advises that:

"These may include specific pathogens that present a risk to the product or environment (e.g. Listeria spp in wet environments or Enterobacteriacae in dry environments), specific spoilage organisms (e.g. yeast or mould) or indicator organisms (e.g. total plate count, total coliforms)."

Even in the broader context of the IG content on this section (4.11.8) and specific clauses I'm not sure it makes things any clearer than the is normal for a new BRC standard, i.e. positively opaque...

[Charles.C]

Alas I'm not sure that the IG is much help with this one, Charles - in terms of target organisms the IG advises that:

"These may include specific pathogens that present a risk to the product or environment (e.g. Listeria spp in wet environments or Enterobacteriacae in dry environments), specific spoilage organisms (e.g. yeast or mould) or indicator organisms (e.g. total plate count, total coliforms)."

Even in the broader context of the IG content on this section (4.11.8) and specific clauses I'm not sure it makes things any clearer than the is normal for a new BRC standard, i.e. positively opaque...

 

Hi pHruit,

 

Yes, thks. After a little searching, I found one BRC example ("low risk"/meat) where no (BRC) EMP pathogens monitored -

 

https://www.ifsqn.co...pling-low-risk/

 

and one [packaging] example (low risk teabags [although not definitively BRC]) the opposite -

 

https://www.ifsqn.co...ng/#entry142571

 

It is possible that BRC may not yet have achieved  a 100% consistent Policy on the appropriate interpretations/EMP Expectations involved.

 

 

Sort of OT but JFI here is a FSIS quote regarding environmental Listeria monitoring -

 

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

 

Edited by Charles.C, 25 June 2019 - 07:59 PM.
edited

[Scampi]

I would like too add that listeria IS NOT prevalent on raw meat............not in proper slaughterhouses anyway, the live side of things yes, on the finished raw cuts??? No.

 

Having said that, raw meat is a low risk product and I wouldn't stick my neck out swabbing for specific pathogens. In my poultry experience, we only did ATP and TPC for equipment. Salmonella and ecoli were required on carcasses (but not as a part of the EMP)

[NicholasChai]

I am working in a poultry processing plant- low risk, we do swab our equipments once a week(rotation basis) for SPC and Coliform. 

[Charles.C]

I would like too add that listeria IS NOT prevalent on raw meat............not in proper slaughterhouses anyway, the live side of things yes, on the finished raw cuts??? No.

 

Having said that, raw meat is a low risk product and I wouldn't stick my neck out swabbing for specific pathogens. In my poultry experience, we only did ATP and TPC for equipment. Salmonella and ecoli were required on carcasses (but not as a part of the EMP)

 

^^ red, Not my product area but, for a totally raw scenario, FSIS appear to disagree. (Post 6)

 

 "low risk" depends on one's definition.

 

^^ blue - was this for BRC8 ? (I'm guessing was for SQF8?)

[Charles.C]

I am working in a poultry processing plant- low risk, we do swab our equipments once a week(rotation basis) for SPC and Coliform. 

 

Thanks for input.

 

Accepted for BRC8 ???

[NicholasChai]

Thanks for input.

 

Accepted for BRC8 ???

No we are not BRC certified, but our new plant is aiming for BRC certification. I am also curious if it will be accepted, due to our low-risk product which requires cooking before consumption. 

[Charles.C]

No we are not BRC certified, but our new plant is aiming for BRC certification. I am also curious if it will be accepted, due to our low-risk product which requires cooking before consumption. 

 

Does yr specification for finished raw product include "absent" (or "not detectable") for Salmonella, L.monocytogenes and  Campylobacter ?

 

Just curious.

[NicholasChai]

Does yr specification for finished raw product include "absent" (or "not detectable") for Salmonella, L.monocytogenes and Campylobacter ?

Just curious.

Our finish products (raw) only includes spc, coliform, E. Coli, staph aureus and salmonella, no campy or listeria, we are located in Malaysia BTW.

Edited by NicholasChai, 10 July 2019 - 06:50 AM.

[Charles.C]

Our finish products (raw) only includes spc, coliform, E. Coli, staph aureus and salmonella, no campy or listeria, we are located in Malaysia BTW.

