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Environmental Pathogen in the Chocolate Industry

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C@ndrade40

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Posted 08 September 2026 - 06:04 PM

Greetings!

I’ve been working in chocolate manufacturing for about two years. Coming from the meat industry, it has definitely been a learning curve.

I am currently beefing up my environmental risk assessment to comply with SQF Edition 10. We currently perform environmental pathogen swabbing in Zones 3 and 4. As I update this risk assessment, I started looking at one piece of equipment differently: the mold washer.

Since it is located in a separate washing room, where we clean disassembled equipment parts and utensils, I am inclined to include the molds in our EMP program AFTER the cleaning and sanitation cycle, despite the fact that they are food-contact surfaces (Zone1).

I was wondering if any of my fellow QA professionals in the chocolate industry have done this before or considered a similar approach?

 

Thank you!


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Scampi

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Posted 08 September 2026 - 06:36 PM

I agree with your approach as a way of validating your mold cleaning program/process

 

what about the tempering machine???


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C@ndrade40

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Posted 08 September 2026 - 08:00 PM

Thank you!

For the tempering machine, I can swab the external surfaces. We use an established push-through process when changing from dark chocolate to milk chocolate and vice versa, so we are not currently performing wet cleanings on the equipment.

I'm not sure if that's what you were referring to, but that's the approach we're currently taking.


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Scampi

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Posted 08 September 2026 - 08:02 PM

Just checking lol   Sounds perfect

 

You're ONLY cleaning molds between allergens or when molding quality suffers?


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C@ndrade40

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Posted 08 September 2026 - 08:26 PM

Exactly, between allergens or when the finished product start losing its shiny. 

The confectionery industry is a really interesting place. There seems to be more subjectivity than in any other industry I've worked in. I think shared equipment is one of the biggest challenges to navigate, especially while we're waiting for clearer legislation. 

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GMO

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Posted 08 September 2026 - 09:05 PM

I find some of the US approach on micro baffling but we're headed that way in thinking in the UK and EU. Sadly. 

But with my pragmatist head on, I always think "why are you testing" is a good question to ask yourself and "what would you do if you had a failure".

I'm not advocating not testing for pathogens but I actually think the reason you're testing is as verification of your wash process which is probably better verified by indicator organisms. Not saying I wouldn't swab for pathogens here but if that's why you're testing for Salmonella, I'd probably also test for a hygiene indicator too which is more likely to show you any issues before they become severe.


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C@ndrade40

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Posted 08 September 2026 - 10:17 PM

Good perspective. I agree that testing can be tricky, 100% agree with question, "What would you do if you had a failure?" I learned early in my career how important those questions can be.

Sure, in this scenario testing hygiene indicators would be a no-brainer. However, since I've been verifying the cleaning process periodically with ATP swabs, I was looking at this more from the perspective of confirming that clean molds remain free from environmental contamination while they're staged in the washing room before being transferred back to the dry processing area.

If I were to test a load of clean molds for pathogens, I would need to segregate them until the results come back. My concern is that, if I got a positive result, I guess….one could argue that it originated from the chocolate process itself rather than the washing room environment. Thoughts?


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Tony-C

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Posted 09 September 2026 - 02:51 AM

Hi C@ndrade40,

 

Given low numbers of Salmonella in chocolate are a food safety risk, is there any reason why your EMP program doesn’t cover Zones 1 & 2?

 

Kind regards,

 

Tony


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New Edition 10 SQF Food Safety Management System Implementation Package for Food Manufacturers - Compliant with SQF Edition 9 & 10 and includes technical support until you achieve SQF certification

 

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GMO

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Posted 09 September 2026 - 05:44 AM

Agree with Tony on that. I would include zone 1 and 2 and product testing. Or always did. I wouldn't want to be oblivious about a potential issue that could be so serious even if it means a potential recall.

But also I would strongly argue that ATP swabbing in no way compensates for lack of environmental hygiene swabbing. The two are very much not the same.


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Posted 09 September 2026 - 12:02 PM

The issue with salmonella and chocolate in particular is the addition of water.......

 

are you receiving CoA from your suppliers?  I'm assuming your bringing in cocoa butter and chocolate separately and mixing as required (and then adding inclusions) and that you limit the amount of water as much as possible in the process?


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Tony-C

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Posted 09 September 2026 - 01:29 PM

The issue with salmonella and chocolate in particular is the addition of water.......

 

Hi Scampi,

 

Clearly the water addition can be a factor and I’m not sure I would have a ‘mold washer’ unless there was a post clean drying element to that cleaning cycle.

 

However, there are far more important aspects of chocolate contamination to understand.

