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Environmental Monitoring
18 Plays4 years ago
Environmental Monitoring is the process of testing surfaces inside a pack house or post-harvest area. In this episode, Scott Wall with New Age Laboratories and Jordan DeVries, a Produce Safety Technician with Newaygo Conservation District, discuss why you may want to implement an environmental monitoring program on your farm.
Funding for this podcast was made possible in part by the Food and Drug Administration through grant PAR-16-137. The views expressed in the posted materials do not necessarily reflect the official policies of the Department of Health and Human Services, nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
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Transcript
Introduction to Produce Safety
00:00:01
Speaker
Hello and welcome to the Agri-Food Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule. In this episode, we'll be discussing environmental monitoring, which is a process of testing surfaces inside a packhouse or post-harvest area. Surfaces are tested for bacteria or indicators of potential contamination to determine if the practices used in the packhouse ensure a clean and sanitary product.
00:00:31
Speaker
It's important to note that environmental monitoring programs are not required to be compliant with the FSMA Produce
Why Implement Environmental Monitoring?
00:00:48
Speaker
So we're here to talk about environmental monitoring, Scott. Your laboratory here does quite a bit of that, as I understand. And we're trying to just break down the science here for growers, help them understand why they would want to implement an environmental monitoring program or understand why their buyers might be doing some environmental monitoring.
00:01:01
Speaker
Safety Rule.
00:01:09
Speaker
Oh, okay. Well, you know, it's, I think the biggest push is that, you know, FSMA is coming online and GAP and Primus audits are putting more point deductions behind the whole EM. So that's, I think that's what pushes people towards it. That's not necessarily whether they should be considering it. For my growers and my producers that I'm working with, what I'd like to point out to them is that it's a risk mitigation for them.
00:01:39
Speaker
You know, they've invested a lot of money and a lot of time in building their brand and they've got their entire life savings, their family's reputations behind, you know,
00:01:52
Speaker
the name of their farm, the name of their business. And to put at risk that goodwill, because they don't have environmental monitoring plans to potentially mitigate risk, to find out if they've got some source of microbial contamination in their processing facility just doesn't make sense nowadays.
00:02:15
Speaker
Okay, so it's kind of about identifying that source, that reservoir of microbial risk and trying to develop a strategy for addressing that on the farm. Does it help any with their audits? I know that it's not a requirement for a FSMA produce safety rule inspection, but when it comes to an audit, how does an environmental monitoring program support the work that they're doing with their GAPS program?
Supporting GAP Audits with Monitoring
00:02:39
Speaker
Well, I think, yeah, under the Primus audits, they are really looking at whether or not some of the farms have and the packing facilities have environmental monitoring programs in place. There's some need to have the ATP in place, but keep in mind that ATP really validates your cleaning procedures. It doesn't validate your sanitation procedures.
00:03:03
Speaker
So the EMP or your environmental monitoring swabs and things like that, that's going to validate the cleaning and the sanitation. So there's the difference between the two. The ATP is very quick. You're going to do that on farm. It's a readily received number right back to you to say, hey, we've done a good job. The EMP is a little bit more in depth. It's going to tell us what kind of microbial risk do we have. Oh, absolutely. OK.
00:03:33
Speaker
So when we're looking at that, what's a sampling plan for an environmental monitoring program for your basic produce farm with a small pack shed?
Sampling Plans and Zones
00:03:43
Speaker
How is that going to be different than in a larger produce processing facility?
00:03:48
Speaker
Well, what we typically do is we look at where their season's gonna start. And we try to say, okay, get the facility set up, get it cleaned and sanitized, and then let's come in and do a baseline assessment. So in those types of situations, depending on how many lines they're gonna run, that'll dictate how many swabs we're gonna come in and do before any produce comes through that facility.
00:04:12
Speaker
because we want to get a feel of whether or not the lines and the buildings are clean to begin with. Because if we've got a hotspot that's already pre-existing, we need to get that addressed before produce starts coming through. Then we get that assessed, and then once produce is coming in, we'll cut it back to five samples a week, 10 samples a week, depending on how many lines there are. Typically, we try to set it at about five swabs per line.
00:04:38
Speaker
And that runs through the processing season. And those will be divided up between typically zone two, zone threes, and zone fours. We stay away from zone ones because with fresh produce, we're not in a hold and release situation. Produce is coming in, processed, and going right back out. So we're trying to stay away from situations where we're going to be faced with a recall. But we do want to be able to have corrective actions
00:05:08
Speaker
if we find sanitation issues that we need to address. Oh, absolutely.
