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Are All Environmental Monitoring Programs (EMPs) Created Equal?

By: Mike Koeris on April 19th, 2017

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Are All Environmental Monitoring Programs (EMPs) Created Equal?

FSMA  |  Food Safety

Getting your manufacturing operation up to speed with the tremendous transformation happening in the food safety arena requires an authentic shift in mindset and approach. It means adopting a more proactive, preventative plan to address the danger of pathogens. To minimize risk and meet rigorous FSMA requirements, you need a strong environmental monitoring program (EMP) in place. Unfortunately, not all EMPs are created and run the same way, and therefore don’t provide the same amount of protection and risk management! It’s critical to step up and strengthen you EMP, and do it in a way that is specific to the food you produce and will fit your unique facility best.

Not sure what to look for?

The truth is some EMPs are better designed and managed than others. The only way to make the best choice for your facility is to identify which factors are most important to you. In this article, you’ll find out what characteristics you should be considering as you search for a new system. Ask yourself the following questions to help distinguish an environmental monitoring program that fulfills your needs and prepares you to meet the changing demands of FSMA and the industry as a whole.

Is Your EMP Ready for FSMA?

Take the free quiz to find out.

Is it easy to manage?

An environmental monitoring program is most effective when its components are easily managed and automated. For instance, is it fully understood by those running it? Do you have an ability to view the plant in its entirety and see every test point at whichever level of detail you desire? Does it take advantage of modern data management approaches that reduce time and effort? As you work on strengthening your EMP or adopting a new system, it is important to ensure you are integrating a solution that enables you to:

  • Harmonize and automate your EMP processes across plants to simplify future food safety audits
  • Reduce manual errors and increase your productivity through automated tracking
  • Visualize your plant, with all facilities in one place, and see active tests in your entire floor plan
  • Track activities and ensure transparency through automated documentation and reporting

With the rollout of the Food Safety Modernization Act, safety standards have changed, and it’s more important than ever to implement a EMP that can be easily managed to meet more stringent requirements.

Does it facilitate communication?

Strong communication is essential to running a successful pathogen environmental monitoring program. Without it, you can’t properly and efficiently address the food safety challenges occurring throughout your facility. Your plant is a dynamic operation with  many departments and complex functions. Therefore, you must be able to foster cross-department communication and get everyone involved in your EMP.

Ensure that your EMP is leveraging a solution that enables fluent communication between departments and provides visibility to all teams and stakeholders. Your capacity to promote this visibility and communication impacts each individual’s contribution to the pathogen environmental monitoring program as a whole. In your efforts to find a EMP that makes strong communication possible, be sure to ask questions like:

  • Can the plant be visualized with a color-coded floorplan, individual pictures and powerful reporting tools?
  • Are there scheduling, monitoring and reporting features that support the program?
  • Can results and actions be communicated quickly to the entire team?

When it comes to preventing contamination risks, a lack of communication has the potential to cause major problems. You’re unable to relay data clearly and efficiently, minimize pathogen hazards and bring the whole team together in a unified effort. Facility-wide communication should encompass:

  • Day-to day contact between front-line supervisors and employees
  • Clear visibility into all aspects of the remediation process
  • Automatic alerts and email notifications to relay timely, business and safety relevant information immediately to the right stakeholders
  • Customized and detailed workflows
  • Robust reporting tools to help managers see the whole picture and make well-informed decisions
  • Functional checklists for effective change management
  • Practical means of documenting test results, corrective actions, notes, pictures, maintenance forms, statuses and progress

Does it enable proper evaluation?

Unless you are evaluating the results of your EMP, you can’t know whether it’s serving your facility effectively. That’s why this question is such an important one. Ongoing evaluation of both testing results and corrective actions is crucial to success. For every component of your pathogen environmental monitoring program, there must be an evaluation process that ensures the method in place is actually protecting food quality at every juncture.

In addition, it’s vital for this evaluation process to be highly efficient. If your testing and data management lags by several days, your ability to mitigate pathogen risks is compromised. You should be opting for the fastest tests available and ensuring that the data is returned as quickly as possible. Manual data transfer is not an effective solution. Choose an automated system that affords you the capability to prevent data loss and errors that lead you down false paths.

How does it address corrective action implementation?

Any effective EMP is going to see a small percentage of presumed positives. This should be expected as you tighten your monitoring program and enforce greater prevention controls. What you need in order to respond to those positives is a thorough remediation process, including the tools to track and record corrective actions. This enables your facility to learn from a positive, use it to improve the overall condition of the environment and, therefore, improve pathogen prevention.

What type of corrective action factors, then, should you be identifying in your efforts to adopt an effective EMP? It’s critical to ascertain how corrective actions are managed, how compliance is ensured and how communication is handled. Utilize a solution that improves your ability to:

  1. Communicate with key stakeholders -- everyone from the plant manager, corporate quality and food safety, corporate supply chain, and even brand owners -- and confirm the location of a positive result.
  2. Stop the operation of the implicated production line and determine the disposition of the product.
  3. Bring together critical components, including people from Quality/Food Safety, Operations, Maintenance/Engineering, Laboratory, Corporate/Plant and Crisis Management, as well as historical data, departmental or program data, etc.
  4. Develop a flow diagram with inputs and outputs at each step, and map this to statements from the team on the floor and other activities at the plant in order to determine the source of the contaminant.
  5. Address the situation either based on predetermined policies and standards or specific to the root cause.
  6. Confirm, once corrective action is complete, that cleaning and sanitation was effectively performed through additional environmental testing.
  7. Use the team's findings to improve process, SSOP, the overall environmental monitoring program and plant operations.
  8. Document the incident, corrective actions and outcome.

Ultimately, the responsibility of combating contamination risks can become an overwhelming one, but with a strong pathogen environmental monitoring program in place, you can adequately and efficiently work to meet FSMA standards and preserve the safety of your products.

To find out if your environmental monitoring program is ready for FSMA, take this free quiz now.

Is Your EMP Ready for FSMA?