Setting up an Environmental Sampling Plan

1. Setting up an Environmental Sampling Plan BC Food Protection Association Burnaby, April 30, 2009 Kate Abraham Canadian Fishing Company

2. Elements of the Plan • Designation of a “Sanitary Zone” for RTE areas • Sanitation • Good Manufacturing Practices (GMP) • Training of Plant Personnel • Plant Environmental Monitoring & testing • Raw material controls • Minimizing growth in Finished Product

3. What is an Environmental Sampling Plan ? • Aggressive, targeted & systematic testing which results in information that enables you to react to any contamination • Half hearted, non targeted testing results in a lot of data but won’t provide reliable information about the environment • Needs to be Flexible • Needs to be specific to your plant and each type of product • Includes Training of personnel

4. Principles behind a sampling plan • If you don’t test you won’t find it • If you want to find it you have to look for it – and look for it aggressively • Environmental plan must be ongoing, since entry of Listeria cannot be prevented. • Know what you are going to do when you find it before you find it

5. KISS Keep it Simple, Stupid

6. I have six stalwart serving men They taught me all I knew; Their names are What and Where and When And How and Why and Who Rudyard Kipling

7. Initial Questions to ask yourself before you create a “Plan” • Why sample ? • What to sample for ? • Where to sample ? • When to sample ? • How to sample ? • Who will sample ? and who will evaluate the results ? Then question each and every detail Why?... Why?... Why?... The answers to these questions will be different for each plant & each product. Therefore sampling plans are plant and product specific.

9. Why are you sampling ? Cannot inspect Quality or Safety into a Product, so the worst reason to sample is merely to satisfy regulations or customers. Good Reasons: • To verify Clean up is effective • To verify GMPs are adequate and no cross contamination of equipment or services (e.g. water) is occurring • To give a measure of confidence that your product is safe • Verify entire spectrum of Lm control measures are working • Assess the need for additional pathogen control measures. • Provide historical data that the hurdle technology used in a plant is working

10. Hurdle Technology

11. What do you need to sample? Services • Processing liquids – water, brine, CIP rinse water • Ice • Air (incl. air conditioning, ducted air, heat exchanger drip trays) Plant Equipment • Tables and framework • Specific pieces of equipment • Fabric of plant –walls, floors Personnel • Gloves and hands

12. What are you testing for ? Use your HACCP Plan - This should indicate bacteria of concern Water and Ice • SPC • Total & Faecal Coliforms • Consider nitrates ..pH .. Metals .. Sanitation in High Risk & RTE areas • SPC • Listeria spp General Clean Up SPC / ATP / Protein residues ASK AN EXPERT…… Call the Lab ….

13. RTE Environmental Monitoring • Frequently the organism of concern is Listeria monocytogenes • Focus on non-pathogenic indicator such as Listeria spp - found more frequently than pathogens • Testing for spp gives more Positives and highlights niches. • Gives a heads up that things should be better and you need to react

14. What to do with the Results ? Detection of Listeria species does not necessarily indicate a microbiological control problem; it indicates the need for additional investigation.

15. Who is sampling & Who is Testing? • In house or outside laboratory personnel • Is there a local lab ? Can it do Lm ? (not all can) Is it accredited ? …Check SCC site • How fast can they get you the results? • In House – do they have any technical training ? or just good competent staff. • Clean up crew

16. Reality Check ! • Remote locations with no lab nearby • Only way in and out is by Boat or Plane

17. Reality Check ! Plant produces RTE fish products that are controlled by hurdle technology rather than a kill step (cold smoked salmon, caviar etc.) • Minimally educated crew – who may not speak much English • Short season with long hours • Water is from a bore-hole

18. How to sample ? • Depends on training of those taking samples • Facilities on hand to deal with samples • What you are sampling & why • How quickly you need the results back • Relative costs • Micro sampling • ATP sampling • Protein sampling

19. Protein detecting Swabs • Swabs detect protein residue • Give a clean / not clean result in 10 minutes (max) • If Its Green, Its Clean…

