Your Environmental Monitoring Program isn’t just a scoreboard where you compile “good” or “bad” numbers; it should drive change.
“Environmental monitoring is most valuable when it changes what we do. A positive or an elevated trend is not the end of the story. It is the environment telling us that one or more controls may not be working the way we think they are,” Neil Bogart, Assistant Director of Sanitation at Post Consumer Brands, said.
Speaking in the Food Safety Magazine webinar, Advances in Environmental Monitoring Science and Strategy, sponsored by Rootwurks, Bogart said that the EMP is a feedback system that signals when we should investigate and intervene.
Bogart and fellow panelist Dr. Byron Chavez, Associate Extension Specialist and Professor, Department of Food Science at Rutgers University, dived into the subject of swabbing during environmental monitoring and why it’s such a crucial component to creating safer production facilities.
“When there is an environmental pathogen that persists despite normal cleaning, I do not immediately assume we need a stronger sanitizer. I start asking what is protecting the organism? Is there damaged flooring? A crack? A poor transition? A moisture source?”
He added that diagnostic swabbing that finds persistent safety issues “tells us the routine control system has a gap somewhere.”
He said in such instances he wants teams to investigate four issues:
“This is where validation and verification become more than paperwork. The point is to prove the intervention works and improve the routine so it keeps the problem from coming back,” Bogart said.
Environmental monitoring requires sampling that is used to build a broader picture, based on data. And that data must be digitized.
“The largest advancement in environmental monitoring programs is our ability to use the data we already have. Food manufacturers have accumulated years of environmental results. The problem is that a lot of that history still sits on paper,” Bogart said.
He added that facilities should use heat mapping to see where risk is concentrated and track trends to see if an issue is isolated, recurring seasonal, equipment-specific, or shift-specific.
“The best system is not the one that is the prettiest. It is the one that helps you and the team see the signal early enough to act before a signal becomes an event,” Bogart said, adding that “if your environmental monitoring program is still entirely on paper, you have probably already lost some of the value in the data that you’ve already paid to collect.”
Environmental Monitoring must take into account the unique conditions of the facility if it is to be effective, Byron Chavez said.
“We need to understand our own conditions. The first thing I do with companies is assess the GMPs (Good Manufacturing Practices), to always ask how good the GMPs are and then develop some kind of verification checklist.”
Chavez said this results in much better risk assessment for the facility, the product, and the process, and then you can start looking at how you are performing sanitation.
Knowing the conditions also makes it possible to know where best to perform sampling.
“It is very difficult for me to tell you where to sample because I don't know where it will give you the most information,” Chavez said, adding that it must be long-term.
“You can’t make decisions with data that you've just collected for a couple of days. You need historical data that you can trend to see what is the actual normal behavior of your facility.”
He also said it is crucial that “don’t sample where you know you’ll pass.”
“Places that are very easy to clean and sanitize and to move the equipment and everything is spotless - that is not the equipment that is going to give you the most information. So design the sampling plan to find the problem, not to demonstrate that there are sites that are very easy to clean and sanitize.”
In addition to where, it also matters when you sample, according to Chavez.
“The timing is particularly important. We make comparisons so that we can see if there's something that's happening throughout time. If the shifts are different, the personnel is different, maybe we are using slightly different ingredients or ingredients from a different supplier at a specific time of the day.”
But regardless of what you find, Chavez said it is important to always know the context.
“To actually take corrective action, we need context. This means documentation and verification. This is how we strategically sample and do confirmation."
To train your team in how to launch an effective EMP, enroll in the Rootwurks course "Implementing an Environmental Monitoring Program," available on the Rootwurks online store. Available now for only $34.99.
And if you'd like to hear the rest of the takeaways from Advances in Environmental Monitoring Science and Strategy, register here.