Risks from Water and Condensation
00:05:13
Speaker
Let's talk about water in an environmental monitoring program and how we're addressing the movement of water within a facility and how that helps and sometimes makes your work more difficult.
00:05:26
Speaker
So when you're talking about water, are you talking about fugitive water? Fugitive water, yeah. Let's talk about puddles and things like that in the facilities. Fugitive water is the biggest
00:05:43
Speaker
red flag, if you're an auditor, if you're an inspector, if you're looking for problems, you look for you look for a fusion of water because those are little pools of bacteria. You know, when we talk about how life formed on the globe, we talk about bacteria in water. So when we have puddles on the floor, that's a place to look for bacteria. If we have condensation,
00:06:12
Speaker
Condensation over produce is a problem. That becomes a zone one, because if there's condensation directly over where you got food, that is a source of contamination that can directly get on a food source. That has to be remediated. We have to take care of those types of things. So, yeah, fugitive water is a big issue.
00:06:34
Speaker
Absolutely. So in areas where we may have some condensation, are you in a ceiling or overhead pipes or things like that? Are those areas to test in an environmental monitoring program? Well, here's your problem. That's a zone one. If it's directly over the produce, it's a zone one. So if that pipe is in a place where it's not directly over the produce, test there. Don't do the swab directly over the produce because if you take it directly over the produce,
00:07:01
Speaker
Now you've got a zone one versus where it could be considered a zone two. Get a feel for it. But if you've got condensation where it's directly over the produce, remediate the situation. Put a catch pan, put a diverter on there, just change the course. Eliminate that and then deal with, okay, what is the potential source of contamination? But anything that overhangs food, lights, let's say you've got a conveyor that goes through a tunnel.
00:07:31
Speaker
Those surfaces, once it goes into that tunnel, that surface inside that tunnel, that overhead, that's a zone one. People don't think about that. We think, oh, that's a zone two because it's adjacent to, but it's not because the potential of that surface, anything can fall onto the food and vegetables. Those are issues that we have to take advantage of.
00:07:53
Speaker
Avoiding, you know, we run into some of those.
Avoiding Common Mistakes
00:07:56
Speaker
Sometimes we get in teaching environmental monitoring, a lot of the growers will want to do the sampling themselves. It saves them some money versus us going out and doing the sampling for them. And that's great.
00:08:10
Speaker
biggest mistake they jump in and sometimes they they they swab a zone one see yeah so that can you know even a ceiling or a pipe or something like that if it's dripping down those can be zone ones inadvertently where they're not i've seen them go right in and do brushes you know you know brush on an apple line or tomato line or something like that and it's like
00:08:30
Speaker
okay now you've got a hit of EB or something like that it's like okay now what how are you going to address that because now you've you've kind of stepped into it and if you've got produce that's come across there we've got to address that now you've got to take figure out how how do you want to address potential risk that you've presented
00:08:51
Speaker
to an auditor or a gap inspector, that type of thing about, okay, is it a risk? Is it not a risk? What did you do to do corrective action?
00:09:02
Speaker
So now you've got to kind of take that piece of equipment apart, pull it, you know, really clean it up and we're going to have to go back in and do another swab to prove that you remediated that problem. And was it really a pathogen or is it just an indicator? So there's, it kind of opens up Pandora's box and you have to really be careful with that.
00:09:23
Speaker
So it's good to hire a laboratory trained consultant to do your swabbing plan and set that up. And maybe in subsequent sample efforts, they can teach you where they want those swab locations to be. You might consider that a biased sample, but it's good to know where your zones two and three are that you want sampled. But that first time around, it's really good to have a professional come in and swab them.
00:09:47
Speaker
Oh, absolutely. Work with your consultant. Work with somebody who's done it.
00:09:54
Speaker
number of times because there's a couple other issues that you want to start thinking about bias sampling.
Microbial Hazard Analysis
00:10:03
Speaker
Don't just go and swab nice flat open surfaces. We want to find the places where you call them sandwich locations where two pieces of material types of material come together or you've got a nut and bolt or something where you can't clean in between those or a crack in the concrete because
00:10:24
Speaker
Those little places, that's where bacteria finds locations to hide, to grow. Those are the harborage points we talk about. So the bacteria finds that as a harbor, a safe place.
