When developing and implementing a comprehensive sanitation program, food companies need to relentlessly look for pathogens, rather than swabbing to satisfy compliance requirements, says Food Safety Specialist
“The biggest mistake I see when doing an initial audit of a food company’s sanitation program is that they are not trying to find problems,” explains Dunn. “Rather than looking for a specific pathogen, like listeria, and looking for specific pathogens in high risk areas, the company will stick to a standard set of swabs and not deviate this practice when consistently receiving negative results.”
Instead, food companies need to be approaching it with the mindset that pathogens are present – and must do everything possible to find them, prevent them from contaminating product and find a solution to mitigate any future risks.
According to Dunn, this requires a strategic Environmental Monitoring Program (EMP) to assess the effectiveness of current sanitation practices and to gather and analyze required data to implement corrective actions.
“Look at it as one big defensive line. Your EMP program is always going to be paramount to knowing where your issues are and leading into those corrective actions – which is usually where things fall short. You know you have an issue and put all corrective actions through your verification process. But, how do you take your swabs, your vector swabs and follow-up? A lot of facilities have issues with closing those corrective actions now because so many of them are redundant depending on how many swabs you had,” he explains. “EMP should ensure follow-up swabs, and that high risk areas are focused on. It should also ensure additional non-routine swabs are being introduced, with results reported to the food safety team. It goes hand-in-hand with a food-safety program – serving as a blueprint of how a facility operates.”
Create an EMP team
Through his experience of working with individual companies on EMP, Dunn has found one of the most effective ways to create and execute a comprehensive program is to create a designated EMP team. This should include “owners” of specific aspects, like quality and sanitation managers, to be the driving force behind EMP practices related to their area of the operation.
“Making sure that your team is large enough to be able to make a voice but also small enough to be able to work together as a team to where you can get things done. Depending on the size of the facility and automation, I’ve found teams are most efficient with six to 10 members,” he explains.
While not a common practice, Dunn also advocates for EMP teams to include one outsider within the company that doesn’t specialize in food safety.
“Get a member of the finance team or someone the front office and let them come out and help you. I know a lot of people might not jump to that opportunity but you’d be surprised the insight you’d get from folks that are not completely blinded by the day-to-day operations. You get questions that normally other professionals in the industries won’t ask because we all assume we understand it if that makes sense,” explains Dunn. “In one company we worked with, we brought in the maintenance team leader. Typically there is friction between maintenance and sanitation. However, he had a tremendous amount of insight to offer and contributed a lot of useful outside thinking that allowed the plant to feasibly improve food safety practices.”
When developing an EMP, the team should look at the facilities as a whole, and perform a risk assessment over the entire plant. This will help establish pathogen testing location, time and frequency.
“An EMP team will map out the facility and look at all the risk factors. Multiple risk assessments will be conducted by your team, looking at all the areas in your plant, from where vectors are located to where employees are walking,” he says. “Everything that can pose a risk will be taken into consideration to determine swab sites.”
There are four standard sampling zones for all swab testing, based on risk. Generally, sanitation effectiveness swabs for things like aerobatic plate count are done Zone 1 and Zone 2, and EMP pathogenic testing is done in Zone 3 and Zone 4.
Zone 1: Direct product-contact surfaces like processing equipment (non-EMP)
Zone 2: Non-food contact areas closely adjacent to Zone 1 like equipment framework (non-EMP)
Zone 3: Non-food contact surfaces not close to Zone 1 like floor wall junctions or forklift traffic patterns
Zone 4: Remote from product processing areas like employee breakrooms
Once the EMP team has established swabbing guidelines based on the risk assessment, it is paramount they be followed in conjunction with good manufacturing practices (GMP) to minimize any additional pathogen contamination risk.
“Humans are the number one vectors and typically the biggest risk factor to a food safety compromise. Food fall is one of the main issues, with people coming in and out of different areas of a facility. Because of this, micro-mapping a facility is very beneficial to outline which areas of a plant an employee is allowed in and which areas they must avoid to prevent cross contamination,” explains Dunn. “Human error is also leading cause for failed EMPs. This has to be executed by your team – and that takes good management leading a good crew. One of the craziest things I’ve seen over the years working in plants is that a company will have a guru-quality manager that’s been in the industry for years and knows everything. They’ll know all the procedures and have a tremendously put together plan. But if every single bullet point on the plan isn’t being implemented – then the plan doesn’t really matter.”
There is no one and done
The most important factor to a successful sanitation program is to update the EMP practices based on where issues are coming in from.
“EMP is a complete living program that evolves and changes every month as you look at the areas you’re excelling in and the areas that need to be improved. It’s constantly changing so that your program isn’t going to become stale – It’s actually going to evolve into what you need it to be,” concludes Dunn.
Source: Food Safety News