ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE 2

BIOGRAPHY JACK VAN DER SANDEN 04

05
ARTICLE #1
HOW HEALTHY IS YOUR FOOD FACTORY?

ENVIRONMENTAL
PATHOGEN 07
ARTICLE #2
TIME FOR SOME LISTERIA HYSTERIA?

MONITORING:
09
ARTICLE #3

AN INTRODUCTION PATHOGEN HUNTING, WE ARE GOING ON A BEAR HUNT!

GUIDE ARTICLE #4
HELP – WE FOUND A PATHOGEN IN OUR PLANT 11
A COLLECTION OF ARTICLES BY JACK VAN DER SANDEN

13
ARTICLE #5
PATHOGEN MANAGEMENT: DANGEROUS ASSUMPTIONS
3 ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE 4

JACK VAN DER SANDEN

Jack van der Sanden is an internatio-
nal food safety advisor. He has been
part of the global food industry for
over 30 years.

After obtaining a food technolo-

gy degree in The Netherlands, Jack
joined the food industry as produc-
tion supervisor. He migrated to New
Zealand in 1990, where he obtained a
post-graduate diploma in dairy science
and technology at Massey University.

Over the years, he rose through the ranks and ended-up managing pro-
duction, technical and food safety & quality teams. This cross-functional
exposure enabled him to find pragmatic solutions, that strengthened
food safety and quality systems in different multinational organizations.

During his career, he has not only advised small and medium-sized
businesses in the food industry in New Zealand, but has also managed
international consultancy projects in the United States, Europe and
China. His expertise has opened many doors for him, from leading
training in food safety and quality to mentoring many professionals in
the food industry around the world.

