The basics of a monitoring plan
To set up a good monitoring plan, start with the basics. What are the raw materials and what is the finished product range? Based on this data, you start figuring out what parameters you are going to test for. The basis of the monitoring plan is laid down in various legislation, such as Regulation (EU)2073/2005, Regulation (EU)915/2023 and or Regulation (EU)1333/2008. For specific hazards, this may also be laid down in other legislation, such as TVB-N in fish species. The standards for this are laid down in Regulation (EU)2019/627. Besides European legislation, national laws and regulations must also be taken into account, such as in the Netherlands the Warenwetbesluit van voorbereiding van levensmiddelen and in Belgium Royal Decree 26 April 2009 on microbiological criteria for foodstuffs. Furthermore, requirements for analyses may also be laid down in sector guides such as hygiene codes in the Netherlands auto-control guides in Belgium.
General parameters
After the legal parameters have been visualized, start looking at the general parameters. For example aerobic plate count, lactic acid bacteria or enterobacteriaceae. How do you know which parameters are suitable for a particular raw material or end product? Especially if you work with many different products or raw materials, this is difficult to figure out. And besides, what does a certain parameter say about the product or raw material? It is wise to look at what has been researched over the years at a company. This gives a picture of which parameters are important for a product. Another useful tool is the 2018 Microbiological guidelines, Support for interpretation of Microbiological Test Results of Foods from the University of Ghent.
This Guideline contains background information on spoilage organisms and in which products certain spoilage organisms occur. It is important to indicate in the monitoring plan why a certain parameter is being investigated so that it can be properly substantiated during an audit. For example, general aerobic plate count is generally used because it is an indicator of the overall condition of a product or raw material. The Guideline describes different product groups such as dairy, meat, seafood and mollusks, vegetable products, bakery and confectionery, compound products, long-life food and water. For each product group, different subgroups are indicated and advice is given on which parameters are relevant to investigate. These can be included in the monitoring plan.
GFSI recognized standards also require that the monitoring plan be prepared based on a risk analysis. So you need to identify which parameters could potentially be present in your products and these should be included in the plan.
Standards and frequency
Once it is known which parameters need to be examined, then you can set standards. Again for legal standards, this is relatively easy. The legislation specifies what the standards are and how many samples must be taken. For general parameters, the standards can be based on past experience and, if these are not available, on the standards indicated for the product group in the Microbiological Guideline. The frequency of investigations can be determined from Infosheets 85 and 64 or is risk-based.
Analysis results
Once this information is incorporated into a monitoring plan, it becomes easy to interpret analysis results. In this case, the preliminary work is more important than the final implementation. A report of analysis results can be laid next to the monitoring plan and assessed to see whether or not the analysis results exceeded the standard.
Action in case of deviation
What should you do if the analysis results exceed the standard? Also in this situation it is necessary to distinguish between legal parameters and general parameters. In addition, you must look closely at food safety parameters, think of salmonella or MRL exceedance or process parameters. Legislation often already states what to do if a parameter is exceeded. Information can also be found on the NVWA website under the topic Reporting unsafe food. An exceeding of a food safety parameter can lead to reporting to the NVWA and possibly a recall.
If there is an excess on general parameters, an action can be: re-sampling, contact with supplier or investigate process hygiene. This is unique for each company and cannot be cast in one overview.
Good preparation is half the battle! A good monitoring plan makes implementation and interpretation of analyses easy. Therefore, put a lot of energy into setting up a monitoring plan, properly name the sources and substantiate why certain parameters are examined.
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