The Environmental Monitoring Budget!

Here is a million dollar question: “Jack, how many samples do we need to take for a good environmental monitoring program?". Well, as I do not know your factory, my answer tends to be “How long is a piece of string?”.

Costs for environmental monitoring programs can escalate quickly. 50 samples/week at say $20/test adds to about $50,000/year. That is just environmental monitoring and doesn’t even include other testing costs or the labour costs of the sample technician.

If you think 50 samples/week is a lot, consider this: if we have a factory of 50 by 100 metres and 5 metres high, our total (flat) surface area of the building is 11,500m2. Of course our factory surfaces are not flat and we also need to swab the things inside, so let’s set the total surface area to 15,000m2. Let's assume that the average swab covers 0.5m2, which means that with 50swabs we cover 25m2 per week or 0.17% of our total surface area. It will take us 600 weeks or 11.5 years to go around the factory once.

That's why, when it comes to environmental monitoring, sample point selection is critical and we need a "targeted" plan, where we look for “worst-case, representative" points for our monitoring (see The Bear Hunt Continues). It is also why we should celebrate if we find a pathogen because clearly, the odds are against us.

Now, $50,000 dollars is still a lot of money and most food safety & quality professionals will struggle to get this through the annual budget review; particularly, since it is “discretionary” testing. I have yet to see an international rule or guideline, that specifies the actual number of samples in an environmental monitoring program. Hence, it's no surprise I have come across programs that take anywhere from 2 to 100 samples per week, and technically, they both comply.

Maybe we should change the million dollar question to: How many samples can we justify?

Let's look at some arguments we could use to increase our monitoring budget:

“We make a higher risk product!”

If we produce a chilled, ready-to-eat product or infant formula, management should need no convincing. Clearly, it is in the interest of the business to spend more money on environmental monitoring. A good question to ask management is: “what’s your risk appetite for a food poisoning outbreak?". When the answer is – “Not on our watch!”, the scene is set.

“Our factory is old!”

An older factory shows more wear and tear (like me!) and will have more harbourage points, so our program should have a bigger budget (like, my doctor does more tests on me these days).

“Our factory is big!”

A bigger factory with more lines should have a bigger budget and maybe you can try the above calculation example during the discussion with your managers.

“We have had positive results before!”

There is plenty of evidence that pathogens are here to stay! That is, once a pathogen has been found in the factory, it will be nagging us for the rest of our days and we should put up our guard and take more environmental monitoring samples.

This does of course not mean that we should halve the budget if we have no detects. Again, the odds of finding a pathogen are against us and “absence of evidence is not evidence of absence”.

In my experience, finding a pathogen tends to find more money for monitoring (it's like hitting the "jackpot").

"Let's benchmark!"

Finally, we may want to use "peer pressure". Try and find out what other people in your food category are doing (from auditors/customers/conferences) and use this for leverage. If we lag behind, it may help to lift our budget and if we are ahead we can compliment management on their food safety leadership (or keep quiet).

And never forget to tell management the reason why.

The real reason for an environmental monitoring program is not compliance. The real reason is that an effective program verifies the food safety controls in our factory, is a proven “smoke alarm” and will give us “peace of mind” and a good night’s sleep.

All the best with your budget reviews.

Jack

Disclaimer: this article is my personal opinion and does not reflect the position or opinion of my employer.