This article walks you through the steps of product inspection, testing and the environmental monitoring programme. The following information complies with:
|BRCGS Food Safety Issue 8||5.6 Product inspection and laboratory testing
9.3 Product inspection and laboratory testing (traded products)
4.11.8 Environmental monitoring
|BRCGS Packaging Issue 6||5.6 Product inspection, testing and measuring
7.3 Product inspection and laboratory testing (traded products)
4.8.5 Environmental monitoring
|BRCGS Agents & Brokers Issue 2||4.4 Product inspection and laboratory testing|
|Storage & Distribution Issue 4||10.3.6 Product inspection and analysis
12 Product inspection
9.1.2 Microbial growth risk assessment (environmental monitoring)
|FSSC22000 Version 5.1||2.5.7 Environmental monitoring|
|IFS Food Version 7||5.6.1 Testing plans, 5.6.6 organoleptic tests, 5.6.7 testing review|
|SQF Edition 9||126.96.36.199 Testing programme
2.4.8 Environmental monitoring
The areas covered in this article are:
- What’s an inspection and testing programme?
- What’s environmental monitoring?
- Does it apply to my product?
- Risk assessment
- Inspection and testing controls
- Testing schedule
- Sampling and testing
- Assessing results
- A common mistake
- Examples of hazards and controls
- Frequently asked questions
What’s an inspection and testing programme?
A programme is a set of activities, which all have one long-term aim. The aim of the inspection and testing programme is to ensure that the product supplied is safe, legal, authentic and the required quality.
The activities involved in the inspection and testing programme are:
- Defining the scope
- Establishing the hazards
- Carrying out the risk assessment
- Identifying the inspection and testing controls
- Developing a testing schedule
- Sampling and testing
- Assessing results
What’s environmental monitoring?
The aim of this section of the standard, is to make sure that the environment (as in the area or facility) that you process product in, is fit for purpose and doesn’t pose a risk of contamination to the product.
To make sure that the standard of the environment is right, you need to check it (monitor it) to make sure it’s OK. Typically, this would only be applicable in areas where the product is open and therefore – a risk of contamination.
Environmental monitoring has been added to all of the BRCGS Standards now. It’s even covered in the Agents & Brokers Standard, under the HACCP section.
This can be really confusing if you’re not actually producing food. But if you can understand what you’re ultimately trying to achieve, it can make it easier to understand how you apply this in your company.
The ultimate aim is to stop food from becoming contaminated with pathogenic bacteria and causing the consumer to get sick.
Let’s translate that aim, for each Standard:
Food (including FSSC22000 Version 5.1, IFS Food Version 7 and SQF Edition 9)
If you’re a food producer, then that’s fairly straight forward. Your environmental monitoring must ensure that the facility and the equipment that you use to make the product is hygienic.
If you’re a food contact packaging producer, then you have to make sure that the facility and the equipment you use to the make the packaging, is hygienic – so that when your customer puts food in it, it doesn’t contaminate that food. The main question here is whether pathogenic bacteria can survive on surfaces, like a piece of packaging for long enough to pose a risk. They certainly wouldn’t grow to unsafe numbers, as there’s no food source.
Storage and distribution
This only applies where you handle open product. So, crates of produce for example, which are exposed to the environment. This means the environment needs to be hygienic so that any airborne contamination doesn’t pose a risk.
Agents and brokers
Where your suppliers produce product for you, you must ensure that environmental controls are applied by your suppliers. This means you must carry out the assessment, so you know what your suppliers must do.
Does it apply to my product?
It may not no, but that doesn’t mean you don’t need a risk assessment. If you can justify why an inspection and testing programme (including environmental monitoring) doesn’t apply to you – then what you’re essentially doing in your head is a risk assessment. Write down your justification, as your basis of your risk assessment. You’ll need this to prove to an external auditor that you’ve considered the risks.
The auditor will want to challenge your risk assessment, if you’ve 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. Think very carefully about the result the risk assessment has given you, and make sure it contains enough justification and evidence as to why no monitoring is required.
