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Food Safety Command Center 16 items

Environmental Monitoring Program (Listeria/Pathogen) Checklist

Verify a zone-based environmental monitoring program for Listeria and other environmental pathogens in RTE facilities.

FSMA21 CFR 117.165GFSI

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Program Design

  • Is a written environmental monitoring program (EMP) documented with scientific rationale? *
  • Is EMP required because a ready-to-eat food is exposed to the environment before packaging? *
  • Are hygienic zones 1-4 defined and mapped across the facility? *
  • Is the target organism (Listeria spp., Salmonella, or indicator) defined for each area? *

Sampling Plan

  • Are sampling sites, zones, and frequencies defined in a documented schedule? *
  • Are random and rotating sites included to avoid predictable sampling? *
  • Is sampling conducted during production (several hours in) rather than post-sanitation only? *
  • Number of environmental sites sampled per period

Testing & Laboratory

  • Is testing performed by an accredited laboratory using validated methods? *
  • Are analytical methods and detection limits appropriate for the target organism? *
  • Are results trended over time to detect harborage sites? *

Response to Positives

  • Is a documented corrective action / seek-and-destroy procedure triggered by a presumptive positive? *
  • Is vectoring (intensified sampling around the positive) performed after a Zone 2/3 positive? *
  • Are procedures defined for finished-product hold/testing after a Zone 1 positive? *
  • Is root-cause analysis conducted for recurring positives? *
  • Date of most recent presumptive positive investigation

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