 

Even relatively small amounts of contamination can lead to an outbreak when chocolate is subject to Salmonella contamination, including environmental contamination. That is why I posted that monitoring of zones 1 and 2 is important, more so than zones 3 and 4.

 

For those interested this is covered in my Food Safety Essentials Webinar What Food Safety Recall Data Tell Us - Part 1 in 2024 and many other webinars I’ve presented on behalf of the IFSQN

 

View slide Bacteriologist Professor Hugh Pennington of Aberdeen University told BBC News that the only safe level of salmonella in chocolate was "zero".

 

Cadbury fined £1m over salmonella

 

For Salmonella spp., the infectious dose is thought to be very low, as demonstrated by the small numbers of cells per serving recovered from low-moisture foods implicated in outbreaks. Furthermore, there is evidence that the composition of a food (especially, high fat content) may protect Salmonella against the acidic conditions of the stomach, potentially increasing the likelihood of illness from consuming low numbers of the organism.

 

‘At the hearing on Friday the court heard how Cadbury changed its quality-testing systems, allowing salmonella to enter its chocolate bars, to save money.’

 

I cannot emphasise enough that environmental monitoring programs in chocolate manufacture should be amongst the most stringent systems applied in the food industry.

 

Kind regards,

 

Tony


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New FSSC 22000 Food Safety Management System for Food Manufacturers - Version 7 Implementation Package available here - includes technical support until you achieve certification
 

New Edition 10 SQF Food Safety Management System Implementation Package for Food Manufacturers - Compliant with SQF Edition 9 & 10 and includes technical support until you achieve SQF certification

 

Free monthly Food Safety Essentials Webinars - Look out for our next live webinar

 

Practical Internal Auditor Training for Food Operations Available via the recording until the next live Webinar in December 2026

Suitable for Internal Auditors as per the requirements of GFSI benchmarked standards including BRCGS and SQF.

 

IFSQN Implementation Packages, helping sites achieve food safety certification since 2009: 

IFSQN BRC, FSSC 22000, IFS, ISO 22000, SQF (Food, Packaging, Storage & Distribution) Implementation Packages - The Easy Way to Certification

 

Practical HACCP Training for Food Safety Teams Available via the recording

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C@ndrade40

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Posted 09 September 2026 - 03:59 PM

We bring in chocolate discs (dark, milk, and white), then melt them and blend them with various inclusions. We require COAs from all of our suppliers, and we also have a monitoring program in place that verifies raw materials, finished products, water, air, and other relevant food safety parameters.

@Tony-C, I understand that there are several aspects to consider when it comes to Salmonella in chocolate, and that's exactly what I'm trying to address with an updated plan based on my risk assessment. I'll definitely check out the webinar to make sure I'm not missing any potential blind spots - Thank you!


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terris

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Posted 09 September 2026 - 10:37 PM

Hi C@andrade40 welcome to the chocolate world!

We do EMP swabbing once monthly, 11 samples,  in all 4 zones.

Zone 1 we test indicators only- APC and EB. 2 samples.

Zone 2 we test APC, EC, generic E Coli, Salm, List sp. 5 samples.

Zone 3- same tests as zone 2, 2 samples

Zone 4- same tests as zones 2 and 3, 1 sample. 

Drain- test E coli, Sal, List - 1 sample

This has worked for 11 years SQF certified.

Hope that helps!


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liberator

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Posted 10 September 2026 - 04:28 AM

In the dairy industry we'd never ever test zone one for pathogens, only indicator organisms, and respond promptly to any that fail.

 

Dairy regulations require any positive pathogen results on product contact surfaces to be reported, and it means all hell breaks loose. Product goes on hold. Ten batches prior to the positive has to be put on hold and tested at a higher rate. The line is shut down and a full pull down and clean and sanitise.

 

After enviro checks are clear then 3 post contamination production runs must be cleared of pathogen before you can resume normal production.

 

I agree with the other comments that indicator orgs is the better way to go, and any positives are treated like a positive pathogen result. I understand dairy has more defined requirements due to the high risk of salmonella/listeria, with chocolate using dairy, maybe that's a consideration as well.


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GMO

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Posted 10 September 2026 - 03:15 PM

I really worry about this growing trend for people to not test food contact and product samples. I understand the pragmatism. The consequences of a positive are severe in some markets. But they're severe for a reason. Instead we decide not to know. While hygiene indicators are useful, they're not everything and I've certainly seen situations where a specific niche has been almost perfectly designed for pathogen survival meaning the hygiene indicator is in spec but the pathogen is not. Especially if only clean surfaces are checked. 

 

I understand it, I understand why people do it but does it really keep consumers safe?


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