Insight & Guide | Environmental monitoring & Robust testing schedules

Being able to identify which areas within a food facility are vulnerable to all  hazards and which ingredients are vulnerable to food fraud is essential in ensuring the early detection of any potential risks.

This can be achieved through building a robust testing schedule which takes into consideration all areas of concern (hygiene, microbial, food fraud and food safety in general). It is one way in which you can ensure you detect a potential issue before it becomes a problem.

Environmental monitoring is a process used in facilities that produce ready-to-eat foods that assesses how effectively the plant is being cleaned. This typically involves swabbing of various surfaces for pathogens and sending those samples to a laboratory for analysis.

A contaminated environment increases the risk of post-processing contamination. It also enables the identification of potential entry routes and sources of contamination which can then be monitored and effectively controlled. Early detection is essential in avoiding the spread of a contaminant or hazard from one area of a facility into another.

FACTS has put together a guide to assist you with making effective decisions on testing and environmental monitoring management at your food facility.


What does an environmental monitoring program consist of?

An environmental monitoring program typically consists of the following components:

  • Risk assessment of the hazards you’ve identified: looking at your ingredients and the nature of your operation, you should be able to identify the specific pathogens that may exist in the environment. You may have started this in your hazard analysis.
  • Your methodology
    • A map of your facility separated into hygienic zones (e.g. Zone 1 is the highest risk part of the production process and Zone 4 is the office)
    • A process for exactly how you will collect your samples
    • A description of how often you will conduct your environmental monitoring
    • A description of where you will swab. These should be the highest risk areas where bacteria may be hiding and could get into your product.
  • A description of how you will have the tests analysed (most likely by an external party, but it may also be in an in-house lab).
    • You must list the specific lab conducting the analysis and confirm they are properly accredited.
  • Corrective action procedures – how you will respond if you receive a positive result.

What are the types of Environmental Monitoring Zones in a food facility?

  • Product contact surfaces: direct contact with surfaces with potential to harbourage and contamination build-up conditions; for example, conveyors, fillers, pipes, storage vessels, utensils.Pathogens that need to be monitored on a routine basis; Salmonella and Listeria sp. (low to medium risk products)
  • Non-product contact surfaces: areas that are adjacent to direct product contact surfaces; for example, the exterior of equipment, control panels buttons, tables
  • Non-product contact surfaces: non-product contact areas in RTE rooms that are remote from product contact surfaces; for example, floors, walls, drains, leg supports, wheeled items, forklifts
  • Remote areas: Areas which are remote to product contact surfaces outside of the RTE room; or example, hallways, doors, coolers, cafeteria

To be able to effectively validate and/or improve the robustness of environmental control programs and hygiene zoning protocols in facilities that supply, manufacture and package food products the following components need to be taken into consideration:

  • Traffic patterns
  • GMP’s
  • Maintenance and condition of floors, ceilings and walls
  • How the design of a facility hinders or helps sanitation and cleaning
  • Sanitation procedures
  • Adverse events
  • High-risk areas and ingredients

Do I need an environmental monitoring program in my food facility?

  • Does your process have a kill step? (e.g. cooking)
  • Are there appropriate verification steps in place to monitor kill steps?
  • Is your product exposed to the environment after the kill step and before packaging?
  • Is your product a collection of ready-to-eat products combined to produce a ready-to-eat food that doesn’t include a kill step?
  • If your product is refrigerated, is it one that is conducive to the growth of pathogens? (e.g. Listeria)
  • Do any of my ingredients have a high vulnerability for food fraud?
  • Does the supply chain increase the risk of food fraud?
  • Do I and can I trust where I am getting my raw materials from?
  • What is the risk that my raw material have food safety risks other than pathogens/allergens (e.g. pesticide residues, heavy metals).

While testing the product itself may inform you about the safety of that sample, testing of your facility verifies that your cleaning activities are working and that each batch is being produced in a pathogen-free environment.

Am I ready to implement an environmental monitoring program?

If you have already confirmed that you should have an environmental program, consider the following questions before diving into a plan:

  • Do you have a thorough sanitation program?

Your environmental monitoring program is a test of your cleaning, so if you have doubts about the thoroughness of your sanitation practices, address those first.

  • Do you have the resources to enact it faithfully?

Once you launch your program, it’s important to follow it. If you doubt your ability to adhere to the program you’ve created or respond appropriately to a test result, then you should address those gaps before implementing the program.

What should I test for in my environmental monitoring program?

Before deciding on what to test for, a risk assessment should be conducted on and vulnerability assessment should be conducted. This allows for the identification of weaknesses which can be exploited and can result in risk. 

A potential risk to food safety is that of food fraud, which is a collective term used to encompass the deliberate and intentional substitution, addition, tampering or misinterpretation of food, food ingredients, or packaging; false or misleading statements made about a product for economic gain.

Different types of hazards need to be taken into consideration.

How do I design a robust testing schedule? 

A robust testing schedule should be carefully designed after evaluating the facility and its products. Different food plants with various food products may require different testing schedules. A tailored testing schedule with a baseline/target will be more specific as well as more effect is assessing the overall sanitary conditions and quality of raw materials of the facility.

The team designing the testing schedule must define which raw materials and wherein a facility constitute the highest risks. Choosing the correct testing tools and methods before beginning to collect samples ensure that results are accurate and the date is usable.

How important is laboratory testing?

Laboratory testing is an important process, which relies on scientific analysis to identify problems or potential problems with food products. It provides analytical data on the quality of a product or production process to support quality control. The objective of quality control and food safety is to identify contaminants in raw material or contamination after a product is produced and before it is laced on the market.


Analytical chemistry testing: the study of the separation, identification and quantification of the chemical components of natural and artificial materials such as pH, additives, colours, contaminants, preservatives, minerals and trace elements, to name a few.

Food microbiological testing: the study of the microorganisms that inhabit or contaminate not only raw materials, components, ingredients and final products but also production areas, help to ensure and guarantee the safety of food products.

Food nutritional analysis: this not only provides nutritional information for labelling purposes but can also be used to confirm that the product does not contain substitute or replacement ingredients.

Food allergen testing: when a food facility manufactures products that contain different combinations of allergen, products must be tested to ensure that no cross-contamination has occurred in both the raw materials and the finished products.


Making use of horizon scanning can be useful in the early detection and prevention of food fraud incidents and is integral in the decision-making process for food fraud mitigation. It is also useful to consider consumer needs whilst doing this and to identify ways to overcome challenges faced by your organisation to prepare for successful food fraud mitigation in the future. (maybe a link to the food fraud quick guidance document)


A receiving facility is required to document a written supply chain program in its record.

A component of that program includes the documentation for sampling and testing performed as a supplier verification activity. The documentation must include identification of the raw material or other ingredient and the number of samples tested. It also means that the tests conducted and the analytical method used must be identified, the date the test is conducted as well as the date of the test report must be provided, and the identity of the laboratory performing the testing must be revealed. Any corrective actions that were taken in response to a hazard detection must also be reported.

However, the most crucial aspect to consider when creating a testing schedule is the question that needs answering, for example:

  • What will the test achieve?
  • What is the desired outcome of the testing?
  • How will testing assist in maintaining a rigid food safety system?
  • Does the test need to be accredited?
  • Does it make sense to test?
  • Will testing provide the answer to my question? Etc.

If you would like more information, please contact us.