Common Issues with EMP Programs
Many companies lose sleep at night, wondering if their food safety program is sufficient to detect food safety issues before they become a problem. However, upon further review, the environmental monitoring (EM) program is not sufficiently designed to detect problematic facility operations and maintenance areas. Let’s look at three areas that are insufficiently addressed or three areas where mistakes are made in the EM program and design.
First, many programs are not designed around a comprehensive environmental assessment of equipment, facility design, and maintenance and how this impacts our EM program.
Recently, EM assessments were performed in two very different facilities. One, plant A, was an older facility (50 to 60 years old), and the second, plant B, was a new construction. Plant A was a retro-fitted facility being utilized for products for which it was not designed. Plant B was a new construction where the product flow was explicitly designed into the facility. As you can imagine, plant A had many more facility design issues, and product flow was problematic, resulting in EM issues. Plant B had a product flow built around hygienic zoning with climate control designed to minimize many facility issues (condensation).
These differences eliminated many EM issues during facility design and construction. The result was that plant B required much less EM sampling and analysis. A well-designed EM program considers all the factors that can contribute to product contamination and builds the required sampling into the program based on risk.
Second, many EM programs have established sampling sites and frequencies designed such that sites exhibiting product entrapment and growth niches are not detected. Unfortunately, some of this is by design, and some in error. Many programs only sample the easily-cleaned surfaces. EM programs should include equipment teardown and further sampling to reach those hard-to-clean surfaces that harbor products and microorganisms.
Doing a “deep-dive” into equipment and looking for facility areas compromised by water is essential to detect harborages and growth niches. A well-designed program should detect problems. Any program that does not include “high-counts” or pathogen-positives from time to time is probably not well-designed.
Many companies do not have a well-designed corrective action and root cause analysis program. If a program is well-designed, then positive outcomes will occur. What sets a great program apart from a sufficient program is how EM problems are dealt with. Root cause analysis is necessary if recurring issues are going to be eliminated.
In today’s business and legal climate, detecting problematic areas before they happen and continuously removing or addressing them through a thorough root cause analysis and corrective action program is essential.
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