During the last 10 years, he has specialised in Environmental Pathogen

Management (EPM) and advised food industries in the design of pre-
ventive and effective EPM programs.
5 ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
HOW HEALTHY
IS YOUR FOOD
FACTORY?
“Prevention is better than cure” is a basic
principle which seems rather simple to follow.
And yet, as Jack Van der Sanden points out,
it is probably easier said than done.
Whether it is for a simple health check-up or
for plant health routine, procrastination or
budget cut very often prevent us from putting
prevention first.
At BioMérieux, the implementation
of preventive food safety control
programs within food factories is one of
our priorities. In these companies, annual
budget challenge often undermines an
already poorly organized plant environmental
health surveillance program.
Let Jack explain to us how a strict
routine of plant health checks would
detect anomalies more quickly and avoid
many problems.
ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
I’m a privileged man. I’m in the age group where
every few years, I get a lovely reminder from
my doctor to make an appointment for a health
check-up and every time I do the “male thing”; I
put it off!! Fortunately, the nurses have caught
on to my habit of procrastination and have
taken matters into their own hands by giving
me a phone call a few weeks later with a set
time and date for the appointment. The last
time a young lass very firmly told me: “You
will just have to come in Mr van der Sanden,
no excuses!”.
What is the deal with humans and prevention?
How come we are often very quick dealing
with issues but when it comes to preventive
routines, it’s so much harder? It happens on
a personal level as well as in business. You
may have come across the saying “we have to
create a burning platform!”? In other words,
if there is no fire, nothing will happen. I have
read this has all to do with our internal reward
system - if we do not see an immediate gain
from our efforts, we are just not inclined to
move as quick.
When it comes to a food plant, I consider the
environmental monitoring systems for wa-
ter, air, pests, pathogens and other hygiene
indicators like a health check. They are all
incredibly important preventive food safety
controls. However, whilst we all tend to agree
that “prevention is better than cure”, these
checks do suffer from the “prevention flaw”:
the rewards are often invisible to senior mana-
gement. Alas, management does see the cost
of our sampling and testing, so it should come
as no surprise, that every budget round the
food safety & quality manager has to defend
their preventive monitoring programme (like I
ask myself: “Do I really need to have that health
check every few years?” “YES”, my wife says!).
6
During these budget rounds, you can of course
try the technical angle; explain why you monitor
and the importance of prevention. You can talk
about the dangers of pathogens and raise the
fact you have not had any recalls, unlike some
others in your industry. Well, here are some
other human flaws! We are not easily swayed
by other people’s mistakes and mishaps!
Some of us don’t even learn from our own
mistakes (like me and my annual health check
procrastination). We also tend to have an in-
credible short attention span and the shutters
go up very quickly if it doesn’t interest us.
For me, the best way to prepare for the annual
budget challenge and defend your plant health
routine is to make the results visible. You see,
all our preventive monitoring generates a large
amount of data, which over time, can give you
a very useful health history of the plant. If you
paint a picture, you will turn this data into in-
formation (and take it from me, when standing
in front of senior management: “a picture is a
thousand words”!).
Unfortunately, when I ask food safety & quality
managers to see the historical results of their
environmental monitoring, I often draw blank
looks and I’m lucky to get presented with a
year’s data in a spreadsheet (no graphs/heat
maps or trends). The practice of “exception re-
porting” has a lot to answer for, because when
our “plant environmental health” results are
as expected, they disappear into the “cloud”.
I think that is a shame, because if you turn your
data into a trend or graph, you may not only be
in a better position to keep your budget; you
may also pick-up on that slow, incremental
deterioration of the air quality in the plant!
Hmmm, maybe I should start mapping my
cholesterol levels!?
— Jack
7 ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
TIME FOR
SOME LISTERIA
HYSTERIA?
Listeriosis is a serious microbial
infection, fatal in 20 to 30% of cases,
caused by eating food contaminated with
the bacterium Listeria monocytogenes.
Lately, the food industry has faced an
increased number of Listeria incidents:
from preventive recalls to the deaths of
dozens of people.
Surprisingly, whilst we thought that Listeria
could only affect high risk food products, it
is now popping up in new food categories
that were traditionally not implicated, such
as melons or frozen vegetables.
Jack Van der Sanden, our food safety &
quality expert, discusses this unexpected
spread and shares some thoughts
on management of Listeria in
food factories.
ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
I’m not sure about you, but as a food safety
professional (and a consumer), I have noted
an increased number of reported Listeria
incidents in recent years. Only a few years
back, the nasty one: Listeria monocytogenes
(Let’s call it Mr. LM) has managed to kill over
