Environmental Monitoring Program in a Flour Mill

Hi, has anyone here created and Environmental Monitoring Program for flour mill? 1. What were your indicator organisms and pathogens considered? 2. Considering that EMP is stricter for RTE industries, how stringent was your sampling plan? 3. Any other tips in establishing the EMP for flour mill? Thank you very much.

Hi Christine,

Relevant Pathogens are Salmonella and pathogenic Escherichia coli (e.g. O157:H7).

The most common indicators are total coliforms, faecal coliform and E. coli 

Also used as indicators: enterobacteriaceae and enterococci

For routine hygiene screening with indicator organisms I would also include Y&M and TVC

Your Environmental Monitoring schedule should focus on in order of priority:

Product Contact Surfaces

Product Handling Equipment

Product Handling Area – Walls/Floors/Drains etc.

Access to Area

I would do a weekly indicator survey covering your whole plan in a month and monthly indicator plus pathogens.

Kind regards,

Tony

We are a NRTE flour, cracked grain, grain flakes, and whole grain producer.  We've been BRC certificated for 10 years now.  For the first 9 years I conducted environmental swab testing for Monocytogenese,  Salmonella, and E-coli / Coliforms.  This past year we were given a minor finding for not having a Monocytogenese vector program.  I asked if we even needed to continue with the swabbing as we are a NRTE producer, very low water activity, and do not have a pathogen kill step.  All of our specifications state this as well.  So what they gave us approval to do was to use an ATP program for environmental monitoring.  My two cents worth.

We are a NRTE flour, cracked grain, grain flakes, and whole grain producer.  We've been BRC certificated for 10 years now.  For the first 9 years I conducted environmental swab testing for Monocytogenese,  Salmonella, and E-coli / Coliforms.  This past year we were given a minor finding for not having a Monocytogenese vector program.  I asked if we even needed to continue with the swabbing as we are a NRTE producer, very low water activity, and do not have a pathogen kill step.  All of our specifications state this as well.  So what they gave us approval to do was to use an ATP program for environmental monitoring.  My two cents worth.

I assume yr 10 years of monthly(?) pathogen data were also negative ?

Almost equally amazing that BRC never offered any passing comment  related to the (apparently) negligible risk.

Thank you for that Benjamin.

I think if you have established some history of monitoring then this helps. I personally, would still carry out environmental monitoring as I described above and reduce the frequency with increased level of confidence based on the findings. I think it is important to monitor hygiene and also to minimise the risk of increased contamination of products with pathogens in the mill.

Kind regards,

Tony

I assume yr 10 years of monthly(?) pathogen data were also negative ?

 

Almost equally amazing that BRC never offered any passing comment  related to the (apparently) negligible risk.

10 years of negative results.  Yes Sir.

Thank you for that Benjamin.

I think if you have established some history of monitoring then this helps. I personally, would still carry out environmental monitoring as I described above and reduce the frequency with increased level of confidence based on the findings. I think it is important to monitor hygiene and also to minimise the risk of increased contamination of products with pathogens in the mill.

Kind regards,

Tony

Thanks Tony, I agree.  We monitor hygiene on a daily basis.

10 years of negative results.  Yes Sir.

Hi Benjamin,

Thks for feedback.

IMEX such a result would have concerned me considerably.

I would suggest to revalidate yr sampling/analytical procedures together with appropriate Proficiency Testing.

Zone 1 would be:

1. Indicator microorganisms - enterobacteriacea, total plate count, coliforms, yeast and molds,

on zone 2 do:

1. Salmonella spp., Listeria spp., and E. coli.

on zone 3 do: 

1. Indicator microorganisms as well as pathogens – enterobacteriaceae, total plate count, coliforms and yeast and molds, Salmonella spp. and Listeria spp.

and zone 4 do:

1. Salmonella spp., Listeria spp., and E. coli.

  I would send results off every 3 months.  Do 10 swabs each time.  1 swabs zone 1, 4 swabs zone 2, 4 swabs zone 3, and 1 swab zone 4.  I would make sure you swab a drain each time.  This is what we do and it works well.  Not sure if it would work for you.  You will just have to research it.

https://www.foodsafe...reak-in-canada/

Just to chime in here for my broader understanding, if ecoli and salmonella are a known due to the mills taking in raw agricultural commodities and generating a raw, untreated finished product...........monitoring for ecoli would do what, exactly?  

I think the pp that listed using ATP is on a much better course of action...........what exactly are you going to do when you get a positive hit in a mill, and you will.  Dump metric tons of flour?   Of course your going to find it, eventually

https://www.foodsafe...reak-in-canada/

 

Just to chime in here for my broader understanding, if ecoli and salmonella are a known due to the mills taking in raw agricultural commodities and generating a raw, untreated finished product...........monitoring for ecoli would do what, exactly?  

 

I think the pp that listed using ATP is on a much better course of action...........what exactly are you going to do when you get a positive hit in a mill, and you will.  Dump metric tons of flour?   Of course your going to find it, eventually

Hi Scampi,

Thks for the interesting link. I found its closing comment simply amazing -

Among consumers who use flour to bake, two-thirds said they ate raw cookie dough or batter.

Possibly justifies the raw finished product being classified as (indirect) High Risk !.

We have definitely seen a culture shift...............i know I ate all sorts of raw dough and batter as a kiddo!  Do i let my child do the same?  Oh h e double hockey sticks no

I know some companies are now making "raw" cookie dough that is ready to eat as it's gone through a kill step, but definitely the exception not the rule

Raw agricultural commodities are inherently contaminated, and folks that are removed from rural living tend to forget that

I will never forget that I had to remind field workers that the FIELD was not a washroom..........seriously