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Good Manufacturing Practices (GMPs) or prerequisite programs are the foundation of an effective food safety program such as Hazard Analysis Critical Control Point (HACCP). HACCP requires scientific evidence that hazards associated with ingredients, products, or processing steps are controlled. To ensure that your GMPs are controlling hazards related to the personnel and environment, use an environmental monitoring program to provide scientific evidence.
An environmental monitoring program provides scientific evidence to managers, auditors, employees and clients that the resources and effort put into providing clean uniforms, following traffic patterns, effective hand washing , cleaning and sanitation procedures, sanitary equipment design, etc are effective in providing an environment for the manufacture of safe food.
The environment in a food processing plant can provide sufficient time, moisture, nutrients and other essential conditions that allow pathogenic and spoilage microorganisms to grow and contaminate food products. It is not good enough that facility floors, walls and equipment simply look clean; they must also be microbiologically clean.
For an effective environmental monitoring program, you need to define the following elements:
In addition, hard-to-reach places, such as the inside of equipment, gaskets, hinges, etc., should be sampled periodically to prevent undetected contamination. Consider taking samples of employees hands when frequent hand contact with food is required (ex: in packaging areas), as well as sampling aprons or uniforms.
There are different ways to present microbial results. Examples of different formats include:
Collecting data for one to three months, depending on sampling frequency is usually enough to determine a baseline for most microorganisms. Your baseline may be set at a specific number or, if testing for pathogens, can simply be the presence or absence of them.
Cleaning and sanitizing should reduce microbial loads to levels of less than 10 CFU per sponge for coliforms, aerobic plate count, yeast and mould, and coagulase positive Staphylococcus on product contact surface before packaging.
CFU per sponge values for other areas, including non-product contact areas (ex: walls, ceilings, pallets, drains, floors, etc.), will vary, depending on the plant and type of product manufactured. Aerobic plate counts of above 10,000 organisms should cause concern and an area with 100,000 organisms should be considered a microbial contaminated site.
It is important that the results are analyzed to ensure proper corrective actions can be taken. Once the samples are analyzed, the baseline data can be displayed on a spreadsheet or graph to demonstrate plant performance. A graph will provide easy visualization of the data.
When you understand baseline values for your facility, deviations above the baseline may indicate a failure in your plant's system. This could include changes in traffic patterns, personnel practices and inadequate use of sanitizers. You need to establish corrective actions that include: investigating the cause of the failure as well as retesting positive test areas. Finding the root cause of the problem may lead to a variety of solutions, including repairing the equipment and facility, examining current plant practices and retraining staff. The goal is to prevent reoccurrence. Once action has been taken, it is important to resample the areas, to ensure the solutions were effective. Documentation must show how the problem was addressed and that the corrective actions were effective.
It is important to continue to validate GMPs to ensure they are effectively controlling potential food safety hazards.
For more information, email the CVO/Food Safety Knowledge Centre or call 204-795-8418 in Winnipeg.