Should Zone 1 Be Included in Environmental Monitoring?

Hello, we recently had our SQF audit and it went quite well with only 2 findings. I have a question about the finding for our environmental monitoring program. 

Our procedure for EM states that we take quarterly swabs at 6 random sites, with at least 2 of those sites being zone 1 sites (this plan is fine with the auditor in this and past audits). We had a very intense customer audit about a year ago where the auditor indicated that we should not be swabbing zone 1 sites and that zones 2-4 are more important. The rational for this was that we are doing regular ATP swabs of zone 1 (food contact) sites and getting results of 0.

For the past year almost we have been doing our regular EM swabbing but only doing zones 2-4. Unfortunately we did not update our procedure or do a risk assessment to justify this change so this was a finding. Our auditor marked it down as a minor finding since we have never had a positive listeria or salmonella EM swab is our facility and that our regular ATP swabs of zone 1 are good.

My question is, should we keep this change and only swab zones 2-4, and update the procedures and do a risk assessment to justify this? Or should we go back to swabbing zone 1 as well. What does everyone else do in their facility. We are a herb and spice company, with dry ingredients only. 

You're over thinking it.  Update your procedure to match your practice.  You've already justified it based on ATP swabs but you can do it formally if you want.  Call it a day.  

Personally I don't get the justification for not swabbing zone 1.  ATP swabs are not representative (despite the blurb saying otherwise).  Product samples being the first indication of a Listeria issue?  I think some of your countrymen have painful experience with not swabbing zone 1 enough and not reacting well enough to out of specification results.

Step 1, ensure you are adhering to your regulators requirements

(you are BTW) https://www.canada.c...-eat-foods.html

Nonetheless, from the RTE foods definition above, the following foods are excluded from the Listeria policy:

1. dried goods or low-moisture foods that do not require storage under refrigeration or freezing conditions (for example, cereals, bread, dry pasta, nuts and seeds, dried herbs and spices, dried soup mixes)

Your customer was WRONG----if you are using a seek and destroy methodology (which is the gold standard) product testing is the LAST thing you should be doing as per CFIA -zones 2-4 for listeria is the policy statement

Amend your program to reflect what you are actually doing and call it a day

salmonella does occur in spices. 

unless your spices are 'treated' . i would err on swabbing zone 1 .. Not for pathogens but for some indicators  eg enterobacter

Hi vkul84,

ATP is not generally used for environmental monitoring, indicator organisms include:

TVC

Enteros

Y&M

Well-known examples of pathogens and spoilage organisms that are applicable to a site’s environmental monitoring for low moisture products include Salmonella and/or Enterobacteriaceae in dry environments where susceptible products are handled.

I would always include some Zone 1 swabbing and would revert to swabbing there again for indicator organisms at a minimum. I have posted some relevant information and links that you might find useful below. Some of the guidance suggests focusing on Zone 2 for Salmonella swabs and that may be where your previous auditor got that idea from.

Codex Code of Hygienic Practice for Low-Moisture Foods. CXC 75-2015 

Annex II Guidance for the Establishment of Environmental Monitoring Programmes for Salmonella spp. and other Enterobacteriaceae in Low-Moisture Food

Processing Areas:

‘Examples of areas where environmental monitoring should be used include post-lethality areas, packing lines and other areas immediately surrounding where ready-to-eat foods are exposed to the environment.

Environmental monitoring sampling sites should be prioritized according to the likelihood of contamination of processing lines and the impact on product in case of contamination.’

Annex on Spices and Dried Culinary Herbs:

6.5 Monitoring effectiveness

‘Verification of hygienic control measures should include an environmental monitoring program that has been designed to identify pathogens such as Salmonella in the processing areas. (Refer to Annex II.)’

Understanding the Environmental Monitoring Zone Concept - Michigan Department of Agriculture and Rural Development

'Most environmental samples collected should be taken from Zone 1 and Zone 2, and to a lesser degree Zone 3. Very few, if any, environmental samples should be taken from Zone 4.

Zone 1 refers to all direct food contact surfaces (e.g., slicers, mixers, conveyors, utensils, racks, work tables, etc.). For inspections focusing on the presence of Salmonellae, food contact surfaces are normally not sampled. In contrast, for inspections focusing on detection of Listeria monocytogenes, sampling of food contact surfaces is essential.

Zone 2 encompasses the areas directly adjacent to Zone 1. For investigations focusing on Salmonellae, this is the area where environmental contamination is most likely to directly affect safety of the product.'

Kind regards,

Tony

I have to admit I missed that this was herbs and spices but...  There are a surprising number which are not heat treated.  I'd still be testing zone 1.  Salmonella is probably more the pathogen of concern though.  Agree and as I put before, ATP Is just not directly representative of indicator organisms.  And the type of ATP system and swabs you use depend on how good it is on detecting ADP and AMP as well.