Your inspection and testing programme must cover:
- Materials, including work in progress materials
- Finished product
- Own brand traded product
- The product handling environment (for environmental monitoring)
If you have product produced for you, because you’re an agent, broker or wholesaler, or you use another processor to produce the product for you, you still need to have an inspection and testing programme. The only difference is that the controls that you identify may not be applied by your company, as they may be carried out by your suppliers. This doesn’t however dissolve your responsibility, you’re still accountable for your suppliers performing these controls for you.
It’s common to presume that the hazards you’re looking at when developing an inspection and testing programme are just microbiological. But they do also in fact cover:
Nutritional verification is an aspect that’s often forgotten. Your programme needs to verify that nutritional claims are being met and also the nutritional on pack is also in compliance.
When thinking about microbiological hazards, don’t just think about pathogenic risks. Spoilage organisms are important too – if your product is prone to these. If your product supports mould growth for example, this must be one of the hazards you identify for inspection testing and also environmental monitoring.
Look at your products and environment, to establish which hazards are a risk and list them down. Try to write your hazards into a definition, which includes:
- What the hazard is
- How it got there
For example – Staphylococcus aureus contamination of the finished product, due to inadequate hand washing by product handlers.
By making yourself write down the reason that the product got contaminated, it will force you to be realistic about the hazards you identify. That way you’ll end up with a really focused list.
The hazards you should consider all depends on what product you’re handling. Think about what the product is susceptible to. Looking at complaints as these are a good indicator for this. For bread production or cheese cutting, mould complaints may be an issue. The mould comes from the production environment before the product is packed, so this would be a risk you would add to your risk assessment.
Don’t ever add hazards, just because you feel like you need to write something down. If there really isn’t any, that’s fine – just write something like ‘no applicable hazards.’
Using your customer specifications and codes of practice is important when identifying what hazards you need to include. What you’ve said you will adhere to, in the micro section of the customer spec is the minimum amount of testing that you should be doing.
The next step is to create a risk assessment to assess each hazard, which has been identified. Where risk assessments have already been completed for materials and finished products, the results of these should also be included, such as:
- Material risk assessments which have identified routine testing and inspection that’s required.
- Vulnerability assessment which may have identified material or product testing, as protection measures for fraud.
The risk assessment must consider the severity of the hazard and the likelihood of it occurring.
Every risk assessment needs inputs. Here these inputs should be facts about the likelihood of the hazards being present in the product. Use your previous test results to help you determine the likelihood and add this justification (in writing) to your risk assessment. We always recommend having a column on every risk assessment for likelihood justification, where you can write why you came to the likelihood rating that you’ve given.
The output of the risk assessment is to define:
- Which hazards are significant and therefore need controls in the form of testing or inspection.
- The frequency of such controls based on the significance of risk.
For frequency, if there’s a high risk of the test results being out of spec, then you may want to test every batch. If there is less risk, you may just carry out routine testing, so you can see whether the controls that you’ve put in place are working.
When setting frequencies, remember that it doesn’t need to be at this frequency forever. A risk assessment must never be done once and then left – it’s an ongoing and developing piece of work. If the results of your testing come back and the results are always in spec, then you can look to reduce the frequency of testing. If, however, the results come back and are regularly out of spec, then this identifies an issue which needs action. And part of that action, should be to increase testing while actions are taking place to improve the test results.
Inspection and testing controls
Where a significant risk is identified, the risk assessment must apply controls with a suitable frequency based on risk. The next step is to establish what testing methods should be used and the acceptable limits for results.
Acceptable limits sounds complicated, but it’s just the target, accept and reject criteria you use to determine if something is within or out-of-spec.
You should use your customer specifications or codes of practice when determining what your acceptable limits should be.
If you don’t have any references such as customer specs to go to, then think about what level of contamination would cause the product to be unsafe or cause a complaint. This is then your reject (red) specification level. Then work back from that, to what warning level you want to work to. This would be a level which would not make the product unsafe or cause a complaint but would indicate that something’s gone wrong. This allows you to do something about it before it causes the product to become unsafe or create a complaint (and hit your reject level). Then, under your warning level is your target.
For environmental monitoring you may also need to do some work to establish what a ‘clean’ environment looks like, in order to decide what you want to achieve. This may require testing over a period of time, comparing this to the levels of complaints you get or finished product test results – to work out what’s acceptable and what’s not.
