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
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:
- Review of the applicable hazards that the environment could impose on the product
- Risk assessment of the hazards identified
- Development of monitoring activities where a significant risk is highlighted
- Completion of the monitoring activities
- 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.
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.
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!