Expert Answers to 8 Questions from Our Environmental Monitoring Webinar

Our dynamic webinar featured David Acheson M.D., former Associate Commissioner for Foods at the FDA and developer of the 2007 Food Protection Plan, and François Bourdichon Ph.D, food safety microbiologist and Principal Consultant for Food Safety, Microbiology and Hygiene. The session was moderated by Karim-Franck Khinouche, CEO and Founder of Novolyze.

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We were unable to get to some of the many excellent viewer questions we received during the webinar, so we asked our presenters and experts to answer you:

Q.​​​​​​​ I have a not ready-to-eat product, containing raw meat as an ingredient. The product is assembled in one room. Raw meat is occasionally on the process floor. If I monitor our environment for pathogens and find a positive, how can I differentiate if the positive came from my raw meat or if there is a problem that exists in my environment?

A. Strain typing at the subspecies level, if not at the strain level, will help you to discriminate from occasional "transient" isolates that do not persist in the processing environment vs. "resident" strains that can persist for years if not decades. You need to go beyond the simpler analytical methods to track the possible sources of contamination.

Q.​​​​​​​ Environmental Monitoring Plan (EMP) software seems great, but it is expensive and I don’t think I could get approval for it. How could I convince my company that it is worthwhile?

A. Run a mock exercise and see how it would go with EMP software. If you are looking for FSSC22000 V6 certification or renewal, EMP software will give you compliance with the requirements (points 2.5.7.c and 2.5.7.d). Prevention is cheaper than cure, but it is indeed not free. One cannot decide not to invest and take on the risk of a crisis, because that often puts the company out of business.

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​​Q. We are a low risk/low water activity facility (cookies, snacks, and cereal). For EMP, I have Listeria spp. as an indicator, and yeast and mold. Should I add Salmonella spp.? I also have onsite Listeria testing, and product testing including Salmonella.

A. Listeria spp. is not relevant for low moisture food facilities, but rather Salmonella spp. The Hygienic Indicator is Enterobacteriaceae for surfaces, yeast and molds for the air. There is no correlation between EB and Salmonella for monitoring, so expect to do both. Monitoring only EB and, in case of deviation, Salmonella is known to be inappropriate and, at least in Europe, forbidden and stated as such in EU Regulation 1441/2007.

Q.​​​​​​​ I hear a lot about AI and predictive analytics in swabbing and sanitation. Do you think this is something that is inherently important in an EMP program, or we can wait on it?

A. It is important indeed to have insights on the isolates (resident vs. sporadic) for tailor-made controlled measures. But this is not something that can be implemented overnight. It is relevant to consider, but it is important to plan appropriately and decide what is must have and what is nice to have.

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Q.​​​​​​​ It was established that Listeria monocytogenes was resident in the IQF freezers in the 2018 outbreak involving frozen vegetables. Often processors do not include the inside of freezers to be critical - and classify the surfaces as zone 2 or even zone 3. Indeed, the air used in the freezing was shown to be an important vector in transferring the pathogen to the vegetables. What do you consider would be best practice in monitoring these areas of frozen food plants?

A. Following the episode you mention, which happened due to contamination in a chilling tunnel in the Hungarian factory, guidelines have been published and freely available for tackling this issue. The document is available at this link.

Q.​​​​​​​ I've heard I can cut my EMP budget significantly using software. Is that true?

A. Indeed, implementing a digital EMP solution can significantly cut down on your EMP budget by reducing the need for manual labor and resources required for traditional EMP methods. Additionally, the real-time data the software provides can allow quicker and more targeted responses to potential hazards, further reducing costs associated with corrective actions.

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Q.​​​​​​​ I want to implement Enterobacteriaceae monitoring in zone 1 as a hygiene indicator before the cleaning and sanitizing process. But there is a fear of what will happen with the product if the analysis goes out of limit. The risk of contamination is low (with a dry food), but is not impossible. Is there a recommendation of what to do with the product?

A. Zone 1 (i.e. Food Surface) swabbing is always critical, in case of non-compliance. The best approach is to do Z1 testing with "positive release" as necessary. For hygiene criteria, the product, in the case of a positive surface swab, indeed has a hygienic deviation. But it is not necessarily unfit for consumption. Nevertheless, an extended criteria on the finished product is recommended. This point is highlighted in the Codex Guidelines 21/1997.

Q.​​​​​​​ What are a few things I should look for to tie my EMP into my sanitation program, so that it is fully incorporated?

A. Ideally, it would be advisable to look for an EMP solution that allows for real-time monitoring and data analysis, integrates with your existing systems, provides detailed reports and alerts, and offers support from a team of food safety experts. Doing so will ensure that your EMP is seamlessly integrated into your food safety program, resulting in improved compliance and reduced contamination risks.

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