The FSMA Requirement: When a hazard analysis identifies an environmental pathogen (like Listeria monocytogenes or Salmonella) as requiring a preventive control, you must implement a risk-based environmental monitoring program to verify that your sanitation controls are effective.
Recommended Solution & Expert-Level Pitfall:
- The Solution: A modern EMP is a “seek and destroy” mission. Your program must be written, with a map of sampling zones (Zone 1: food-contact; Zone 2: near food-contact; Zone 3: in-process area; Zone 4: remote areas). It must specify frequency, the target organism, and a corrective action plan for any positive.
- The Pitfall to Avoid: Swabbing to “get a negative.” The purpose of an EMP is to find the organism. Common failures include:
- Not neutralizing: Failing to use a neutralizing broth in your swab for a post-sanitation sample will result in a false negative (the sanitizer on the surface kills the sample).
- Not seeking harborage: Only swabbing flat, easy-to-clean surfaces. You must aggressively swab difficult spots: hollow rollers, worn gaskets, floor-wall junctures, and inside drains.
- No “vector” swabbing: When you get a positive, you must swab in an expanding radius to find the source.