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Environmental Monitoring with footbath installed at all entrances?


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maylao123

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Posted 05 November 2020 - 11:46 PM

Hi everyone, I have a question regarding to the Environmental Monitoring Program, we divided our production into 4 zonings, Zone 1, 2, 3 are FCS and NFCS within the RTE area, while Zone 4 is NFCS remote from RTE area. For Zone 4, I have a hard to define the Zone 4 area, since for all the entrances to the production, the employees have to step into foaming footbath to sanitize their footwear and washing and sanitize their hands, I am not sure if I should include warehouse, office, lunchroom etc, into our Zone 4, where no matter what the bacteria will be killed before entering production. Can anyone share your opinions? Thanks.

 



Spidey

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Posted 06 November 2020 - 12:35 AM

If I understand your question, you are trying to figure out which areas to define as Zone 4, non-food contact areas.  In my facility, the office, warehouse, and breakroom are considered Zone 4 because they are outside of the production area.  We have SaniStride shoe sanitizing mats located at each production entrance.



maylao123

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Posted 06 November 2020 - 02:33 AM

If I understand your question, you are trying to figure out which areas to define as Zone 4, non-food contact areas. In my facility, the office, warehouse, and breakroom are considered Zone 4 because they are outside of the production area. We have SaniStride shoe sanitizing mats located at each production entrance.


Thanks, my confusion is that if the shoes are sanitized before entering the production, what's the point to test the outside production area.


Spidey

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Posted 06 November 2020 - 05:33 PM

Let's say that an employee drops a pen on the floor in the Zone 4 area, they pick up that pen and bring it into a Zone 3 area.  Any contaminants that may have been on the floor are now potentially on that pen and can to be transferred to whichever surface you put the pen on.  This type of transfer would not be prevented by your footbaths and hand washing procedure.

 

I believe the purpose of testing Zone 4, even when good prevention procedures are in place, is to account for unplanned instances where something might slip through the cracks.  It goes back to the old saying, "It's better to be safe than sorry."  This is especially relevant with the big push to move food safety from being reactive to proactive.



kfromNE

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Posted 06 November 2020 - 07:05 PM

At my facility we don't test zone 4. We test Zones 1 & 2/3 weekly (RTE areas) and monthly in rooms between our FDA/USDA areas where cross-contamination could occur.

 

Do a hazard analysis and see if you would need to test Zone 4.


Edited by kfromNE, 06 November 2020 - 07:08 PM.


Charles.C

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Posted 07 November 2020 - 04:33 AM

Hi everyone, I have a question regarding to the Environmental Monitoring Program, we divided our production into 4 zonings, Zone 1, 2, 3 are FCS and NFCS within the RTE area, while Zone 4 is NFCS remote from RTE area. For Zone 4, I have a hard to define the Zone 4 area, since for all the entrances to the production, the employees have to step into foaming footbath to sanitize their footwear and washing and sanitize their hands, I am not sure if I should include warehouse, office, lunchroom etc, into our Zone 4, where no matter what the bacteria will be killed before entering production. Can anyone share your opinions? Thanks.

Hi maylao,

 

Product/process is unknown other than RTE. Such info. is relevant to risk assessment / micro. targetting.

 

I deduce this is a wet process which often "promotes" Listeria in the EMPG.

 

Canada may have specific Regulatory expectations, especially for RTE.

 

You might compare yr situation with some appropriate examples from "expert" plans, eg some of these -

 

https://www.ifsqn.co...ls/#entry100060

https://www.ifsqn.co...am/#entry119334

 

This zone 4 comment appears in a plan for a Listeria focussed scenario (env 9) -

 

Typically Zone 4 monitoring is conducted less frequently or for investigational purposes.  The sampling locations typically include surfaces outside the production areas in order to determine if there is a potential for Listeria spp. to be present in the non-production areas. Sampling non-production  and  raw  areas  may  also  help  to  assess  the  effectiveness  of  preventive  controls between production areas with different level of risks (e.g., hallway between raw and or at-risk product areas).

 

and this one for a dry, Salmonella focussed situation (env 7) -

 

Zone 4 sites are non-PCS sites outside the processing areas. Contamination in this zone could spread to the processing area via foot or equipment traffic (eg., waste carts picking up contamination in the compactor room).  Zone 4 sites should be sampled monthly for Salmonella if immediately adjacent to a production area and quarterly in other areas not directly related to production.

Edited by Charles.C, 07 November 2020 - 06:10 AM.
expanded

Kind Regards,

 

Charles.C


Twalsh

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Posted 11 November 2020 - 06:04 PM

We also operate with the same Zoning principles, defined in the same way as you described.  Consider the traffic (fork trucks, carts, people, etc.) from the warehouse into the Zone 3 areas.  Is there a potential for cross contamination from a fork truck or cart passing from Zone 4 to Zone 3? Also, a high risk area I have found in Zone 4 Warehouse is at the dock plates. If you are fortunate to have dedicated forktrucks/forklifts. this may not be a concern, but something to certainly think about. Is there a trash room or trash compactor area? This would also be considered a Zone 4.  This is also an area that may be at risk for cross contact. I agree that you have captured the potential foot traffic issues with your footbath, but sometimes testing in these Zone 4 areas can validate the cleaning that is being performed and you can then truly say in your risk assessment that you have shown the Zone 4 areas to be low risk.  Maybe look at testing these areas at a lesser frequency than Zone 3, 2 and 1.  Other Zone 4 areas, such as office areas, locker rooms, lunch rooms, etc. may be tested once or twice per year.  Again, you are "painting a picture" of good hygiene practices throughout the facility. At my previous employer, we added lunch rooms and office entry ways twice per year based on a customer request.  Sometimes you do things also to satisfy your bigger customers.


Edited by Twalsh, 11 November 2020 - 06:05 PM.





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