There are also EU regs for micro limits in food, which can also be used: COMMISSION REGULATION (EC) No 2073/2005of 15 November 2005on microbiological criteria for foodstuffs
The required tests at the right frequency must then be put into a testing schedule. This ensures that the tests are planned in advance, so that they’re not forgotten. Where tests are less frequent, it’s a good idea to set up some sort of reminder system. It’s easy to remember tests that are done every day, week, month etc. But if they’re done once every six weeks for example, or once every infrequent delivery then that’s more difficult for those who are sampling to remember.
Sampling and testing
Sampling must be carried out consistently, otherwise the results may be invalid, or it won’t be possible to compare and trend them.
Once the sampling is done, it’s not over. The results are the most important part, and this is a common area for non-conformances. Make sure that you assess the results when they come in. Have some sort of system for making sure you can cross-check that results have come in, compared to what was sent for testing.
When they arrive, even if they’re in spec, you need to prove that you’ve looked at them and checked them. This means a physical date and signature on the lab report, or some other digital way of doing it.
When results are received, you must be able to understand what they mean. This is so that you can apply the right corrective and preventive action to stop it happening again in the future. If you don’t know what the results mean, you won’t be able to correct the problem.
To be able to apply the right action you need to:
- Understand the results.
- Have a good understanding of the hazard.
For example: Let’s say you’ve tested a finished product for Bacillus cereus and the results come back as 150cfu/g.
The acceptable limit (spec) is 100cfu/g or less.
The results are out of spec and therefore need action. This means you need to know enough about the hazard (Bacillus cereus) to know where it’s likely to have contaminated the product and where in the process it would’ve had the capacity to grow. Being able to pinpoint this type of information, will enable you to be able to implement really focused action to remove the issue.
There must be corrective action procedures in place, for when results are out of spec.
The last part is to then review the inspection and testing programme as a whole, including the environmental monitoring, to make sure it’s working.
The BRCGS standard is really clear about when this should happen:
You need to do it annually as a minimum, but you also need to do it when:
- Something in the environment changes (such as equipment, structure or layout).
- New testing methods are launched or test accuracy is improved.
- Any product testing fails, but this isn’t reflected in the environmental monitoring results.
- Any product testing is within spec, but a third-party test result is out-of-spec.
- If you’re constantly getting within specification results.
The last three points are really clever, because it reiterates the whole purpose of why we’re doing the testing in the first place. If the product isn’t right and this isn’t shown in the environmental monitoring, then that means the environmental monitoring isn’t working. And if your product testing is fine but a customer or the local authority tests your product and finds it’s not, then again – your system isn’t working.
Getting consistently within spec results sounds great, but it’s not so great if the complaints highlight that they’re not right. If we go back to our bread and mould example, if you’re constantly getting within spec mould results, but you’ve got a lot of mould complaints – somethings not right!
A common mistake
One common mistake is that when an out-of-spec result is received, the only action taken is to re-sample and carry out the testing again. This is one action that can be taken, but it shouldn’t be the only one. The fact that an out-of-spec result was received, can’t be corrected by getting another within spec result.
The problem that caused the first out-of-spec result is still there, even if you get a second within spec result. Corrective action must be taken as a minimum, as you shouldn’t get any out-of-spec results, if you’ve set your limits correctly. The fact that you did, means that there’s a problem you need to find.
If the 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.
Examples of hazards and controls
As mould is airborne, it’s essential to keep the environment clean. When mould growth occurs in the factory environment, this acts as a source and spreads the mould spores around the factory.
Keeping environments like bakeries clean to this degree is a challenge, especially when you consider the dusty environment and the probability that there’ll be mould spores in the flour that’s used. Combine this, with the heat from the ovens and the cold air during the winter months or at night, and you get the right conditions for condensation, and so, mould growth.
Once mould starts to grow on surfaces such as walls, it releases the spores into the factory environment, which can then land on food contact surfaces and the food itself. If those spores land on food contact surfaces, or food, such as bread – post the baking process, the food will pick them up and given the right conditions, this will cause mould problems.
Because of the way that mould spreads, cleaning of contaminated areas can actually make the problem worse in the short term, as disturbing the mould, increases the number of spores released into the environment.