00:10:41
Speaker
It's not a coincidence why we call it harborage points. We all live along Lake Michigan here. We know what it is to get off of the lake and into a harbor when it gets rough out there. That's exactly what the bacteria is doing. It's finding a safe place where you can't get at it and then it grows and multiplies.
00:11:00
Speaker
Great. So let's bring that together and talk about what is a microbial hazard analysis. That's kind of an industry term. You know, you hear it floated out there, especially for those farms that have to comply with the preventative controls rule for human food. It's another FSMA rule. But how is a microbial hazard analysis different on a farm?
00:11:22
Speaker
I think it's terminology, really, to tell you the truth. We're basically going onto the farms and saying, let's assess what the potential risks on the farm or in the packing facilities are that could contribute microbial risk to the product and to the end produce going off the facility.
00:11:42
Speaker
So it's a critical assessment that should be done with a team. So you want to bring in to that team individuals from all the different sectors of the production. And so the bigger the facility, you'll have more people involved. The smaller the farm, you'll have less people involved. But you want to look at, OK, what's going on in the field? So you take into account ag water.
00:12:05
Speaker
You want to take into account wildlife intrusion. You want to take into account, are you mechanical harvesting? Are you hand picking? And what is your training on hand picking? And do you have proper hygiene training? So all these different sections, you start assessing them. And what is the risk and the vulnerability to the produce
00:12:32
Speaker
for microbial contamination by those different sectors all the way through your operation. Right now, I'm really involved in assessing risk and quantifying risk. So if you can go through that process and give each one of those categories a scaled value of one to five, say, and the higher the risk, you give a higher number, well, then you can then prioritize
00:12:58
Speaker
What is the, you know, which areas you need to invest more time into earlier and say okay well my training program just isn't up to snuff or I've got a real problem with cross traffic patterns in my packing facility because my
00:13:14
Speaker
all of my forklift traffic from my loading dock crosses exactly the same pattern that my employees go from the break room into the processing room. And so now we've got a cross-contamination because we've got raw product and finished product.
00:13:33
Speaker
traffic patterns crossing. And that means we've got a risk of something that's already clean being re-contaminated with raw product. And those are things that we don't always see. And that's something that an environmental monitoring plan will tell us, okay, yeah, you saw it in the assessment, now let's validate and see if what we saw is true.
00:13:55
Speaker
So using those testing procedures and our swabs and things like that to, we think where we're having a problem might be in our heads by just doing a visual assessment. We're then backing it up with some real scientific data and saying, yes, this is actually a problem. And in some cases, no, actually that practice is working just fine. Oh yeah. You know, the number of times, you know, I think a lot of times people think, oh, here's, my problem's going to be over here. The number of.
00:14:24
Speaker
facilities we've gone to and probably the most contaminated source in the facility is the the break room picnic table, you know, it'll have astronomic levels of E. coli or anterobacteriaceae on the picnic table because nobody's nobody's thinking about those little cracks and crevices on there. But all of our workers are eating there and then going back out to the processing room. Sure. So it's in that zone four.
00:14:51
Speaker
Yeah, you know, that's that's something way away from where we're supposed to be doing the processing But it's a source that we can then take back into the process
Advice for Small Farms
00:15:00
Speaker
area. Okay So one of the things on my mind and think about this with other guys There's obviously a cost to this and it can range from just a few couple dollars a month You know and adding this into really going, you know gangbusters and spending a lot of money on all this and
00:15:17
Speaker
It sounds like you are adding some value there to growers and helping them identify where those problem areas are. So what's the value proposition for environmental monitoring on small to medium sized farms?
00:15:29
Speaker
That's a really good question. We debate this all the time. When I say we, myself and others at MSU, I'm one class away from having my master's in food safety. I always bring the small processor's viewpoint.
00:15:52
Speaker
to discussions because most of my classmates and professors deal with big operations and I'm bringing the small operator. And FISMA really focuses on big, but there's a cost paid by the small operators too. There's a financial burden paid by the small operator. How do they incur these things?
00:16:20
Speaker
And we have to look at it and say, what can we start with? Don't start with a Taj Mahal. You're always going to be apprehensive. They're always going to say, I can't afford it. I can't afford to add anything. Our margins are tight. You can't
00:16:39
Speaker
You can't afford to not do it, so you have to do something. Start. Start with at least getting a baseline. Figure out where your issues might be. Get your risk assessment done, right? Figure out what could be issues. Make sure that the programs you have in place make sense, that they're not just SOPs in a book that you don't follow. We were talking about that earlier.
