Common Questions Answered About Environmental Monitoring
10월 15, 2025

An Environmental Monitoring Program (EMP) is a powerful tool that helps food and beverage processors take control of food safety and quality. As awareness of its benefits grows, more facilities are moving beyond finished product testing and embracing proactive EMPs that identify contamination sources earlier in the process.
In this article, Neogen experts answer some of the most common questions food safety teams ask when setting up a new program or making updates to an existing one. Each answer draws on the latest guidance from the Neogen Environmental Monitoring Handbook for the Food and Beverage Industries (2nd Edition, 2025) and supports a preventative mindset—one that can help your team catch issues early and build a culture of continuous improvement.
For more detailed information on these questions and more, please download the Neogen Environmental Monitoring Handbook for the Food and Beverage Industries (2nd Edition, 2025).
Who should be involved in developing and managing an Environmental Monitoring Program?
Building and managing an effective Environmental Monitoring Program works best when it’s a team effort. A cross-functional group, typically including food safety, quality assurance, production, and maintenance personnel, brings valuable perspectives on facility flow, equipment design, and operational practices. Collaboration across departments ensures the program is practical, thorough, and easier to sustain long-term.

What are the key targets included in a well-designed Environmental Monitoring Program?
A well-designed Environmental Monitoring Program should include testing for a range of targets based on the facility’s products, processes, and risks. Common targets include pathogens such as Listeria monocytogenes and Salmonella; indicator organisms such as coliforms and Enterobacteriaceae; spoilage organisms including yeasts and molds; and, when relevant, allergens such as milk, peanuts, or soy. Because allergens present both direct and cross-contact risks, testing can be essential for verifying cleaning and sanitation procedures, especially during product changeovers. Adenosine triphosphate (ATP) testing may also be used as a rapid tool to support sanitation verification. Identifying the right targets and incorporating them into a robust EMP supports proactive detection, sanitation verification, and long-term food safety.
What’s the best way to define limits or targets for some of the various types of tests used in environmental monitoring, such as ATP testing and pathogen testing?
Environmental monitoring goals vary depending on the type of test, facility design, and operational needs. To add to the challenge, there are no regulatory requirements in place. However, teams supporting a proactive approach will always be one step ahead. Two different approaches for determining limits or targets include:
ATP testing: Begin with manufacturer guidance to set initial values. Then, collect data before and after cleaning using your current process, analyze the results, and adjust values as needed. Next, gather a statistically representative number of samples (e.g., 30) and refine the pass/fail values to align with actual results. Review and update these values regularly, such as every quarter, with the goal of establishing new, lower limits than the initial ones.
Pathogen testing: Begin with zone-specific targets, then set your goal to reduce the number of positives per specific zone. For example, food contact surfaces (Zone 1) should consistently test negative, while other zones may tolerate occasional low-level positives with trending and corrective action protocols in place.

How should Environmental Monitoring Program data be recorded and analyzed?
Environmental monitoring data should be recorded in a consistent, organized format—ideally using digital tools that support trending and visualization. Over time, analyzing results helps identify patterns, track improvements, and flag areas where contamination may be recurring. Turning data into actionable insights can strengthen your program’s effectiveness and support a culture of continuous improvement.
How stringent should an Environmental Monitoring Program be for a non-sensitive or low-risk food?

Table 1. Where and when to conduct testing in food manufacturing facilities
There’s no one-size-fits-all answer. Even traditionally low-risk foods, such as fresh produce, have been linked to contamination events in recent years. That’s why the first step should always be a risk assessment that considers both food safety risks and business risks. For example, if a product tests positive for Listeria spp. or Listeria monocytogenes, there is a serious food safety risk as well as a financial and reputation risk for the business.
Therefore, your environmental monitoring program should decide the amount of testing based on these risks and how customers may use your product. When building your testing strategy, be sure to consider sampling zones and how close those sites are to exposed products, as proximity to the food itself is a key factor in the overall risk analysis.
Is environmental sampling for Listeria required in facilities that do not produce RTE foods?
While not always required, Listeria sampling in non-RTE environments is still strongly encouraged. Because non-RTE products can sometimes be eaten without proper heating, a risk analysis can identify potential use cases and result in an Environmental Monitoring Program that contributes to addressing those food safety concerns. For example, frozen vegetables packed in bags with cooking instructions are often assumed safe after preparation. Still, if used in smoothies or eaten raw, Listeria monocytogenes could pose a serious risk. Similarly, raw meats, such as chicken or beef, are generally considered low risk; however, some customers or markets may still require Listeria testing to verify safety.
Regulators and customers expect facilities to control Listeria early in production, even if the product will be heated before consumption. Neogen® Molecular Detection Assay, Listeria Right Now™ can offer rapid detection to monitor Listeria in the environment and to support ongoing verification efforts. Learn more about Listeria Right Now™.
Root cause analysis helps identify the source of contamination, preventing it from recurring. Is there a baseline for how often contamination must occur before it triggers root-cause analysis?
You don’t need recurring positives to justify root cause analysis. A single positive, especially in a critical area like Zone 1, should be enough to trigger an investigation. Other events that should prompt root-cause analysis include more than three linked positives, such as two consecutive positives from a site and one positive from a vector swab follow-up; sporadic positives from the same site over time; or a general increase in frequency across multiple sites. Waiting for contamination to become persistent only delays corrective action. Starting the process early gives your team the chance to dig deeper, identify vulnerabilities, and prevent small issues from becoming systemic problems.
More Guidance for Your Team

Whether you’re building a new environmental monitoring program or refining an existing one, asking the right questions is the first step. For more in-depth guidance, including a detailed zone chart, a guide to root cause analysis, and foundational tools for designing your testing program, check out the Neogen Environmental Monitoring Handbook for the Food and Beverage Industries (2nd Edition, 2025).
Download the Handbook
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