5 Ways to Optimize Your Environmental Monitoring Program
By Claire Zoellner, PhD
Food Safety Scientist
March 15, 2022
Recent investigations of foodborne illnesses have highlighted the increasing importance of risk management in the food industry. Listeria and E. Coli have been especially prevalent, as we’ve seen several recalls from these contaminants in 2021 and 2022. The food industry specifically designs processes towards controlling contamination risks. However, protecting public health requires continuous collaboration so we can adapt best practices as knowledge evolves.
For example, a strong environmental monitoring program (EMP) is a vital component of every food safety program, but best practices may change over time. When was the last time you evaluated your environmental monitoring procedures, routine sampling sites, or corrective actions? Could your program be updated to account for new equipment or processes in your facility? Here are five best practices to implement for your EMP.
1. Review the FDA Guidelines for Control of Listeria Monocytogenes in Ready-to-Eat Foods
In January 2017, the FDA released draft guidance for controlling Listeria monocytogenes in ready-to-eat foods. The draft guidance includes recommendations for designing and implementing an effective EMP. Some key takeaways include:
- Use a risk-based approach that employs strategies based on product characteristics and production methods. Your environmental sampling and testing schedule and corrective actions should be in proportion to the contamination risk.
- Categorize sampling areas of your facility according to the potential for product contamination:
- Zone 1 – food contact surfaces
- Zone 2 – non-food contact surfaces in close proximity to food contact surfaces
- Zone 3 – more remote non-food contact surfaces that could lead to contamination of Zone 1 or 2
- Zone 4 – non-food contact surfaces, remote areas outside of the processing area, from which pathogens can be introduced into the facility
- Create written, scientifically valid environmental monitoring procedures.
- Maintain records of your written procedures for sampling and testing, any corrective actions you take after identifying Listeria spp. in your facility, and your review of test results.
Although the guidance hasn’t been finalized yet, it provides a strong foundation for your EMP and reinforces common practices encouraged by industry associations. Notably, the emphasis on a risk-based approach offers flexibility for each facility. This allows you to tailor your EMP to unique risks and ensures you are taking reasonable steps to mitigate contamination.
2. Widen Your Testing Scope
Do your historical results provide confidence that your EMP could detect a lapse in Listeria controls? Could there be blind spots in your facility sampling plan? Consider updating your routine testing sites or periodically expanding the reach of your testing to new locations. Data should be your guide in this area. You can’t make effective decisions without having sufficient data points to validate them.
Start by collecting a large number of samples from your facility over a short timeframe, including areas above and below the processing equipment. The idea is to occasionally cast a wider net compared to routine sampling, which ensures sampling decisions are based on the potential risk for harborage. It is difficult to know exactly when and where you may find Listeria in your facility. Having a procedure for periodically expanding your testing lens provides a means of validating the routine program.
The science team at iFoodDS offers intensive “swab-a-thons” at facilities to help establish baseline contamination and/or validate existing sample sites. This rigorous sampling provides confidence in your program’s ability to identify and eliminate Listeria harborage in your facility.
3. Create a Living Program That is Adaptable
Your EMP should be carefully documented yet flexible. Think of it as a living program that adapts to new findings and risks. A major part of this adaptability is permitting your team to make decisions based on new data. For example, give technicians the authority to identify additional or alternative sampling locations, depending on their observations at the time of sampling.
It’s also vital to update your program according to changes in the conditions, products, and/or the environment. Some scenarios that might warrant an update to your EMP include:
- Interruptions to production
- Maintenance of production line/equipment
- Extreme weather events
- New or alternative traffic patterns
When anything in your facility changes, this is an opportunity for new contamination risks you may not have considered. Your EMP should be a safety net to quickly identify any new risks so that you can mitigate them.
4. Consider Digital Document Storage and Management
In the event of a contamination issue, instant data access is invaluable. You can best achieve this by recording and storing your food safety and EMP data securely online. Paper records are slow and inefficient, providing limited insight into larger trends and appropriate corrective actions. With digital data management, you can instantly reference historical data and cooperate with root cause analysis and investigations.
Digital data management also helps you conduct your own routine review so that you can make continuous improvements to your EMP. When all the data is organized in one place, it’s easier to spot trends you might have missed on paper.
5. Be Open to Utilizing New Technology
Consider where you can utilize new technology, such as:
- Rapid detection methods
- Further characterization of presumptive positives and positives (e.g., confirmation, speciation, subtyping, or whole genome sequencing)
- Data analytics and models
As the industry works towards smarter food safety, we must be open to continuous innovation. For example, the FDA now routinely uses whole genome sequencing in investigations to help accurately pinpoint the source(s) of contamination. In some cases, this narrows down the scope of recalls. However, there is still much work to be done, including improving traceability throughout the industry.
One emerging area of smarter food safety is data analytics and modeling. iFoodDS has worked with its science team to develop the EnABLe model for predicting Listeria presence. This agent-based model helps identify the areas of highest risk for Listeria contamination in a facility. Using data from your facility design and workflow, the model simulates production and potential Listeria contamination dynamics to help you develop a more robust EMP.
Work with iFoodDS to Optimize Your EMP
iFoodDS provides Environmental Monitoring Solutions to help food processors validate and optimize their EMP. Our science team provides the right level of support for your organization with multiple service options, including:
- A detailed review of your current EMP
- Intensive sampling and testing
- An agent-based simulation for your facility
Reach out to our team to get a free consultation and a custom quote.