18 replies to this topic

[kevinkt]

Hello,

We produce popcorn produts and are undergoing annual Costco Audits. We are now required to do swab testing. My question is how to to impletent an ATP swab testing procedure. If I choose to do random ATP testing on all food contact surfaces, do I have to test all food contact surfaces or just a few? How do others do theirs? if you have an example testing form that  would be great! 

[Charles.C]

Hello,

We produce popcorn produts and are undergoing annual Costco Audits. We are now required to do swab testing. My question is how to to impletent an ATP swab testing procedure. If I choose to do random ATP testing on all food contact surfaces, do I have to test all food contact surfaces or just a few? How do others do theirs? if you have an example testing form that  would be great! 

Hi kevinkt,

 

I anticipate the objective is environmental evaluation. This demands micro. testing, not ATP.

 

If the objective is Cleaning Validation. This may be different again. eg allergen considerations.

 

Please clarify objectives.

 

Also wrong Forum ??

 

PS - for some extended thoughts on above see -

 

https://www.ifsqn.co...e-2#entry107729

[Gelato Quality Lead]

Hi, not sure if this is helpful but this is how we do our ATP swabbing.

 

We have a few sites that have been pre-determined as our swabbing sites. These include some zone 1 (food-contact surfaces) and some zone 2 (very near to food-contact surfaces). We swab these same sites every time. We swab before production begins and after cleaning (before sanitizing). We do the same procedure with our allergen swabs.

Edited by Gelato Quality Specialist, 12 July 2022 - 04:11 PM.

[Charles.C]

Hi, not sure if this is helpful but this is how we do our ATP swabbing.

 

We have a few sites that have been pre-determined as our swabbing sites. These include some zone 1 (food-contact surfaces) and some zone 2 (very near to food-contact surfaces). We swab these same sites every time. We swab before production begins and after cleaning (before sanitizing). We do the same procedure with our allergen swabs.

Hi GQS,

 

Thks input.

I suppose it depends what Costco are asking for. Need a Nostradamus.

[MDaleDDF]

I also have my production room broken into 4 zones.   I only atp zone 1, food contact surfaces.   I take 3 swabs every Monday morning, all SOPs having been run Fri and Sat.   Zones 2-4 I swab and do micros, but only quarterly.  

My facility is very low risk, so this is what I do, but may not be sufficient for others.   I don't know much about the popcorn biz, are you doing RTE popcorn stuff?    All my stuff has a kill step and is non RTE, which changes things.....

[Scampi]

Are you sure Costco is happy with just ATP?   It's only a measure of the sanitation process, it does not detect pathogens......

 

 

Seems to me Costco is more likely to request an environmental swabbing procedure (salmonella, or ecoli or listeria) which are usually done quarterly depending on your risk level RTE vs RTC etc

 

We run our ATP on Friday nights only (as sanitation has extra time)  We have the 3M system, I have input every available contact area into the meter told it how many FCS vs non to do weekly and it randomizes it for me.  The operator just then has to swab the locations as the show on the device. 

 

I then log in a look at the trend by area or piece of equipment or user etc

[MDaleDDF]

While they don't test for pathogens, isn't the idea that they test for organic material needed to grow pathogens, and that if the surfaces pass, no pathogens can exist on them?  That's what I was told when we switched to them.   I used to do micro on everything, and no zones bitd, and was persuaded to switch to my current setup by my lab at the time.    

[Scampi]

Not really

 

 ATP stands for adenosine triphosphate, which is an energy molecule found in all living things. So while it could (in theory) tell you if you MIGHT have presence of protein left for micro to grow, it really is ONLY a measure of how clean (or not) something is

 

We swab for salmonella quarterly and have never had a positive hit, but I have had ATP readings of 900 so the 2 are not really correlated

 

ATP is generally used in a pass/fail fashion for allowing production to go ahead as part of the sanitation program and as such, is separate from your enviro swab program

[kevinkt]

Not really

 

 ATP stands for adenosine triphosphate, which is an energy molecule found in all living things. So while it could (in theory) tell you if you MIGHT have presence of protein left for micro to grow, it really is ONLY a measure of how clean (or not) something is

 

We swab for salmonella quarterly and have never had a positive hit, but I have had ATP readings of 900 so the 2 are not really correlated

 

ATP is generally used in a pass/fail fashion for allowing production to go ahead as part of the sanitation program and as such, is separate from your enviro swab program

Thank you for your input. How did you determine your facility only needed quarterly salmonella testing? How do auditors feel about only quarterly testing? 

