Cleaning, Sanitation, and Environmental Monitoring Programs – How They Work Together
Food production operations generally devote an entire shift plus fully dedicated teams to painstakingly clean and sanitize their plants. It’s a critical element of each company’s food safety system. Cleaning and sanitation crews must know how to disassemble complex processing equipment, which cleaning solutions to apply, and how to apply them effectively. But how can team members—or their managers—really be certain that a line is sufficiently cleaned and sanitized?
The complex sequence of cleaning and sanitizing steps must be completed correctly to ensure food safety while not disrupting productivity or product quality. Companies depend on the knowledge and confidence of their employees to successfully complete the cleaning and sanitation process correctly. Frontline employees must be thoroughly trained so that processes are strictly followed and the cleaning/sanitation operation is consistently executed.
Sophisticated, comprehensive, yet affordable training delivery systems are available to deliver that knowledge and confidence. But the actions of a well-trained workforce executing to standard on cleaning and sanitation operations still aren’t a guarantee that all contamination risks have been eliminated.
Environmental monitoring—what is it?
An environmental monitoring program (EMP) provides vital information about the possible presence of indicator microorganisms and pathogens. EMPs evaluate the effectiveness of a plant’s cleaning and sanitizing practices by assessing both the cleaning and sanitizing frequency and the cleaning methods utilized. Testing data resulting from the EMP will provide useful information in determining the state of control of the facility.
Effective EMPs must be fundamental parts of modern food manufacturing and safety systems. FSMA guidelines state that effective EMPs act as key preventive measures for the control of pathogens. Development of good environmental sampling systems and programs are prerequisites to control and mitigation of the risk of pathogens harbored within a processing plant. Poorly designed EMPs may not reveal pathogen harborage in a complex facility. Since food products, processes, raw materials, equipment, employee practices and possible contaminants are unique to a given processor and facility, effective EMPs must be designed, equipped, and implemented to fit individual facilities.
Environmental sampling should be performed systematically and on a regular basis. The first step is to clearly understand the objectives for your EMP. What risks are you working to mitigate? What organisms are you looking to identify? What is your baseline for acceptable results? How will you use the results and trend data? How will you respond to the EMP findings? If you are not fully prepared to answer each of these questions with a well thought out plan, you could find yourself implementing an ineffective program or, worse, expose yourself to uncalculated liability. Initially, to best understand the higher risk elements of a specific plant, baseline sampling is typically performed throughout the plant with the goal of understanding those locations within the plant that may be harboring unacceptable organisms or creating cross contamination potential. The duration of this baseline sampling should occur over a period of time and address all areas of the plant in order to be representative of the operations and the different conditions of operations. Establishing the resulting ‘hot spots’ from the analyses of this baseline data will allow you to create a sampling cadence focused on those locations posing the most microbiological risk to the product.
A useful tool that can help in site selection and managing your EM program data is the zoning concept. Using the principles of the zoning concept, plant operations are divided into four zones based on level of product risk – from product contact surfaces as Zone 1 to Zone 4 that could include locker rooms, hallways and breakrooms. It is absolutely critical to understand the implications of sampling, testing and addressing potential positive results in each of these distinct zones as the corrective actions will typically vary. It is also important to understand the food safety regulations as they pertain to not only your product but your process.
Results and trends
Record and track sampling results over time. Not only will individual results sometimes require a specific corrective action, but trends in test results can also trigger their own corrective actions. When results exceed the action levels, a clear protocol of retesting, more frequent testing, more intensive testing, vector sampling etc. is needed to address this identified risk. Having a cross functional team that can analyze the findings and collaborate on the root cause and necessary corrective actions is valuable. As an example, poor sanitation could be one contributing issue but, if the team can dig deeper collectively, often other causes are identified like poorly maintained equipment that is creating a source of harborage, inappropriate foot or equipment traffic, ingredients not meeting specifications, etc. In fact, plants need to go beyond root cause analyses and find the root source and address!
Cleaning and sanitation operations are inadequate without the verification of a commensurate EMP. Similarly, a poorly designed or unscientifically-based EMP is a waste of time and money, because results of inadequate environmental monitoring will not accurately identify whether the operation is in control. Cleaning, sanitation, and environmental monitoring programs must be fully coordinated and integrated in order to mitigate the inherent food safety risks we face daily.