Although disinfectants are not typically used within ambient bakery environments, they do have their uses when it comes to mould control. Spraying surfaces which have mould growth with a disinfectant designed to combat mould, helps to dampen down the area and prevent the mould spores being released when the cleaning process is actually completed.
Disturbing physical structures in the factory, can also increase the amount of mould spores released into the environment. Structures such as mezzanine floors may over the years have ‘absorbed’ a level of mould spores and when these structures are disturbed or removed, this can release the mould into the air.
Because mould growth in food is strongly linked to temperature and therefore, the time of the year – it’s advisable to schedule high level cleaning or changes in structures to the colder months of the year, to try to reduce the impact on the mould complaints.
Where products produced in the factory are susceptible to mould growth, it’s advisable to have monitoring techniques in place, as an early warning system to mould complaints.
This could be the in form of:
- End of shelf life assessment
- Environmental air plates
- Compressed air testing
End of shelf life assessment
To establish what level of mould that’s on the product, you could carry out mould testing. However, it’s very difficult to establish what level of mould is acceptable and what isn’t – in order to define the specification for testing.
Most moulds cause quality complaints (mould complaints). The majority of mould issues don’t put the safety of the product at risk unless mycotoxins are involved. This means that the level of mould on the product, only becomes unacceptable where the quality of the product is affected.
Therefore, it is good idea to monitor the quality of the product, for mould. This may be for visual signs of mould, or for particular smells which are associated with a specific type of mould.
In order for these product assessments to be an ‘early warning’ system, you need to make it easier for the mould to grow – by giving it the right conditions. A nice warm room works well – this way, when you see the mould appearing as a problem, you have some time to find the source of the problem and fix it, before it starts to impact on your quality complaints.
Where the mould grows on your product should also give you clues as to where to find the source of the problem. For example, if it’s growing on the base, look for contact points such as conveyors where the base touches. If it’s just on the sides, look for side contact equipment, such as guide rails or pusher bars.
Environmental air plates
Air plates are a great way of establishing whether you have a problem. They should be placed around the factory, in locations where mould would be an issue.
For example, in a bakery, this would be from the cooler down to where the product is packed, because prior to the cooler air plates – it wouldn’t really add value. Because you’d expect air plates in a mixing area to have an increased level of mould, because the flour dust would probably cause this. Also, if the product was contaminated with mould, prior to baking, the baking process would eliminate it.
In order to establish if you have a problem, when reading the results from the air plates, it’s important to know what a ‘normal’ level of mould looks like. To do this, results would need to be taken over a period of time and then reviewed, to establish what the acceptable range should be. You’d do this by comparing your results from your complaints and your end of life assessments, with the air plate results. Where the complaints are end of life assessment results are good, then the air plate results are acceptable. It would be advisable to do this assessment in the warmer weather, as this is when you’re more likely to get a problem.
Once you have your base level which is acceptable, routine air plate results can be compared to this. Where there are spikes, this should highlight to you that you have a problem. This should generate an investigation, where you look for the source of the mould. Where the source cannot be found, further air plates can be used as part of the investigation, to try to pinpoint where in the factory the source is.
Compressed air testing
Another important monitoring technique is to make sure that any compressed air that comes into contact with the product – post baking, so where the product is at risk from contamination, this is checked for mould.
This can be done by spraying an air plate (petri dish) with the compressed air and sending it for testing.
Other control examples
Here’s a list of other inspecting and testing controls for the product and for the environment, to help you understand what an external auditor will be looking for.
- Nutritional analysis
- Pathogenic testing
- Organoleptic taste panels
- Shelf life assessments at end of life
- TVC or ATP swabs of equipment to establish general hygiene.
- Staphylococcus aureus swabs on staff hands to establish handwashing standards.
- Water test results
- Listeria swabs of equipment and susceptible areas
Frequently asked questions
What is environmental monitoring?
In the food industry, the aim of environmental monitoring is to make sure that the environment (as in the area or facility) that you process product in, is fit for purpose and doesn’t pose a risk of contamination to the product.
Does environmental monitoring apply to my product?
It all depends if your product is at risk of contamination and if your product can support pathogenic growth. If it doesn’t, you still need to justify this through risk assessment.
Get the maximum benefit from your testing budget!
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