Many segments of the dairy processing industry see increased pressure to develop and implement effective Environmental Pathogen Monitoring Programs in their processing facilities. These programs are essential to reduce the risk of post-processing contamination with pathogens. Key pathogens that may be targeted by Environmental Pathogen Monitoring Programs are Listeria monocytogenes, Salmonella, and Cronobacter. While recent FDA visits to dairy and cheese processors seem to focus on FDA collecting samples that are tested for Salmonella and Cronobacter, any dairy processors needs to consider testing for all three pathogens and needs to use a risk-based approach to determine which of these pathogens need to be targeted in a facility’s Environmental Pathogen Monitoring Programs. In general, Listeria monocytogenes likely needs to be included in the Environmental Pathogen Monitoring Programs of most dairy processing plants (this can be done through Listeria spp. or L. monocytogenes testing). Salmonella also is a hazard that needs to be considered in most dairy plants. While many dairy processing facilities may collect fewer environmental samples for Salmonella testing than for Listeria testing, facilities that produce certain products and in particularly low water activity products (for example dairy powders) may collect larger numbers of samples for Salmonella testing. Facilities that produce dairy powders intended for infant formula also will need to address Cronobacter as part of their Environmental Pathogen Monitoring Programs.
Importantly, any guidance provided on Environmental Pathogen Monitoring Programs, including the guidance detailed in the preceding paragraph can only be that – guidance. Environmental Pathogen Monitoring Programs and associated environmental sampling plans need to be individually developed for each facility, considering various aspects, including age of the facility, types of products produced and likely and intended product use, prior environmental sampling data, etc.
Importantly, every facility that performs environmental sampling for pathogens or index organisms must have written procedures for corrections that are performed if a sample tests positive for one of the target organisms. Facilities also need to have well developed and explicit procedures for record keeping and must assure that written records of corrections are always linked to any record of a positive test; this is essential in case of any audit (regulatory, 3rd party, etc.).
The Dairy Foods Extension Program at Cornell also has resources available to help dairy plants with the development and implementation of Environmental Pathogen Monitoring Programs. We have a hands-on workshop on Environmental Pathogen Monitoring Programs and the development of environmental sampling plans, which we are willing to offer in 2015 if a sufficient number of companies and individuals are interested. If you are interested in sending individuals to this workshop, please contact Louise Felker. We also are available to do plant visits with a team to review sampling programs and records. We specifically can serve as an independent party that collects environmental samples in a facility to independently validate existing environmental sampling plans. If you are interested in any of these services please contact Martin Wiedmann.
Here are some links to other environmental sampling related resources that may be useful:
For guidance where FDA likely will collect samples: see http://www.fda.gov/downloads/iceci/inspections/iom/ucm252109.pdf
For a Dairy Pathogen Control Program Assessment that includes a section on environmental monitoring with some very explicit guidance; see http://www.commercialfoodsanitation.com/wp-content/uploads/2011/07/Dairy-Pathogen-Control-Program-Assessment.xls
Note: Neither Cornell nor the Dairy Foods Extension team provide any guarantees as to the accuracy of the content of the materials provided here. These entities also do not provide any guarantees that following these guidelines will fulfill regulatory or other requirements.
