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environmental testing

We’ve had quite a lot of enquires around what sort of environmental testing should be done, to meet the BRC standard, so I thought it would be a good idea to go into this in a bit more detail…

Environmental monitoring was added to Issue 8 of the Food Safety Standard and has also been added into Issue 6 of the Packaging Standard.  It’s more than likely that it will be added to the other Standards too, as they’re updated.

What is environmental monitoring and environmental testing?

In a previous article we covered the general principles of what environmental monitoring is, so if you’d like to read that you can do so here: https://techni-k.co.uk/environmental-monitoring

Environment in this context is the surrounding area where the product is produced.

What is an environmental monitoring programme?

A ‘programme’ in general is system made up of activities and actions, which have an overall aim or goal. So, an environmental monitoring programme is a system which aims to make sure that the environment that we produce the product in, doesn’t have a negative impact on that product.

What are the elements to an environmental monitoring programme?

The programme should be made up of 5 distinct parts:

  1. Review of the applicable hazards that the environment could impose on the product
  2. Risk assessment of the hazards identified
  3. Development of monitoring activities where a significant risk is highlighted
  4. Completion of the monitoring activities
  5. Review of the results with corrective and preventive action applied where necessary

1. Review of the applicable hazards

Before starting the risk assessment, you need to determine which hazards the product is at risk from. If you’re producing a product that is chilled, then Listeria monocytogenes should be a hazard.

Salmonella has been identified in ambient product recently as well, so it’s best to include this as a hazard as well and risk assess the likelihood of it surviving in your product.

If you have a product that is susceptible to mould or yeast growth, then this should be identified as a hazard.

General TVCs, as a hygiene indicator should be a hazard which you should include in your risk assessment.

2. Risk assessment

First of all, we need to go over what the purpose of a risk assessment is, as this is really important.

A risk assessment is meant to determine if there is a likelihood of the hazard you’ve identified being a problem in your product. It’s not, a way of removing the need to do environmental monitoring. You can’t risk assess your way out of having to implement monitoring that really should be in place. That being said, if there is no risk of the hazard having an impact on your product, and this is robustly justified through your risk assessment, then you don’t need to do environmental monitoring.

Let’s look at a couple of examples of this, because there are not many risk assessments that will result in no monitoring being needed.

High alcohol strength products
Alcohol inherently controls micro growth, as long as the strength is high enough. Spirits is one of these. Alcohol typically has been used as a way of cleaning to remove microorganisms, so there is an extremely limited or even no risk of micro growing in spirits. Therefore, a risk assessment for spirits, could determine that no environmental monitoring is required.

Non-food / hygiene sensitive product contact packaging
If you’re producing packaging that isn’t food contact or that doesn’t come into contact with hygiene sensitive consumer products (such as cosmetics or baby products), and isn’t used in areas by the customer where these types of products are open, then your risk assessment may determine that monitoring isn’t required.

Other products
For all other products, including low aw products, it is unlikely that a risk assessment would determine that no environmental monitoring is required.

For example; bakery products would need yeast and mould settle plates.  Dried milk powder would need salmonella swabs.  All products susceptible to Listeria would need Listeria mono swabs.  All products where water is used for cleaning would need water sampling.

For example; If you’re producing packaging which is food contact or hygiene sensitive, as a minimum general hygiene indicators for cleaning would be needed such as ATP or TVC swabs.  Where cardboard is being produced yeasts and moulds would also needed, which could be done through settle plates.

3. Development of monitoring activities

Once you’ve completed your risk assessment and determined what hazards your product is at risk from, you need to put together a monitoring programme. This needs to include what monitoring will be done, where it will be done, when it will be carried out and what limits (pass and fail criteria) you’re going to work to.

4. Completion of monitoring

Once you have your monitoring programme set up, you need to work it into your routine, to ensure that the environmental monitoring is completed when and where it should be.

5. Review of results and action

When the results of your environmental testing come in, you need to have corrective action procedures in place, for when the results are out of specification (they don’t meet the limits you’ve set). To do this you need to be able to understand lab reports.  We’ve written an article on this, which you can read here: https://techni-k.co.uk/lab-results/

One common mistake that sites make here, is that the first and only action taken is to re-sample and carry out the monitoring again.  This is one action that can be taken, but it shouldn’t be the only one. The fact that you got an out-of-spec result, cannot be rectified by getting another in-spec result. The problem that caused the first out-of-spec result is still there, even if you get a second in-spec result.  Corrective action must be taken as a minimum, as you should not get one out-of-spec result, if you’ve set your limits correctly.

If the environmental testing results are out of spec sporadically and you can’t tell why, then this is a trend.  Any trend should be assessed to root cause and preventive actions implemented.  It’s not acceptable to cancel out one of spec result, with another in spec result.

BRC auditors on environmental monitoring

The auditors from the certification bodies have been told to make sure that there is an environmental monitoring programme in place for all products. This means, as a minimum you need a risk assessment.  If the risk assessment determines that no monitoring is required and the justification is robust, then you don’t need to put in monitoring.