200 people using sausage (South Africa) and
some more with melons (Australia) and fro-
zen sweetcorn (Europe/US); and that’s not
counting the numerous preventive recalls for
cheese, ice-cream and other foods.
What concerns me is the fact that Mr. LM is
popping up in new food categories that have
traditionally not been implicated (ice-cream,
vegetables, even dried), which suggests Mr.
LM is a growing problem for the food industry.
(Admittedly, the micro detection technologies
have advanced and outbreaks in the distant
past may not have been able to pinpoint the
source as effectively. However, for a food ma-
nufacturer, I think this makes the problem big-
ger).
So what are your options!? Well, if you are
a food producer, the only barrier between
you and a major Listeria recall are preventive
controls and measures or as I call it: “a Resilient
Food Safety System”.
To get you started, here are four key lessons
from my pathogen traceback involvement in
the food industry (note - these lessons are
from several different products, companies
and factories).
Fix your floors!
Mr LM’s favourite hideout is the factory floor.
Unfortunately, the number of floors I have seen
with pooling water, loose tiles, cracks and lifting
surfaces, is too numerous to count. Building
maintenance in the food industry really is the
poor cousin of equipment maintenance. I know
that replacing floors doesn’t make money, but
if you have a poor floor and the Listeria family
comes knocking, no amount of “deep cleaning”
will work. You will have to replace the whole
floor, to get on top of the contamination!
Clean your Chains!
My visits tend to be anticipated with some
nervousness; apparently, I can be scary. As
8
a result, most of the factories I visit tend to
be very shiny. Fortunately, in most cases, all I
have to do is to open those shiny stainless steel
doors underneath the machine to expose a
problem (Yes, I do ask nicely first!). So, it really
is worthwhile to inspect the gear underneath
your filling lines to ensure those drive chains
are clean (they are often close to the floor
too!). Oh, and one more thing, I have been
told of pathogens found in food grade grease.
Keep it dry!
The Listeria family does not like dry! Fortuna-
tely for them, most food operators like to keep
their environment nice and wet: hosing the
floors, water blasting (perfect to get the fa-
mily from the floor onto your equipment!)
and plenty of condensation. I have seen plants
with pretty poor plant access controls from
outside, that did not have a Listeria problem.
Their saving grace: keeping the plant dry du-
ring production! Yes, it’s not easy to break the
“hosing habit” of food operators, so I often
ask them: “Gosh, do you keep your kitchen at
home this wet as well?”.
Find Them in your Factory!
A good environmental pathogen monitoring
programme is worth it’s weight in gold! One of
the first things I look for during my factory visit
is the design and effectivity of the monitoring
programme. It’s like your pathogen “smoke
alarm” and not very difficult to implement. The
great news is that with the latest technology,
you can get results within less than 24 hours,
so you can do something about it straight away.
Of course, there are numerous other risk fac-
tors, such as cleaning habits, water circuits
etc.; however, if you manage the four points
above, Mr. LM will struggle to get a foothold.
And one other thing! Recent research has
shown that Mr LM is very close to Listeria In-
nocua (Let’s call it Ms. LI). Turns out, Ms. LI is
not as “innocuous” as her name suggests. They
appear to be lovers and she hides Mr. LM in the
testing environment, so rather than having a
big sigh of relief when the test says: “It’s Ms.
LI”; increase your vigilance, because Mr. LM
will be around somewhere (Maybe we should
rename her Ms. LA, like “Listeria alarma”).
— Jack
9 ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
PATHOGEN
HUNTING, WE
ARE GOING ON
A BEAR HUNT!
Tracking a bear whilst wandering randomly
in a forest without a strategy or plan is not
easy. The same goes for your pathogen
hunt. The best way to go on a pathogen
hunt is to establish a strict environmental
pathogen monitoring program.
Surprisingly, food factories often fail to
plan when it comes to environmental
pathogen monitoring. Jack Van der
Sanden believes that it is an essential
tool for food plant safety and the
principle is simple: if we search correctly,
we increase our chances of finding.
Remember, it is better to find a pathogen
in the environment of your food plant,
before your product is contaminated.
ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
If you are a parent, chances are you’ll reco-
gnise the sentence: “We are going on a bear
hunt!”. It’s taken from a famous children’s
book by Michael Rosen, illustrated by Helen
Oxenbury. We had to throw our first copy
away because it fell apart, and I still remember
the first lines (after almost twenty years):
We are going on a bear hunt; we are going to
catch a big one; what a beautiful day! We’re
not scared - Oh Oh!
I couldn’t help but take these classic lines and
link them to environmental pathogen moni-
toring, because sometimes, to get a serious
message across, it pays not to be too serious.
Let’s start on a positive note: “We are going
on a “pathogen” hunt, we are going to catch
a big one, what a beautiful day!”. If your envi-
ronmental pathogen programme is designed
on this principle and aims to find pathogens, it
will be one of the most important pre-requisite
programmes in your food safety & quality
system, because it will provide you with plenty
of warning before your product is at risk.
