4 replies to this topic

[BobbyLow859]

Hello All!

A bit of background… I was a QC Supervisor for a breadcrumb, batters, breaders, seasonings, and crouton manufacturer for about 6 years. We were BRC certified. We had a very robust EMP, conducting about 240 swabs a month, across all 4 zones.

Recently, I have taken over the Food Safety/Quality Department at a sausage manufacturing facility and as I am not all too familiar with USDA regulations, I began reading on their many Cfrs and policies. I find it odd that a facility that manufactures meat and poultry does not conduct any Environmental Monitoring Swabs at all. Now, I have not actually seen or read anything from USDA that mandates swabbing, however, I would assume that a Risk Assessment would need to be completed and the said EMP would be based upon that? Didn’t USDA conduct a sampling plan for this? Am I not seeing an EMP as a result of this?

My question I guess would be, 1. Does this seem like a normal thing to come across in meat manufacturing? (This is my first meat processing facility) 2. Would Listeria, Salmonella, Clostridium P., and possibly others not pose a risk? I feel like there should be some type of EMP in the works, even if it was just a yearly event. This facility I am in is also trying to get SQF certified as well and it seems that they themselves mandate this as well. Why wouldn’t USDA?

[TimG]

Good morning, Bobby. No clue on the answer to your questions but wanted to say welcome to the forums. This is the right place for that type of information.

[BobbyLow859]

TimG thank you! I appreciate it my friend! I was on here for a few years a while back, but couldn’t remember my login, so I just made a new one.

[Killian]

Welcome back to the forum!

 

I've never worked in meat packing unfortunately, but I have to agree that most of what I hear from that sector sounds a little odd to me as an outsider.

 

If I had to hazard a guess as to why they would place less of a priority on EM in facilities with raw meat, it would be because you'd be popping hot in the meat processing rooms all the time from the inherent load present in the raw materials contaminating their immediate environment. Depending on the nature of the process, especially if there is RTE production occurring elsewhere in the facility, it would make sense to me have an EMP for those areas.

 

Pure speculation on my end though, hopefully someone more versed in meat packing responds soon!

[FSQA-USDA]

I can answer your question, but I first need to clarify a couple of details. Does your establishment produce raw sausage, fully cooked sausage, or both? Also, when you refer to ‘Environmental Monitoring Swabs,’ are you referring to ATP swabs used to detect organic residue on a surface, or laboratory samples such as Listeria spp. tests?”

 

If you are working on a fully cooked sausage establishment then you'll need to check out the "FSIS Compliance Guideline: Controlling Listeria monocytogenes in Post-lethality Exposed Ready-to-Eat Meat and Poultry Products" from January 2014.

 

If you are working on a raw sausage establishment then you'll need to check out the "Industry Guideline for Minimizing the Risk of Shiga Toxin-Producing Escherichia coli (STEC) in Raw Beef (including Veal) Processing Operations 2021 Guideline."

 

There are no CFRs that directly mention the requirement of swabbing or laboratory samples. There are CFRs that require that the establishment maintains adequate support (validation) and maintains outgoing verification to prove that the hazards mentioned in their HACCP are controlled. To maintain this outgoing verification, establishment select a frequency that supports that the hazards are controlled, this is usually done by conducting monthly, quarterly laboratory samples for Generic E. Coli (Raw) or Listeria (Fully Cooked).