00:17:04
Speaker
do a baseline, do a couple swabs a week, or a couple swabs every two weeks. It'll be your first season, but get a season under your belt, start doing something. Then maybe if you don't break the bank, you start next year. Maybe you learn a little bit of something and we build onto it. And eventually you'll have a full-fledged program that you worked into. And I think that's,
00:17:32
Speaker
That's the course that I would recommend. Don't try to eat the elephant all in one bite. Do it in steps because you'll get credit for doing something and you can always improve upon it. You know, FSMA is ISO based and ISO says, tell me what you're gonna do. Do what you said you were gonna do, document it, then review it and improve upon it.
00:18:00
Speaker
So let's start, let's start somewhere and then build, build off of it.
00:18:05
Speaker
Yeah, I think in a lot of cases, you know, growers, we're out there doing these risk assessments on either on-farm readiness reviews or produce safety risk assessments with conservation district technicians. And, you know, we're thinking theoretically about what these problems are based on experience on other farms and what is in the produce safety role. We don't actually know if they're risk. We can't see these microbes any better than the farmer can.
00:18:31
Speaker
So going through an environmental monitoring program and actually knowing what those risks may be, having that raw data is going to be something really useful. Like you mentioned in prioritizing, you know, what are the value of each of these risks that I have? And let's take out those big ones first before we need to move through the smaller ones and eventually get down to that, you know, 99 percent risk free farm. Right. Right. Exactly. You know, and make sure that it's
00:19:01
Speaker
Build a program that is actually doing something. Don't put something in place that's just there to try and fool an auditor. Don't collect a set of samples two weeks before the audit so that you can put a piece of paper in front of the auditor. Because then all you're doing it for is simply for the audit points and you're not,
00:19:26
Speaker
You're not safeguarding anything. You're not safeguarding yourself, and you're not safeguarding the public health.
Legal Benefits of Monitoring
00:19:36
Speaker
I know how hard it is to make a living in farming, and the obligations on us are higher and higher every year.
00:19:48
Speaker
And the number of my friends and my growers and packers who have said, you know, we've never made anybody sick. And I see more food safety problems in a grocery store than I've ever done on my own farm. I get it. I understand all of that. But what they have to understand is that as inspections come on board and if some
00:20:13
Speaker
indication of filth or unsanitary condition exists on your farm and that leads to a swabbing and that swab comes up positive and that positive is then genome sequenced and that goes into this into the database and that links that positive to a genomic illness
00:20:35
Speaker
As many years back as 10, 12 years, we've got over 10 million unsolved deaths and illnesses in our genome sequence database right now. You may find out that you've made somebody sick or died from something that's resident on your farm that you never knew existed.
00:20:53
Speaker
it would behoove us to, if they can come back and say, yeah, but I've got a program in place, I'm working on it, then you've legally, you have worked to show that you're at it. But if you, all you've done is made a paper mache program, you're at huge risk. You're just, you're putting your family and all your employees at risk. So I say,
00:21:20
Speaker
I understand it, but if you're going to stay in agriculture, this is the game and this is how it's going to be played and I don't think we've got a choice.
00:21:31
Speaker
If we're going through this conceptually here and a farm has conducted an environmental monitoring program, sent the results to a lab like yours, you come back and we did have a hit on a secondary or third level zone on the farm.
Responding to Contamination
00:21:51
Speaker
What's the next step? Where are we trying to point the farm to now?
00:21:55
Speaker
Well, first, don't panic because we want to find them. So if you get a positive hit on a zone two, zone three, zone four, the first thing to do is go to your program, figure out what your corrective action procedure is. So we want to go back to that location. We want to resanitize it.
00:22:19
Speaker
We want to clean it, sanitize it, re-swap it. We also want to assess all of our procedures around that area.
00:22:28
Speaker
to determine why is it not up to our sanitation and cleanliness criteria? Are we not cleaning it the way we said we were, or did somebody not do their job? Sometimes we find out people just aren't doing it, or somebody turned back the sanitation levels. Well, it smelled like chlorine in the facility, so we dialed back the chlorine in the flume.
Root Cause Analysis Explained
00:22:55
Speaker
did you mark that down and now all of a sudden we have higher levels, you know, someplace. I think those are the types of things you have to kind of investigate and corrective actions mean root cause analysis. That is a really nebulous term. Nobody explains ever what root cause analysis really is, you know, and probably we have to use it here in the laboratory because we have undergo audits too.