Unfortunately, quite a few food factories I
have visited go through the motions. They
do not set out to find a “bear”, but do some
swabs here and there (not too many please;
they’re costly!). They see the environmental
pathogen monitoring as just another must-
do compliance exercise to meet a standard.
I cannot emphasise enough that a good
Environmental Pathogen Monitoring pro-
gramme must be designed to seek out
(“hunt”) pathogens, particularly in the high
risk areas close to the product.
The second part of the storyline is important
too: “We are not scared, Oh Oh!”. This per-
fectly illustrates another problem I encounter:
10
the assumption that “all the results will be
negative” and a poor understanding what to
do when there is a positive result (“Oh, Oh!”).
I have written before that if you have an envi-
ronmental pathogen programme, you must
be prepared for the “Oh, Oh!”.
For example, please carefully read the fol-
lowing (to me unbelievable) statement from
a FDA factory investigation:
“Despite finding listeria in 10 of 54 tests on
food contact surfaces from Oct 30, 2014 to
April 28, 2015, Company X didn’t check the
finished products for Listeria. Nor did Com-
pany X continue to check surfaces for Listeria
after April 28, 2015.”
Turns out the owners of Company X did not
know how to get rid of the contamination
and decided to just stop testing. The result:
by late 2016, the company’s products made
several people ill (including 2 deaths) and the
company lost their operating license.
If we look at the timeline in this example, it
is similar to many other famous food safety
cases; finding pathogens in your plant envi-
ronment is a real warning, which requires an
immediate, pro-active, managed response.
And if you struggle with your fight against
a persistent pathogen in your plant, please
seek expert advice and don’t make it your
new normal.
When it comes to pathogens in your factory
environment, there are few second chances
and so I feel compelled to make one small
change to Michael Rosen’s text:
We are going on a bear hunt; we are going to
catch a big one; what a beautiful day! We’re
not scared; we are prepared!
— Jack
11 ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
HELP – WE
FOUND A
PATHOGEN IN
OUR PLANT
Finding a pathogen in your food plant
can lead to some real drama and
panic. This should not be so! A good
environmental pathogen monitoring
program seeks to find pathogens in
your plant environment and a positive
result should not surprise you.
So, it is important to know what to do
when you find them and your program
needs a pre-determined response plan.
In this article, Jack Van der Sanden
offers some suggestions on how to
develop an environmental pathogen
surveillance program, for your plant.
ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
First of all - congratulations! The fact that you
have found a pathogen in your food manufac-
turing environment means you actually monitor
your plant for pathogens - that’s a good thing!
Many investigations in major food poisoning out-
breaks show: the pathogen was detected in the
plant environment well before the product started
harming people!
It is poorly understood that to get things really
wrong in the market (illness/death), you have
to have a major pathogen source and product
contamination; not a one-off or sporadic environ-
mental detection in the plant. For this reason, A
well designed Environmental Pathogen Monitoring
(EPM) system is like your food factory smoke
alarm, because it will warn you that your product
may be at risk, not necessarily is at risk.
I also urge you to test your final product for pa-
thogens to verify that your pathogen defences
and EPM are working (In one famous case, a
company did not conduct verification testing
of their final product before release. Once, the
scientists started testing the product (after the
outbreak), they found >90% was positive). If you
test your product for pathogens, you also need
“positive product release” (i.e. waiting until the
results are known), unless you want to be in the
news for the wrong reason (recall)! With the new
rapid detection methods, this doesn’t even have
to affect your supply chain anymore, because
the product will still be in your control when the
results come out.
An effective EPM combined with product
verification and positive release provides you
with the greatest assurance your product will
not harm people!
You can find a large number of free guides on
EPM’s for Listeria and Salmonella from Go-
vernment Agencies, most of them based on the
concept of zoning (In the US we have zones 1 to
4, with 1 being product contact; New Zealand has
zones 4 to 1, with 4 being product contact (maybe
because we are in the Southern Hemisphere?)
and Australia uses A,B,C,D (I suppose they just
wanted to be different?)). Beware though, the
guides are generic and the design of your EPM
does need to be plant specific. There are some real
cost-benefit decisions to be made when hunting
for pathogens (you can spend a small fortune on
the wrong samples).
I use a design with only 3 zones (just names:
12
“close , in-between and far”). For me, product
contact swabbing is the same as actual product
testing for pathogens and therefore not part of a
warning system but more like the actual fire. My
logic is simple: if you find a pathogen on a product
contact surface, the product you have made is
contaminated and no amount of final product
testing can clear the batch. So, if you must swab
product contact surfaces for pathogens (and in
some food factories it may be the best option),
please put your product on hold until your results
