Environmental Monitoring Program for Kombucha?

Hello,

I am working as the quality control manager at a kombucha brewery that is working towards SQF certification. I know that environmental monitoring is necessary in order to achieve SQF certification but it is not clear what level of monitoring is necessary. Our pH of the product starts out around 3.5-3.7 and goes all the way down to 2.9-3.1 at the end. I know anything under pH 4.6 is considered not able to grow or support pathogens. 

My question is, do we need to monitor for pathogens such as Salmonella and Listeria? These organisms would not survive or grow in the product, so common sense tells me no although I haven't found a clear answer. We do ATP swabs to confirm that our cleaning processes are effective so as of now I was thinking of just having ATP swabs be our environmental monitoring program. Would this be sufficient?

Thanks,

Riley Lynch 

My first though is that since there have been salmonella outbreaks in orange juice documented, which has a low pH, you will need to at least start your program with salmonella testing of non food contact surfaces. 

Listeria likes to live in drains, coolers, and moist areas, and can survive inside biofilm material that builds up when drains are not physically scrubbed, regardless of the pH of the product you are making.  

Try using your plant flow diagram to look for places that are hard to clean, wet or damp for a large portion of the day, along employee routes from the outdoors to inside, and in any cooler you have, especially drains in coolers.  Listeria is also found near rust, and under things like trashcans, hand sink foot pedals, inside motor boxes and control panels, maintenance carts, ladders, beneath cooling units, basically the underside of anything or where people step.  See if you can find anything and then base your program on your findings.   It's probably somewhere, unfortunately.  Just don't swab product contact surfaces or above them., in areas that could indicate product contamination.  

Hello,

 

I am working as the quality control manager at a kombucha brewery that is working towards SQF certification. I know that environmental monitoring is necessary in order to achieve SQF certification but it is not clear what level of monitoring is necessary. Our pH of the product starts out around 3.5-3.7 and goes all the way down to 2.9-3.1 at the end. I know anything under pH 4.6 is considered not able to grow or support pathogens. 

 

My question is, do we need to monitor for pathogens such as Salmonella and Listeria? These organisms would not survive or grow in the product, so common sense tells me no although I haven't found a clear answer. We do ATP swabs to confirm that our cleaning processes are effective so as of now I was thinking of just having ATP swabs be our environmental monitoring program. Would this be sufficient?

 

Thanks,

Riley Lynch 

Hi Riley,

As indicated in Post 2, the belief that micro. pathogens don't grow below pH 4.6 is variously stated in the Literature but is incorrect, eg -

 pH and growth of micro pathogens.pdf   2.72MB   33 downloads

Generally food EMPG programs necessitate microbiological measurements. The specifics may depend on the product/raw materials, etc but, pathogen-wise, dry environments often focus more on Salmonella and wet ones on L.monocytogenes but in US I get the impression that "Listeria" must be included for every conceivable situation.

Some examples -

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

PS - I also noted this comment in Wiki -

Because kombucha is a commonly homemade fermentation, caution should be taken because pathogenic microorganisms can contaminate the tea during preparation.

https://en.wikipedia.org/wiki/Kombucha

Don't forget the infamous unpasteurized apple juice in the 90's and E coli O157:H7. Apple juice pH is low, and everyone believed it to be incapable of supporting pathogenic growth.

https://www.foodsafe...o157h7-outbreak

Don't forget the infamous unpasteurized apple juice in the 90's and E coli O157:H7. Apple juice pH is low, and everyone believed it to be incapable of supporting pathogenic growth.

 

https://www.foodsafe...o157h7-outbreak

Hi juanolea,

Indeed.

Also see the table in attachment post 3 although this time Salmonella seems the culprit while path.E.coli goes for V8 juice (whatever that is ?).

Hello,

 

I am working as the quality control manager at a kombucha brewery that is working towards SQF certification. I know that environmental monitoring is necessary in order to achieve SQF certification but it is not clear what level of monitoring is necessary. Our pH of the product starts out around 3.5-3.7 and goes all the way down to 2.9-3.1 at the end. I know anything under pH 4.6 is considered not able to grow or support pathogens. 

 

My question is, do we need to monitor for pathogens such as Salmonella and Listeria? These organisms would not survive or grow in the product, so common sense tells me no although I haven't found a clear answer. We do ATP swabs to confirm that our cleaning processes are effective so as of now I was thinking of just having ATP swabs be our environmental monitoring program. Would this be sufficient?

