Monitoring: Seek and Destroy
Components of an effective
Whether you are just setting up your environmental Listeria monitoring pro- gram or reassessing your existing pro- gram, there are basic elements that you will want to include. A general overview of these elements is provided below. In addition to
these elements, an effective environmental Listeria monitoring program must have expressed commitment from
the senior management or executives within the company. “For food safety to succeed in an organization, the
most important element is management commitment,”
notes a previous article in Food Safety Magazine.1 This
can be true for Hazard Analysis and Critical Control
Points (HACCP) and prerequisite programs such as
Good Manufacturing Practices (GMPs), allergen management and environmental monitoring. Consequently,
it is important that as you develop your environmental
monitoring program, you ensure that senior management and executives are educated as to why the program
is necessary, how it will be implemented and what will
be done with the data that are generated.
Rationale for Environmental Monitoring
It is commonly stated that before you do any type
of testing, you should ask, “Why are we conducting the
testing and what will we do with the results?” This is a
good maxim to apply with regard to environmental test-
ing because gathering data that point
to a potential problem but not having
a plan to address it can result in regula-
tory control actions. For example, if you
are collecting environmental Listeria
swabs in a raw environment during op-
erations and receive positive results, you
will be expected to take actions to elimi-
nate the positive results, which, in a raw
environment, may be quite challenging.
So, when you ask yourself why you
are conducting environmental monitoring, the likelihood is that you are doing
so for the following reasons:
• You are seeking to identify the sources of entry, harborage and translocation of Listeria in the plant.
• The locations where you will swab
are those areas where finished product could be exposed and susceptible
• When you find those sources, you
will conduct an investigation as to
how the organism established itself
in the locations where it was found.
• Once it’s found, you will destroy the
organism and eliminate the sources
of entry, movement and harborage.
In addition, you will include as part
of your rationale that you are conforming to the requirements of the appropriate regulatory agency or agencies. Plants
operating under U.S. Department of Agriculture (USDA) jurisdiction and making ready-to-eat (RTE) meat and poultry
products already are required to have
programs conforming to the requirements of 9 C.F.R. 430.4 — “Control of
Listeria monocytogenes in post-lethality exposed ready-to-eat products.” These regulations were issued in 2003 and outline
the agency requirements for verification
that RTE meat and poultry products are
not adulterated by Listeria monocytogenes
(Lm). In addition, this year, the U.S.
Food and Drug Administration has proposed rules for environmental Listeria
monitoring in plants that produce RTE
products that fall under its jurisdiction.
By Michael Cramer, CQA