00:23:20
Speaker
The easiest way for me to explain it is ask why five times. Why is it this? Okay, well, it's this way because of that. Well, why is it that way? And then if you keep asking why at least five times, you should come down to a root cause analysis. Is it that way because we didn't have money to spend on it? Or is it that way because we didn't have enough people to do something that day? Is it that way because the person wasn't trained properly?
00:23:50
Speaker
I mean, this is what you want to get down to, and then the corrective action will come out of what your answers were in that root cause analysis. Excellent. So it ends up being something for the farm to follow. Absolutely. Yeah. A nice template there. Because if all you're doing is doing swabs to find dirties to reclaim it,
00:24:12
Speaker
then you're treating the symptom, not the cause. And the whole purpose of this is to create preventative measures so that you reduce your risk, not just clean it up. And because if you don't change your practices, if you don't change the way you do things, then you're not reducing your risk.
00:24:35
Speaker
Sure. So a question I often ask growers in discussing this is, are you willing to make changes based on the evidence that's presented? Because in some cases, if they're not going to change it anyway and they just really want to know, you know, can I clean that better? Can I clean that service better? The Environmental Monitoring Program is not
00:24:56
Speaker
achieving what it's set out to achieve at least on paper. How do you discuss with growers that they may want to look at changing both product flow and handling patterns and maybe even upgrading to some more hygienic equipment?
Cost-Effective Sanitation Solutions
00:25:11
Speaker
Return on investment. That's the easiest way to explain it to them because if you're not willing to make changes
00:25:18
Speaker
then very likely what they're going to end up doing is just throwing more money at what they perceive to be the issue. So they'll throw more money at sanitizer. They'll throw more labor at cleaning something.
00:25:34
Speaker
but the answer isn't more, it's about doing something smarter. It's, oh, well, if we just had two pallet jacks, and that pallet jack only goes from here to there, and this pallet jack picks up from there to here, we eliminate the cross traffic pattern, and now it's not a matter of sanitation, it was a matter that we were pulling raw stuff into our clean area. Think smarter, not,
00:26:01
Speaker
Always more more isn't always better. It's a lot like It's a lot like fertilizer plants, you know, it's not always more this better. Absolutely So in kind of wrapping this up You've done quite a bit of environmental monitoring on produce farms What's a mistake out there that someone could make as they're starting this program besides wanting to just go gung-ho and doing all the samples themselves?
Timing and Data Understanding
00:26:26
Speaker
I think the biggest mistakes that I see is
00:26:30
Speaker
is that when they, well, one, not having, not doing it, that's the biggest mistake. But once they start getting involved in it, they start too late in the season. And so they're right on top of produce is going to be coming in, and now they decide they're going to do an environmental monitoring plan.
00:26:52
Speaker
And they're already hectic over the fact that, oh, I gotta get the equipment in place, I gotta do this, I gotta do that. And now they wanna shove in an environmental monitoring plan. You gotta plan these things out in advance. In April, you need to be planning for what we're gonna be doing in June. Sit down with the lab, sit down with somebody, get the cost estimate, have them come in and walk through the facility and say, okay, here's how we're gonna do the baseline. And let's have the equipment set up by this time.
00:27:21
Speaker
So that you can get these things on the calendar, get in there, get the swabbing, because it's going to take a week to get the swabs taken into the lab, cultured the data back. And if you have hotspots, you've got to remediate those. So you've got to get yourself time.
00:27:39
Speaker
you and I know that we don't control what Mother Nature is going to do as far as the produce coming in out of the field. She's got her own ideas of what's going to happen there. So give yourself some cushion and then be consistent with it. All stay on top of it. Then probably the last thing is don't just collect data. Don't just collect pieces of paper to put in the book.
00:28:07
Speaker
understand how to use the data for trending to see okay what's going on and then really monitor am I improving you know if you're not improving figure out why you're not improving so I think those those would be the things that I would recommend absolutely well that was very informative hopefully it helps a lot of growers out there and we appreciate your time so thanks a lot you're very welcome really enjoyed it
00:28:33
Speaker
Links or definitions to anything referenced in this episode are provided in our show notes, which can be accessed on the website at c-a-n-r dot m-s-u dot e-d-u slash agri-food underscore safety. You may also visit the Agri-Food Safety website for additional produce safety resources, trainings, and assistance offered by MSU Extension. Thank you to everyone for listening and don't forget to tune in next month for another episode of our Produce Bites podcast.