Food Protection Trends - August 2009 - 505

TABLE 6. An example of intensified environmental monitoring and control in response to special plant events plant events include construction, new equipment installation in the processing areas, or other events that may affect the primary Salmonella Control Area. Plant traffic controls, room air pressure, sanitation activities, etc. should be assessed during construction activities. Intensified environmental control procedures and action steps may be required, including: ∞ Reinforce GMP practices and traffic patterns with outside contractors. ∞ Set up temporary control barriers within the plant as applicable. ∞ increase cleaning frequency of adjacent areas during construction, after equipment installation, and after major repairs are completed. ∞ perform sampling and testing for Salmonella in the construction areas and adjacent areas during construction. ∞ increase environmental monitoring (frequency and/or number of samples) after construction, equipment installation, or major repairs are completed. the sampling sites and frequency should be determined based on a team evaluation of the following: plant location of construction activities; type of construction (e.g., installation, demolition, material removal); duration of construction activities; types of environmental controls implemented, etc. – Compositing environmental samples (combining multiple sponges or swabs into one pre-enrichment) or pooling (combining 2–5 post-enrichment samples into one test sample to be run on a rapid method) is generally not recommended. A positive finding on a composited sample cannot identify the specific location of the positive and results in broader, less focused corrective actions. however, there may be some situations where compositing may be appropriate, e.g., samples taken from multiple drains in the same processing area, where it is less important to pinpoint the site. if a “pooled” sample comes up positive, the individual enrichments that made up the pooled sample can be immediately retested separately to pinpoint the positive sample(s). however, this process adds delay in determining the location of a positive, compared to testing samples individually. the ability to composite or pool samples is method dependent and must be validated. implications of compositing or pooling should be carefully considered. ❏ Corrective actions must be taken when Salmonella is detected in an environmental monitoring or finished product sample. In most cases, corrective actions are triggered by presumptive Salmonella test results, since waiting for the final confirmation could take up to a week. – If a positive is found in any of the four sampling zones, the site should be examined and potential causes investigated. it may be advantageous to have a pre-assigned team to assist in the investigation and to help direct corrective actions. – Corrective actions to be taken should be based on an assessment of the potential for finished product contamination, given the location of the positive site in the environment. (A positive in Zone 2, 3, or 4 (non-pCS) does not automatically implicate finished product.) – Corrective actions should include appropriate procedures, such as those described in table 4, and be accompanied by re-sampling of the initial positive and adjacent areas. – All corrective actions taken, including re-sampling results, should be documented. SUMMARY AND KNOWLEDGE GAPS Several significant outbreaks of foodborne salmonellosis have been linked to products produced in low-moisture-food manufacturing environments. the control of Salmonella in these environments is challenging and highly specialized. Validation is complicated by the increased heat resistance of Salmonella at low aws. Stringent environmental monitoring regimens are essential to verify control of Salmonella in the facility. the guidance presented in this paper and its two companion papers has been developed on the basis of a synthesis of industry practices and programs, as well as information from the literature. application of the guidance, in terms of control elements and stringency of control, will depend on the product and process, including the intended use of the product. Knowledge gaps remain to be filled. the lack of adequate Salmonella inactivation data in specific products at various water activity levels has hindered industry’s ability to evaluate the adequacy of certain processes (such as baking of peanut butter cookies) in the event that an ingredient was found contaminated with Salmonella. For example, in response to the 2008–2009 Salmonella typhimurium outbreak linked in part to peanut butter, many peanut butter-containing products were recalled because there was little basis for the companies involved to evaluate the adequacy of the lethality of the specific processes. although heat resistance data for Salmonella in peanut butter were available, data on inactivation of Salmonella in peanut butter-containing cookie dough had not been published. the application of the data based on peanut butter was not appropriate to determine whether the baking process was adequate to eliminate the level of Salmonella expected in the contaminated ingredient (i.e., peanut butter). development and validation of additional dry cleaning methods is needed to AUGUST 2009 | FOOD PROTECTION TRENDS 505

Food Protection Trends - August 2009

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