Meat + Poultry - May 2005 - 71

Environmental testing

thorough environmental assessment
of all identified environmental sites
prior to the first production.
Testing on multiple fronts
Jeff Chilton, president of Chilton
Consulting Group, Rocky Face, Ga.,
points out that environmental testing is just one leg of a multipronged
testing approach recommended by
most food safety experts. "We have
helped a lot of companies develop
environmental testing programs," he
says, but most companies come to
Chilton asking for help in developing
an overall microbiological monitoring
program. "For these clients, we set up
three tiers of
sampling," he
says, including testing for
nonfood-contact surfaces,
direct-foodcontact zones
and product
testing, which
validates that
testing further
up the line is
working. "It's
important to look at both the noncontact, environmental testing plus the
food-contact surfaces," he says.
Once testing locations are established and exposure areas are
identified, food safety officials must
determine how the testing will be
measured. Most often it is by using
total plate count (aerobic plate count).
"This is a good number to measure
how well your sanitation crew is doing," says Chilton. A common goal
for many companies is less than 100
colony-forming units per gram for
most food-contact surfaces. Standards
of less than 1,000 colony-forming
units are common for environmental
areas of plants.
Other testing protocols check for
specific pathogens, such as Lm. In
2001, U.S.D.A. mandated processors
of R.T.E. meats test specifically for
this pathogen and gave them a choice

Higher risk
products, such
as hot dogs and
sliced luncheon
meats, are
subject to more
frequent testing.

MEAT&POULTRY

May 2005

of three testing alternatives to detect
either Listeria-like species or Lm.
"Most companies will test for Listeria
species, which is what we recommend," says Chilton. This is the more
common testing method because if a
plant tests specifically for Lm. and a
positive result is found, "any product
that went across the line during that
day is considered adulterated so there
is a lot of liability that goes into testing for Lm. on food-contact surfaces."
Opinions differ on this point. Many
meat scientists contend that testing
specifically for Lm. is necessary.
Chilton disagrees. "They are looking
at it from more of a scientific point of
view," he says. "For my clients, my job
is to minimize their regulatory liability." By using the three-tier approach,
"and by adopting a test-and-hold pattern, eventually you are testing for Lm.
both in the product and on the foodcontact surface," Chilton says.
Environmental testing is not a
one-size-fits-all proposition. Besides
those areas Westmoreland identifies,
Chilton also recommends considering
other potential hot spots, including
racks, tables, knives, and the ledges
of a packaging machine or slicer.
Hollow table legs are another oftenoverlooked area. "You want to identify areas like floors, walls, drains and
refrigeration units and areas that are
known for harboring those types of
bacteria," he says.
Once the sites have been identified,
frequency then needs to be determined, for food-contact and nonfoodcontact areas. Processors of R.T.E.
meat and poultry products have had
the frequency mandated to them by
U.S.D.A.'s Compliance Guidelines, issued in 2003. Government guidelines
are based on the size of facility, the
volume of their production and the
type of product. Higher risk products,
such as hot dogs and sliced luncheon
meats, are subject to more frequent
testing, often with weekly frequency
requirements. Smaller volume, lower
risk plants are more likely to be subject to monthly testing. A U.S.D.A.

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rule of thumb is for testing to be conducted two times per line at whatever
frequency is required.
Also, as result of 2003 regulations
for R.T.E. processors, plants must
comply with one of three sampling
alternatives, based on the level of intervention built in to their processes.
In short, Alternative 3 plants use only
sanitation measures to control Listeria
and, therefore, are required to sample
at the highest frequency. Plants in the
Alternative 2 category utilize either
growth inhibitors in their formulation or incorporate a post-lethality
process, whether spraying the product
with sodium citrate (high-pressure
process) using a hot water bath or pass
products through infrared heat tunnels. Alternative 2 plants are required
to sample sites less often, perhaps
quarterly, Chilton says. Alternative 1
plants use both growth inhibitors and
a post-lethality process. "For plants in
this category, you may not have to do
environmental sampling but maybe
every six months or so."
Chilton recommends plant managers should determine how many times
they want to test their areas each
month and divide it up into a weekly
schedule of ongoing tests. "Most
companies will try to work through
their rotating schedule at least once a
month to give them some good reference data and an idea of what is going
on in their plant," he says.
"Although the R.T.E. regulation
only requires testing of food-contact
surfaces for Listeria species, when
companies have gotten into trouble it's
been U.S.D.A.'s expectation that the
plant expand its program to include
environmental areas as well.
"Food safety starts with good sanitation, and you can only measure how
good your sanitation is by looking
at the results of your environmental
testing program," Chilton says. "It's a
critical piece of the puzzle."
We would like to hear from you- your comments
and questions about this article are welcome.
E-mail the author at: jcrews@sosland.com

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Meat + Poultry - May 2005

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