[kevinkt]

I also have my production room broken into 4 zones.   I only atp zone 1, food contact surfaces.   I take 3 swabs every Monday morning, all SOPs having been run Fri and Sat.   Zones 2-4 I swab and do micros, but only quarterly.  

My facility is very low risk, so this is what I do, but may not be sufficient for others.   I don't know much about the popcorn biz, are you doing RTE popcorn stuff?    All my stuff has a kill step and is non RTE, which changes things.....

Thank you. How did you determin what food contact surfaceses needed to be swabbed. I am sure you have many food contact surfaces so do you swab every single food contact surface or are you able to randomize? We make a popcorn kit where the customer takes unpopped popcorn and cooks it in their microwave and adds our sesoning kit. 

[Charles.C]

Thank you. How did you determin what food contact surfaceses needed to be swabbed. I am sure you have many food contact surfaces so do you swab every single food contact surface or are you able to randomize? We make a popcorn kit where the customer takes unpopped popcorn and cooks it in their microwave and adds our sesoning kit. 

Hi kevinkt,

 

Presumably NRTE

 

This is typically Zoning 101, eg -

 

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

 

Could you post the relevant clause in Costco Standard to (hopefully) focus meaningful responses ?

[kevinkt]

Hi kevinkt,

 

Presumably NRTE

 

This is typically Zoning 101, eg -

 

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

 

Could you post the relevant clause in Costco Standard to (hopefully) focus meaningful responses ?

Thank you. This is costcos requirments on enviormaental monitoring:

"An environmental monitoring program that uses rapid methods and /or microbiological swabbing for pathogens and indicator organisms is established and describes when,

where and how sampling and swabbing take place. A pass/fail criteria has been identified. Corrective action procedures are written and implemented and include

investigations into the cause of the failure. Results are reviewed and trended on a routine basis to identify areas for continuous improvement and records are maintained"

 

I am trying to figure out if we should test for all 3 pathogens salmonella, ecoli, and listeria? How do I make that determination? And how do I determin how many surfaces to sample each time? 

[Charles.C]

 

Thank you. This is costcos requirments on enviormaental monitoring:

"An environmental monitoring program that uses rapid methods and /or microbiological swabbing for pathogens and indicator organisms is established and describes when,

where and how sampling and swabbing take place. A pass/fail criteria has been identified. Corrective action procedures are written and implemented and include

investigations into the cause of the failure. Results are reviewed and trended on a routine basis to identify areas for continuous improvement and records are maintained"

 

I am trying to figure out if we should test for all 3 pathogens salmonella, ecoli, and listeria? How do I make that determination? And how do I determin how many surfaces to sample each time? 

 

Hi kevinkt,

 

Thks for info.

 

For starters maybe see Post 6 which I deduce is based on actual Costco experience (eg the risk-related comment). Yr queries in Post 10 are also logical IMO.

 

In general EMPGs are typically based on factors like Risk Assessment,  "Best Practices", Customer Requirements (if any), specific Process,etc. If you study the refs in my Post 11 you will see Listeria (more specifically L.mono pathogen-wise) tends to be regarded as more a threat for wet processes in comparison to Salmonella for dry. 

 

However I anticipate that USA/FDA (not my own location) "simply" expects both so Costco may follow such a respected Organisation.

 

Sampling frequencies are subjective but need to be such as may be shown to be "sufficient". In the absence of a known Regulatory/Best Practice Procedure, Initially guess a maximum implementable frequency then test it. Then "act accordingly".  IM(non-US) EX most subsequent feedback for a NRTE situation suggested that satisfactory data associated with a monthly routine was a typical expectation.

 

Is yr Facility "controlled" by FDA ? People here in such cases were seemingly "obliged" to implement equivalent sampling/testing schemes albeit they seemed  (to myself) rather draconian (and expensive) to maintain ? (Maybe only relates to RTE ?).

 

It is not inconceivable that for NRTE, testing for the non-existence of protein on various fcs may be sufficient for Costco although based on previous threads here this Company are rather rigorous.

 

PS - JFI I looked at previous Costco threads here. I notice that at least up till 2018, the only mention of EMPG seemed to be for high risk items. Seems Costco have now expanded their requirement. Was there any mention of applicable Products additional to your previous environment quotation ?