The auditor will want to challenge your risk assessment, if you have decided that no monitoring is required.  Just having a risk assessment isn’t enough, you can still get a non-conformance if the risk assessment isn’t robust. So, think very carefully about the result it has given you, and make sure you can evidence why no monitoring is in place.

If your risk assessment determines that environmental testing necessary, then the auditor will expect you to have developed a programme of monitoring as we’ve discussed, and it must be in place.  Which means you must have started the testing and have at least some results back.

Challenge

If you have completed a risk assessment and it has resulted in no monitoring (environmental testing) being needed, we’d love to hear about it.  We can use this article as a forum to make sure that your risk assessment is robust.  Please add your thoughts to the reply box below and remember you don’t have to use your real name, so you can stay incognito! If you’ve received a non-conformance for environmental monitoring and you don’t agree with it, please tell us about it too!

12 Comments

  • KK says:

    When hot-filling (and sealing) at temps that provide instantaneous lethality of salmonella and listeria, we find in our risk assessment that there is no need for environmental monitoring since there is no post-lethality exposure.

    • Kassy Marsh says:

      Hi,
      If the temperature is high enough, then yes I would agree. What temperature are you filling and sealing at?
      Thanks
      Kassy

        • Kassy Marsh says:

          So, 165°F is 74°C. For pasteurisation you would need to be able to prove that the material is going into the pack at this temperature and is held at this temperature for at least for at least 36 seconds. If you can do that, then yes, I would agree! 🙂

  • LG says:

    What about all the erroneous results labs give, How often do we get an out of spec, they re-test the same sample and it comes back fine? Surely carrying out an investigation in this case is pointless as is clearly a fault of the lab?

    • Kassy Marsh says:

      Hi
      It may be that the sample you took was out of spec and the second sample that was tested was fine. Sampling typically only tests a small amount of a large batch and therefore there can be variation across the batch. There may also be issues with the way the sample is taken that cause out of spec results, so all these things would need to be checked. If you think that the lab is at fault, then this would be part of your investigation.
      There are so many variables, that an investigation is needed to establish the root cause.
      Thanks, Kssy

  • cm says:

    our process involves using water to make a paste consisting of potato starch and maize (water sampling already carried out), the paste is cooked to min 180 degrees max 200 degrees , this paste is then applied to food contact twines which are then dried on steam cylinders of temperatures around 80 degrees. the twine is then used by the butchery trade for meat tying, the meat is then cooked in an oven.
    would environmental monitoring be necessary in this case?

    • Kassy Marsh says:

      Hi
      I would say that the risk of pathogens is low. Therefore, you would just do hygiene verification of the equipment and also the water used for cleaning. Please note, water used as an ingredient wouldn’t sit under environmental as it’s in the product not a risk from the environment.
      Please check your specs that you send to your customers to make sure it states that the product shouldn’t be used on ready to eat products.
      Thanks,
      Kassy

  • Chris Wilding says:

    Had my audit yesterday, I know that different auditors will have different takes on this (although obviously they shouldn’t!) but thought I’d share that my auditors views were that sites cannot use risk assessments to ‘opt out’. He gave us positive feedback that we had planned to do some checks at various places for various organisms (via air plates) we then reviewed the results in the HACCP meeting and adjusted the areas to check and the organisms to check for based on those findings, adjusting the risk assessment based on this too. (I’m at a rice mill so low water activity product and no wet/chemical cleaning) we did TVC, Y&M & E.coli plates four times to see what results we got at which areas, then dropped to Y&M only, and the frequency to quarterly, which he was happy with. Might be worth having some negative results to strengthen your risk assessment.

    • Kassy Marsh says:

      Hi,
      Thanks for sharing this, that’s great. It’s funny that your auditor said ‘opt out’ – BRC have used this wording too. Although a risk assessment, as long as it’s robust isn’t ‘opting out’. But yes, I agree having some evidence will definitely strengthen the case – but won’t always be necessary. BRC won’t want sites to spend money which isn’t needed, I’m sure.
      Thanks, Kassy

  • Luis P says:

    Very interesting, today I read about the Listeria alert on Southern Spain, most of the experts agree that the meat was contaminated post-bake, therefore stressing how important is environmental testing.

  • Shaun says:

    One example of sites that can “opt out” is companies that manufacture flavourings. I am not a fan of the term “opt out” because I do not see it as the case, they are merely determining by robust risk assessment that it is not required.

    Flavourings that have a propylene glycol content of above 50%, or Ethanol content of above 30% are microbicidal and therefore a risk assessment would generally conclude that environmental monitoring would not be required (so long as all products fit within that bracket).

    There could also be an argument that sites doing soley UHT products into aseptic sealed packs could come to the same conclusion.

    In those instances I would expect that the site had identified all pathogens that could be present in the environment (from location, staff, raw materials etc) and fully justified that the process and/or product properties was sufficient to fully remove the risk. I would say that simply having a very low risk is not good enough.

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