Environmental Monitoring Program

Hello,

Just wondering but we are going to be SQF and our last audit identified that our Environmental Monitoring Program needed to identify that we swab samples at T3. However we do not always swab at T3 sometimes we swab prior to production, End of production. I don't want to get into any issues if I write it that we can choose which time we would sample at. If we were to sample at T3 one month and prior to production another month but my program only said T3.... How do I write it into my program in a way that would comply with SQF and satisfy the auditor. Any help would be appreciated. :) 

Thank you 

Hi Kate,

Can you inform which clause in SQF relates to yr query ?

Specifically, what is T3 ?

sorry our language... means three hours into production. I can't find in the code where it says that I need to include the time of the samples taken. All it asks for is the frequency of the swabs sampled which is monthly. 

Hi Kate,

I presume this is related to  11.7.4.v

v.   An environmental monitoring program shall be in place for high risk areas. At a minimum, a written
procedure  detailing  the  applicable  pathogens  or  indicator  organisms  to  test  for  that  industry,  the
number  of  samples  to  be  taken  and  the  frequency  of  sampling  and  corrective  actions  shall  be
documented.  The  responsibility  and  methods  shall  be  documented  and  implemented.  A  sampling
schedule shall be prepared.

 

from the Guidance -
 

 

An environmental monitoring program (EMP) is a program which includes pathogen swabbing to detect risk in
the sanitary conditions of the processing environment and is a verification of the effectiveness of the pathogen
controls that a management facility has in place for high risk foods (refer Appendix 2: Glossary of Terms).
Swabbing must include not only the smooth, accessible parts of the process, but also the transfer points,
bearings, etc., where product is likely to build up.

 

Yr product / process is unknown which makes comments a bit difficult.

SQF users may have more direct advice but IMEX the EMP sampling locations are based on a zoning setup / risk assessment and can then be rotated according to a logical  plan using a selected frequency, eg monthly. ie you simply write the sampling procedure to correspond to yr intended actions.

Not sure if that helps, actual SQF users may offer more..

We are SQF Certified and have been for several years.  We just state that our environmental samples will be taken throughout each production day.  We train not to sample until at least 3 hours of production have passed, but we do not sample specifically at T3.  We have two shifts and we rotate each week between the two shifts.  We do have a few areas that have to be sampled at pre-op as you can not access them during production and we label them for that specifically.  We have not had any issues with this method from any of the 4 different SQF inspectors we have had.  Each year they just ask that we are taking them after 3 hours of production and we respond yes.

If the pre-op samples are important to you, you might consider taking samples at pre-op once a quarter on a randomly picked day and justify it by saying your are doing so to verify sanitation but based on the training I have received, the majority of your samples should be taken after 3 hours of production to ensure you do not have harborages or are not tracking the microorganism around.

Hi Mulan,

Thks for yr input.

is there any particular reason for the SQF fascination with "3 hours". ?

Arbitrary number "adequately" separated from pre-op check time ?

"....We have not had any issues with this method from any of the 4 different SQF inspectors we have had.  Each year they just ask that we are taking them after 3 hours of production and we respond yes."

Sounds like some inspector(s) got stuck on the 3 hour thing, curious to know where the inspectors are getting that from?