20. Flash Swabs

21. ATP Swabs Quick and Easy. Total Test Time ~ 45 Seconds

22. Millipore • Minimal training • Have a place in remote locations that need to test water

23. Swabbing large areas for Lm Eyeball & Swab a standard sized area e.g. 2 sq ft.Refrigerate and send to lab or process in house asap (same day)

24. Swabbing small areas or in nooks & crannies

25. Petrifilm Aerobic Plate (SPC) Listeria spp Plate

26. Get the answers to all these questions so you know what & why you are sampling and how • You know who will be taking the samples & whether you need to deal with them in-house (the only option in remote locations).

27. Setting up the sampling plan • Now you need to determine exactly where and when • Need to determine what to do with the results when you get them. • Need to know what your options are when the results come back positive • Need to set up a simple set of instructions • Need to think about feed-back both positive and negative to the crew

29. Where to sample ? • Look at your processing rooms and the equipment – observe the movement of people, product, utensils. • Make a list for each area • Look at equipment – moving parts, hard to clean parts, conveyor belts, rough welds, on/off switches • Look at drainage pattern especially if you have RTE and non-RTE areas • Look at overhead structures & pipes • Take photos.

30. Where to sample – Flow Map • Draw a map of plant and product route • Add on people routes • Add on drains and direction of flow • Add on temperature controlled areas • Add on sinks, footbaths • All looks grand till you superimpose another product being made at the same time whose path might cross.

32. Drain Plan Drains Equipment Sanitary zone

33. Zoning by Process Ready To Eat Final Product Work - In - Progress Raw Products General Areas

35. Zoning – by Equipment Product Contact Equipment Indirect contact equipment General Equipment Distant structures

36. Risk Analysis Matrix

37. Where to sample • Product contact surfaces should account for the bulk of testing. This may be in raw, W-I-P or finished area depending upon the product • Indirect contact surfaces also give valuable information – on/off switches, door handles, conveyors • Non contact surfaces may show where Lm is entering the area or where it is spreading from e.g. conveyor housings

38. When to sample ? • Check on clean up – after clean up and before processing • Water – at time of use • Drains - at end of shift (don’t want to disturb drain covers during production) • Product Contact surfaces & equipment that may harbour Lm… 1-2 hrs after start up so motion of equipment can dislodge niches. • End of Shift – will tell you what has come in during the day and its spread during processing

39. When to sample • Different areas will need different frequencies. • Initially sample at least weekly • Using all information you have collected draw up a schedule of what to sample, how, and frequency rate.

40. Finally you get the start of a “Plan”

43. Feedback • Show the results to the clean up crew • Post the results on a notice board – good and bad • Give praise where its due • Educate on an ongoing basis

44. Corrective actions should be pre-determined • Reaction will vary according to which “zone” the +ve results came from • Investigate – review clean up records, maintenance, line records, personnel e.g.– new hires • Re-test at heightened level to determine where niches may be • Intense Clean- disassemble equipment & conveyors etc. more than normal. Clean all racks used for packaging, utensils etc • Deep Clean – Tear down to Nuts and bolts level • Rotate sanitizers • Test Product

46. Longer term Actions • Review trends for the area- If the trend is going in the wrong direction – take action • Modify cleaning methods • Re-Training on GMPs • Redesign equipment

47. Product Testing • If final product has been tested, pre-determine the actions to be taken in the event that Lm is positive above CFIA acceptable levels. • All sampled lots should be held until the laboratory results are available. • When an effective control program for Lm is in place, the primary source of contamination is often a niche where the organism has become established and is multiplying.

48. Records • Ensure all corrective actions are very well documented • Corrective Actions need to be filed for Positive results on all RTE final product contact surface • Corrective Actions may be needed for non-contact surfaces – depending upon trends, product etc. • Positive on Drains – may just need to sign off on results or highlight in red so that it is obvious you have seen them and not ignored the result • Develop a trend graph, spreadsheet etc

49. Conclusion… • You know your plant and your product better than anyone … • You must design the plan.

50. Thank You