 

Thanks.

 

I assume yr process includes no bactericidal "elimination" step.

 

I also anticipate that yr haccp plan "incoming raw materials" stage regards Salmonella as a potential raw meat contaminant/hazard.

 

And yet yr specification implies any salmonella which might be present "disappears" during the process.

 

Not being critical, it's a well-known haccp paradox.

 

IIRC some raw meat manufacturers do refuse to include a "salmonella undetectable" micro comment. Notably where Supermarket sampling readily demonstrates the opposite

 

In the context of the OP, all this might support the non-requirement of some pathogen species monitoring in an EMPG. Just like FDA/FSIS afaik (Listeria-wise anyway).

 

PS -  specification details also have potential "kickbacks" regarding shelf-life validations.

 

PPS - the above comments are also obviously sensitive as to when any EMPG monitoring takes place.

Edited by Charles.C, 10 July 2019 - 07:24 AM.
edited

[NicholasChai]

Thanks.

 

I assume yr process includes no bactericidal "elimination" step. 

 

I also anticipate that yr haccp plan "incoming raw materials" stage regards Salmonella as a potential raw meat contaminant/hazard.

 

And yet yr specification implies any salmonella which might be present "disappears" during the process.

 

Not being critical, it's a well-known haccp paradox.

 

IIRC some raw meat manufacturers do refuse to include a "salmonella undetectable" micro comment. Notably where Supermarket sampling readily demonstrates the opposite

 

In the context of the OP, all this might support the non-requirement of some pathogen species monitoring in an EMPG. Just like FDA/FSIS afaik (Listeria-wise anyway).

 

PS -  specification details also have potential "kickbacks" regarding shelf-life validations.

 

PPS - the above comments are also obviously sensitive as to when any EMPG monitoring takes place.

 

I assume yr process includes no bactericidal "elimination" step. - yes we have a reduction step no elimination, using chlorinated water 

 

I also anticipate that yr haccp plan "incoming raw materials" stage regards Salmonella as a potential raw meat contaminant/hazard.- yes Salmonella is one of the biological hazards for receiving, however for the past 2-3 years we have never detected any salmonella. 

 

And yet yr specification implies any salmonella which might be present "disappears" during the process.

 

Not being critical, it's a well-known haccp paradox. 

 

IIRC some raw meat manufacturers do refuse to include a "salmonella undetectable" micro comment. Notably where Supermarket sampling readily demonstrates the opposite-i agree with this 

 

In the context of the OP, all this might support the non-requirement of some pathogen species monitoring in an EMPG. Just like FDA/FSIS afaik (Listeria-wise anyway).

 

PS -  specification details also have potential "kickbacks" regarding shelf-life validations.

 

PPS - the above comments are also obviously sensitive as to when any EMPG monitoring takes place. - our EMP program is now more to validation of the effectiveness of cleaning 

[freshandsafe]

Hi Alfiebru,

 

If this is your first risk assessment, start simple.

 

Pick one part of the process, one pathogen. Look at it's characteristics and what the inherent risks are in your process.

 

Once you get through the risk assessments I would start with some basic - off the record - exploratory swabbing to understand the baselines in your facility.

 

You need to know what's going on and where you are getting positive hits and that's an important part of understanding what the risks are.

 

-Josh Heinrichs

 

 

 

Hi

 

I am currently creating a risk assessment for environmental swabbing for our food site which produces mainly sausages and is an all raw site - and so low risk. At the moment the only environmental swabbing we preform is ATP swabs which verify cleaning has been preformed correctly. 

 

My question is what hazards/ controls shall I include in the risk assessment. Starting with microbial hazards - is this broken into specific pathogens such as Listeria/ Salmonella? With regard to Listeria, this is quite inherent in raw meat and so if we was to swab for it we will enviably receive positive results regardless of hygiene standards - (We micro test our meat weekly, some of which coming from suppliers of Tesco and Morrison's and they have shown positive for Listeria). Could I make the case that as this is a raw product which has to be cooked, and Listeria is so prevalent that it becomes redundant to test for it? 

 

I am quite new to Food safety - this is the first risk assessment I have done so any help will is appreciated.

 

Thanks

Alfie