12 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).

[kfromNE]

You're looking at this wrong. It's Non-RTE vs RTE product. Most likely your plant is Non-RTE. We went from a RTE & Non-RTE facility to a Non-RTE facility for FDA & USDA. We no longer do environmental monitoring because of this. We do ATP swabs to verify our cleaning but this is a SQF requirement and not USDA. USDA still does product testing on RTE and Non-RTE products. 

 

If you were to test environmental surfaces in a non-RTE facility - you will find something and it's a given. But there is a kill step for you product. Similar to raw produce like potatoes. When we had RTE, we never tested the lines on the potato cooker until the cooker and afterward. 

 

When we had USDA RTE, they did require environmental monitoring for listeria. The USDA did look at our results too. 

[G M]

As others have mentioned, if your product is raw, it is presumed to contain low levels of low risk pathogens.  Testing the environment would predictably find them, because they're coming from the product.  It is presumed that normal cooking behavior will manage the risks in raw meat.

 

If it is RTE product then the 9.III.E.430.4 Control of Listeria monocytogenes in post-lethality exposed ready-to-eat products will outline some options that direct you toward environmental testing.

[BobbyLow859]

Thank you. Our process/product is kind of unique as we produce something called Goetta. It is a kind of a regional thing to our area. I guess you could say it is similar to scrapple.

Anyhow, I do not know why I did not think of it product wise or RTE vs NRTE. Thank you for that. Our product is NRTE. Even though technically it does hit lethality. I’ve only been here for about a month and it just seemed odd to me that they weren’t doing any type of swabs for anything at all, even indicators.

I guess in my mind, it just seemed standard practice to do some type of Environmentals, even if it’s to help verify sanitation or overall cleanliness. Even if it is only on a quarterly basis. Or at least having a Risk Assessment completed (which they do not).

Being at new facility, especially a small one that is trying to catch up, and trying to build many things from the ground up has been a little difficult. Thanks everyone.

[kfromNE]

Thank you. Our process/product is kind of unique as we produce something called Goetta. It is a kind of a regional thing to our area. I guess you could say it is similar to scrapple.

Anyhow, I do not know why I did not think of it product wise or RTE vs NRTE. Thank you for that. Our product is NRTE. Even though technically it does hit lethality. I’ve only been here for about a month and it just seemed odd to me that they weren’t doing any type of swabs for anything at all, even indicators.

I guess in my mind, it just seemed standard practice to do some type of Environmentals, even if it’s to help verify sanitation or overall cleanliness. Even if it is only on a quarterly basis. Or at least having a Risk Assessment completed (which they do not).

Being at new facility, especially a small one that is trying to catch up, and trying to build many things from the ground up has been a little difficult. Thanks everyone.

 

Understandable. It's the cooking part that is throwing you off. We have a room that has a cook step and not RTE. It has thrown off many inspectors. 

With your product - make sure it is labeled as a heat treated - not fully cooked - not shelf stable product vs a fully cooked - not shelf stable. 

These are FSIS product classifications. 

 

Also they must have validated cooking instructions on the package. To validate. Follow your own cooking instructions. Then take the temperature. Document it.

This proves that your instructions are valid. Many do this yearly. 

 

If they want to become SQF certified, doing ATP or some type verification for sanitation is a good idea. 

[FSQA-USDA]

Sounds like the sausage is NRTE and is under a Heat Treated Not Shelf Stable HACCP system which USDA does not require Listeria sampling if the packaging instructions state that the customer needs to cook the product to 160F for beef/pork or 165F for poultry. Technically because the sausage is cooked to lethality it can be under a Fully Cooked Not Shelf Stable HACCP, but products under that category require lethality, and Listeria sampling at a frequency.

 

Electing to use Heat Treated Not Shelf Stable instead of Fully Cooked Nos Shelf Stable is what USDA usually calls "labeling out". This term describes an establishment that chooses to avoid the regulatory requirements associated with RTE products.

 

Regarding your perspective on environmental sampling as a standard practice, there are no CFR regulations that USDA can use to require this. USDA requires establishments to have an SSOP program that has written procedures which are implemented and maintained to prevent insanitary conditions. Establishments have the discretion to determine the complexity of their SSOPs, while USDA inspectors evaluate whether those procedures are adequate. If an establishment voluntarily includes environmental swabbing procedures in its SSOP, those procedures then become enforceable. In such cases, failure to follow them may result in noncompliance findings by the inspector.

 

If your establishment chooses to implement environmental swabbing, I recommend keeping it separate from your SSOPs and HACCP system. Instead, incorporate it as part of your internal quality assurance program. This approach allows flexibility in managing the procedures without creating regulatory obligations that USDA inspectors could enforce.

Edited by FSQA-USDA, 02 July 2025 - 09:30 PM.

[BobbyLow859]

Thank you all for the bit of insight! It’s appreciated. This is a definitely a bit different than what I am used to, so I am currently just trying to gain as much insight as possible.

KfromNE, you are correct. I meant to put this in my response to you earlier, but yes, are cook step is just a Parboil (Heat-Treat) and not considered lethal. Our packaging does have the “Safe Handling Instructions” and the cook/fry process for which I have already validated.

It has been difficult since I started though. They did not have basic SOP’s for any of processes. They don’t have any Prerequisite Program, Foreign Material Policy, SOP’s for Sanitation, etc. Basically, I’m building everything from the ground up myself. Fun. Fun.

[GMO]

KfromNE, you are correct. I meant to put this in my response to you earlier, but yes, are cook step is just a Parboil (Heat-Treat) and not considered lethal. Our packaging does have the “Safe Handling Instructions” and the cook/fry process for which I have already validated.
 

 

As a non American, I find this approach odd.  Not always but normal practice in the UK would be that if something could appear to be ready to eat or ready to reheat, you should treat it as though it would not receive a lethal home cooking thermal process and control your site (including Listeria swabbing etc) to reduce risk as much as possible.  

 

I don't see the validity of having a "parboil" which is not considered lethal, especially if it's possible to make it lethal.  But then I'm not familiar with the product.  A quick google and it has hints of "haggis" about it, albeit with less offal.  While haggis would have cooking instructions on it, I'd still be expecting the boiling process to be lethal (mostly for shelf life reasons if I'm honest) and them to segregate raw from cooked and swab the environment post boil.

[kfromNE]

GMO - items in this category include bacon. Bacon is considered partially cooked but then cooked fully by the customer. Other items include pot pies, soups, sausage. 

 

Many times, it is a mixed item with some of the items cooked while others are raw. Noodles are one example that may be cooked in an item but the other items are raw. We make a stuffed potato with bacon. The potato shell is partially cooked but the filling is raw. 

 

I personally consider all products that need to be cooked, Non-RTE. Safer that way.