come back clear.
Once you have sorted your plant specific zoning,
you set up your swabbing points and away you go.
I have seen a wide variety in sample numbers/
frequencies and techniques, so I will not elaborate.
For me, the key parameter is that your programme
is designed to find pathogens! If you do not set out
to catch the nasty ones before they catch you,
your EPM is not effective.
Of course, when it is effective, you will one day,
get the dreaded call from your laboratory: “sample
XYZ is positive!”. Sadly, this call always happens
on a Friday (Murphy’s Law), when you are win-
ding down and contemplating your plans for the
weekend. This is why your EPM also needs a
pre-determined response plan: what are we going
to do when our alarm is triggered? I’m surprised
almost all food factories have fire drills, but when
it comes to a pathogen in the plant, many sort of
“wing it”.
A good response plan seeks to find the cause
(where could it have come from?), has mitigation
steps (could the product be affected?) and has
clear pre-determined actions for cleaning and
control. A good response plan has an escalation
procedure (who needs to know?) and criteria for
the all clear. When you have a good response plan,
you will know what to do (instead of panic) and
have a better chance of finding the root cause for
complete elimination.
I’m aware I’m skimming the EPM surface in this
post. There are a large number of considerations
in the design of an effective EPM, like: where
to sample, what to sample, what sample me-
thod, where to test, what to test, how to test, who
does what? My key message is that without a
pre-determined response plan to a positive detect,
you will be caught out and spent your weekend
running around like a headless chicken instead
of spending time with your family (believe me, I
have learned the hard way!).
— Jack
13 ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
PATHOGEN
MANAGEMENT:
DANGEROUS
ASSUMPTIONS
Environmental pathogens
management (EPM) is essential in
food factories. Yet, it is often a poorly
understood area, surrounded by some
dangerous assumptions. As a result,
companies may set up suboptimal
and counterproductive programs to
manage environmental pathogens.
During his 30 years working in the
global food industry, Jack Van der
Sanden identified some of these
dangerous assumptions. He exposes
them in this article and shares some
precious tips in order to avoid
costly mistakes in your fight against
environmental pathogens in your plant.
ENVIRONMENTAL PATHOGEN MONITORING : AN INTRODUCTION GUIDE
As you may know, I have been working in En-
vironmental Pathogen Management (EPM) for
some time now and continue to hold the position
that: if you are in the food industry, a well-de-
signed EPM program is a food safety “smoke
alarm” that can prevent product contamination.
However, as I work with customers, I have come
across two dangerous assumptions, with re-
gards to the detection or absence of pathogens
in the environment, which can lead to some
sub-optimal behaviours.
“A pathogen in a food factory is bad!”
Some people, despite their best intentions,
make the assumption that: finding a pathogen
in our food factory environment is “bad”. Their
reasoning appears to be that a pathogen is bad
and therefore finding a pathogen in the factory
environment is bad. Let me try and explain my
reservations, going back to that “bear hunt”:
If we design an EPM program, we should be
trying to find the pathogen we are looking for.
It’s like, if we’re going on a bear hunt; we’re ac-
tually looking for a bear. Now, if we understand
the relationship between our environment and
the target pathogen, we should not be surprised
to find that pathogen; it’s an expected result!
Like, if we’re looking for polar bears in the Arctic,
finding a polar bear means success. Our EPM
programme is effective if we find our target pa-
thogen in the factory environment - it is not bad.
Holding the assumption that “finding a pa-
thogen is bad” (and acting accordingly) may
drive the wrong behaviours in our food facto-
ries. It’s actually very easy to design an EPM
14
program that will never find a pathogen (if you
want one - don’t call me!).
“If you do not find a pathogen in your en-
vironment, your program is in-effective!”
Now, based on my previous argument, this sta-
tement appears correct. Alas, it is flawed as well.
I have seen some very good EPM programs that
have yet to find a pathogen. The reason appears
to be that some factory environments do not
support pathogens. They are either very clean,
designed to prevent pathogen harbourage (i.e.
dry environments) or for some other unknown
reason appear “pathogen proof”. Despite our
best efforts, our arctic expedition can actually
return without seeing a polar bear at all.
So, why is the assumption: “no pathogen detect
equals in-effective program” counter produc-
tive? Well, some of my clients have been taking
samples outside of the factory to try and de-
monstrate to auditors that their EPM program is
working. Useful? Not really! I rather have them
spending that money on monitoring the factory
internal environment for pathogens.
Because, in order to improve food safety in the
global food supply chain:
“We want our food industry to spend their time
and money where the real food safety risks are
in their business and every food safety dollar
and minute that is spend in low risk areas will
not be spend on the high risk ones!!”
To me, sampling outside the factory for pa-
thogens is like hunting for polar bears in the zoo;
you will find one – but in a pretty safe location!
— Jack