 

Thanks,

Riley Lynch 

This is environmental testing, the pH of the product could part of the risk evaluation, but isn't a limiting factor.  "What is the pH of the scum in the floor drain" is a more relevant detail, but not one that needs to be answered.  The environmental testing is about all those surfaces and niches that may or may not be meant to have direct contact with product, but could serve as harborage points if sanitation processes aren't carried out to a theoretically perfect level of execution.

Some relevant sections:

Being "risk-based" and considering all "applicable pathogens or indicator organisms for that industry" leaves you some room to include or exclude, but you will need to give explanations for why residues of the product will or will not not support growth for pathogens.  You will want to list some of the common pathogens in your risk analysis like Salmonella or Listeria even if you decide to exclude them and explain why your product residues won't support them (this seems unlikely).

Not just the product itself, but with added effluent from the sanitation process and time -- that will probably support something; are versions of it pathogenic?  Kombucha is fermented, what other than the intended microorganisms could grow in that substrate if the suppressing acid or alcohol level is too low -- raw and intermediate stages of the product need to be considered, not just the finished goods.

This is environmental testing, the pH of the product could part of the risk evaluation, but isn't a limiting factor.  "What is the pH of the scum in the floor drain" is a more relevant detail, but not one that needs to be answered.  The environmental testing is about all those surfaces and niches that may or may not be meant to have direct contact with product, but could serve as harborage points if sanitation processes aren't carried out to a theoretically perfect level of execution.

 

Some relevant sections:

2.4.8.1 A risk-based environmental monitoring program shall be in place for all food manufacturing processes and immediate surrounding areas, which impact

manufacturing processes.

 

2.4.8.2 An environmental sampling and testing schedule shall be prepared. It shall at a minimum:

i. Detail the applicable pathogens or indicator organisms to test for in that industry;

ii. List the number of samples to be taken and the frequency of sampling;

iii. Outline the locations in which samples are to be taken and the rotation of locations as needed; and

iv. Describe the methods to handle elevated or undesirable results.

 

2.4.8.3 Environmental testing results shall be monitored, tracked, and trended, and preventative actions (refer to 2.5.3.1) shall be implemented where unsatisfactory results or trends are observed.

 

 

Being "risk-based" and considering all "applicable pathogens or indicator organisms for that industry" leaves you some room to include or exclude, but you will need to give explanations for why residues of the product will or will not not support growth for pathogens.  You will want to list some of the common pathogens in your risk analysis like Salmonella or Listeria even if you decide to exclude them and explain why your product residues won't support them (this seems unlikely).

 

Not just the product itself, but with added effluent from the sanitation process and time -- that will probably support something; are versions of it pathogenic?  Kombucha is fermented, what other than the intended microorganisms could grow in that substrate if the suppressing acid or alcohol level is too low -- raw and intermediate stages of the product need to be considered, not just the finished goods.

Hi GM,

It is probably sufficient to just implement/borrow an appropriate "zoning" scheme from the examples in the link of Post 3. This "=" Risk Assessment.

Thank you all for your responses. It sounds like just low pH and lack of ATP in the environment alone aren't enough to justify not sampling for Salmonella or Listeria. However, I have found many studies demonstrating anti-pathogenic properties of kombucha against Salmonella and Listeria spp. Here is one example: https://www.mdpi.com.../26/16/5026/pdf . I am guessing that we would have to do a validation study to confirm that our product does kill these pathogens since one lab study doesn't really prove that this actually happens in our product. Does that seem like something that is doable and that would be acceptable to an SQF auditor? 

Thank you all for your responses. It sounds like just low pH and lack of ATP in the environment alone aren't enough to justify not sampling for Salmonella or Listeria. However, I have found many studies demonstrating anti-pathogenic properties of kombucha against Salmonella and Listeria spp. Here is one example: https://www.mdpi.com.../26/16/5026/pdf . I am guessing that we would have to do a validation study to confirm that our product does kill these pathogens since one lab study doesn't really prove that this actually happens in our product. Does that seem like something that is doable and that would be acceptable to an SQF auditor? 

Hi rlynch,

Unlikely IMO. Maybe have a look  at the various existing responses to SQF's requirement.

Also note the "shall" in SQF clause.