Environmental Monitoring

FSMA TRAINING: ENVIRONMENTAL MONITORING

Environmental Monitoring

Theo Morille-Hinds – Kellogg’s

Listeria Monitoring: Frozen Food Industry

Environmental Monitoring

Our Vision To enrich and delight the world through

foods and brands that matter

Environmental Monitoring Frozen Food Industry Best Practices

• Ingredients & Packaging • Processes • Environment

IDENTIFY • Hazard Analysis

• Science Based Justification UNDERSTAND • Cause & Justification

• HACCP CCP • HACCP Control Point • Pre-requisite PCs

PREVENT • Identify PCs

• Observe & Test • Identify Triggers • ID when limits exceeded

MONITOR • Adherence to PCs

• Mitigate Issue • Correct Process & Root Cause • Prevent Re-occurrence

ADJUST • Corrective Actions

VERIFY • Compliance & Effectiveness Pathogen Environmental Monitoring

Management Commitment

Employee Engagement

Regulation

Science-based Standards

Documentation

Sustainability

HACCP Program

Essentials Preventive Control (PC) Cycle

Chemical Control

GMPs

Facility / Equipment

Allergen Control

Sanitation

Pest Control

Utilities / Waste

Product Protection

Supplier Mgmt.

Trace and Recall

Production Control

Storage & Dist.

Training

Food Defense

Documentation

Building food safety into every Kellogg product, every day!

Foundational Pre-requisite Programs

Environmental Monitoring Golden Six

Environmental Monitoring

The program should be designed to: 1. Verify the effectiveness of your preventive control programs. Preventive

control programs include but not limited to: Sanitation Facility hygienic zoning Personnel practices GMP

2. Find, eliminate and prevent growth niches (seek-and-destroy)

A proactive approach to aggressively identify opportunities for continuous improvement

Finding a positive in this case should be rewarded

Listeria Environmental Monitoring Program (LEMP)

Environmental Monitoring

Risk based & flexible Cross functional team Target organism(s) Site map & zone selection

Testing frequency & criteria

for site rotation.

Root cause analysis and corrective actions

Data analysis & trending.

Reporting and escalation process

Training Documentation & Record

Keeping. Verification and Validation

LEMP Program design – Things to consider:

Environmental Monitoring

STAGE 1 STAGE 2 STAGE 3 STAGE 4 STAGE 5 Environmental Pathogen Sampling Plan

Swab Sampling Frequency Daily Weekly 2x per Month Monthly Determined by risk

assessment Zones Impacted Z2-4

Type of test Listeria spp. or Salmonella (OR Both) Total Swab Quantity 1 of 4 data sets from the master plan

Rotation of Swabs For each scheduled sampling event, rotate through each of the 4 sub-sets derived from the master plan until all sub-sets are sampled.

Ability to escalate or de-escalate based on risk (routine, adverse event, construction) Listeria spp. vs L. monocytogenes

Listeria spp. are a broad indicator of conditions favorable for growth of L. monocytogenes.

Table 1 – Sample stage approach

LEMP Program Design: Risk Base & Flexible

Environmental Monitoring

Zone 4 Remote areas from the RTE

manufacturing areas. Example: loading dock,

receiving area.

Zone 3 Other surfaces within the

RTE room. Example: floors, walls,

drains.

Zone 2 Surfaces adjacent to

Zone 1 areas Examples: equipment guards

and frames

Zone 1

Direct and in-direct food contact surfaces with high

potential impact food. Example conveyor belts. inside covers of conveyor

belts over open food.

LEMP Zones

Environmental Monitoring Starburst Sampling Pattern

for Vectoring

Original Positive

site

Environmental Monitoring Conclusion

LEMP should be a component of your food safety plan.

The program must be flexible and risk based. Include a robust training program Finding a positive during “seek & destroy” should be

rewarded. An effectively designed and implemented program

will significantly reduce the risk of contamination to the RTE food.

Follow the data.

Environmental Monitoring

APPENDIX

Environmental Monitoring Root Cause Analysis &

Corrective Action

Root cause analysis and corrective actions should be conducted any time Listeria spp. or L. monocytogenes positive is identified in the processing facility.

Review of cleaning records Review of environmental data of the

area as well as adjacent areas Review of line records, for mechanical

down time or unusual activity Interview employees Inspection of the area and the

equipment for potential harborage points

Vectoring; monitor traffic pattern

Typical RCA includes but not limited to:

Increase swabbing frequency Increase number of sites Evaluate the need for finished food testing

if positive is Z1 Reinforce hygienic practices and retrain

employees, if necessary Make any appropriate repairs. For example,

repair damaged walls, drains and floors Adjust LEMP as needed

Typical CA includes but not limited to:

Environmental Monitoring Documentation

All facilities where food is subjected to post-process contamination

should consider an LEMP. Document all LEMP monitoring activities. These could include the date,

time, zone, line, and sampling location (may include condition of location).

Documentation should be reviewed and maintained as per company policy.

Document corrective action activities and outcomes. Document all test results and corrective actions to close out the

incident. The documentation demonstrates due diligence and can also serve as a

reference should a similar incident surface. Document updates and changes to the LEMP.

.