Edited by Charles.C, 15 July 2022 - 04:39 AM.
added

[Scampi]

We are a RTC facility, low risk, wet processing

 

We swab for salmonella (our known pathogen in our commodity) quarterly   We rotate through all of our locations on a constant rotation (when you get through them all you start again).  We have never had a positive hit.  4/10 swabs are FCS the other 6 are proximity swabs

 

It is not inconceivable that for NRTE, testing for the non-existence of protein on various fcs may be sufficient for Costco although based on previous threads here this Company are rather rigorous.

 

 

I doubt that this argument will work with Costco and I wouldn't try if you want to keep them as a customer they will drop you faster than Walmart

[wbourg]

 

I am trying to figure out if we should test for all 3 pathogens salmonella, ecoli, and listeria? How do I make that determination? And how do I determin how many surfaces to sample each time? 

 

 

You need to see what common pathogens exist in your raw materials. I work in a commercial bakery. Salmonella is common to flour so I test for that, EB (enterobacteriaceae) and listeria (for drains) in zones 2-3 monthly and zone 4 quarterly. We run ATP on Zone 1 every day to verify cleanliness. I took APC swabs and ATP swabs and compared the values to determine our limit for cleanliness. To determine locations I took the square root of the square footage of the facility, and listed equipment, drains, walls, pillars and the like and just made up a list. In the beginning I took swabs weekly of zones 2-4, but we never got a hit so we adjusted to monthly and quarterly for zone 4. Its all based on risk assessment then implementation. Make sure it doesn't stay static. You should always be trending data and reevaluating that data. 

Edited by wbourg, 15 July 2022 - 02:26 PM.

[Charles.C]

You need to see what common pathogens exist in your raw materials. I work in a commercial bakery. Salmonella is common to flour so I test for that, EB (enterobacteriaceae) and listeria (for drains) in zones 2-3 monthly and zone 4 quarterly. We run ATP on Zone 1 every day to verify cleanliness. I took APC swabs and ATP swabs and compared the values to determine our limit for cleanliness. To determine locations I took the square root of the square footage of the facility, and listed equipment, drains, walls, pillars and the like and just made up a list. In the beginning I took swabs weekly of zones 2-4, but we never got a hit so we adjusted to monthly and quarterly for zone 4. Its all based on risk assessment then implementation. Make sure it doesn't stay static. You should always be trending data and reevaluating that data. 

Hi wbourg,

 

Thks for input,

 

As I understand, you test zones 2-4 for Salmonella, EB, Listeria and never get a hit for any of these items.

TBH, this would make me extremely nervous about the reliability of either/both of my sampling/testing Procedures.

 

I anticipate the square root notion was borrowed from the old method of sampling of Product lots. I have never seen it proposed for environmental sampling ? Risk - based seems more logical.

[wbourg]

As I understand, you test zones 2-4 for Salmonella, EB, Listeria and never get a hit for any of these items.

TBH, this would make me extremely nervous about the reliability of either/both of my sampling/testing Procedures.

 

I am blessed with a facility that was built in 2020 with a dedicated sanitation team that cleans the facility top to bottom every day. I have swabbed locations trying to find pathogens and haven't found them. In 2020 (before my time) there was a hit for listeria on the floor scrubber, but they discovered they weren't using sanitizer, just plain water, and not cleaning it. It was replaced and proper concentration of sanitizer is tested each run. We have other issues though. Not saying I live in a facility called Perfect. 

 

I anticipate the square root notion was borrowed from the old method of sampling of Product lots. I have never seen it proposed for environmental sampling ? Risk - based seems more logical.

 

I think I heard this method in a presentation (or something) sometime. Probably is based on the product sampling technique. I do use risk based analysis for the locations we more test more frequently (i.e. finished good locations have more locations than raw material has).

[Aqila Nur]

I also have my production room broken into 4 zones.   I only atp zone 1, food contact surfaces.   I take 3 swabs every Monday morning, all SOPs having been run Fri and Sat.   Zones 2-4 I swab and do micros, but only quarterly.  

My facility is very low risk, so this is what I do, but may not be sufficient for others.   I don't know much about the popcorn biz, are you doing RTE popcorn stuff?    All my stuff has a kill step and is non RTE, which changes things.....

 

Hi, may I know why you just swab for ATP for Zone 1, while you do microb for Zone 2-4? Thank you.

[G M]

Hi, may I know why you just swab for ATP for Zone 1, while you do microb for Zone 2-4? Thank you.

 

I think that was meant to read that ATP is only being done for Z1 (not for 2-4) -- but it should be assumed Z1 is also getting the micro testing on the highest frequency (which isn't specified, presumably monthly or weekly; only the reduced frequency (quarterly) for the other zones is specified).