Food Safety Magazine, February/March 2013

SANITATIONis a matter of legal liability based onanalytical results and the applicable actionplan(s). For instance, if the purposeof sampling is to monitor indicatormicrobe levels, in-house sampling andanalysis may be sufficient as long as thelevel of competency of the sampler andthe in-house laboratory is commensurateto the sampling and analytical procedure.Should this strategy be followed,it is recommended that frequent blindsamples be sent to a state-certified thirdpartylaboratory to validate the in-houselaboratory performance. Similarly, athird-party sampler should perform sideby-sidesampling to validate the in-housesampling procedure. When wishing toanalyze for a foodborne pathogen, dueto the complexity of analytical procedures,it is advised that analysis and samplingbe performed by a state-certifiedlaboratory proficient in analyzing saidanalyte for the particular sample type.When engaging a California statecertifiedlaboratory to perform said analysis,additional reporting liability needsto be considered. Aside from the federalReportable Food Registry reporting requirements,a California state-certifiedlaboratory (in-house and third-partyalike) has the obligation to report anyout-of-compliance foodborne pathogento the California State Department ofAgriculture.ConclusionsThe sampling process for raw producefor the purpose of verifying and validatinga food safety management systemto yield a food-safe product is not to beoverlooked and should not be consideredan insignificant challenge. The who,how, what, where, when and why to samplecannot be taken lightly, as the ramificationsof the analytical results when asampling plan is not well planned canproduce a devastating blow, not just forthe producer but for an entire industry.To design and develop a thorough,complete and representative samplingprocess, one must take the time to plan,spell out the purpose, state the objective,define the results and ask the difficultquestions. A well-planned sampling programwill not only achieve the purpose,objective and anticipated results but willalso sustain and maintain a sound analyticalprocess representative of the foodsafety management system it is designedto verify and validate. Think about it! •Sri Pfuntner, M.Sc., is managingpartner of Hartono & Co.and serves as a consultant to theagricultural, ag-chemical and retailindustries for the implementation ofbest practices. She can be reachedat hartono_co@msn.com.References1. www.extension.org/pages/19198/overview-ofmonitoring-and-identification-techniques-forinsect-pests.2. www.btny.purdue.edu/pubs/vegcrop/VCH2005/VCH447.pdf.LaserONMIT 1000Introducing the MIT 1000 Microbial Identiication SystemFaster, More Accurate, Easier to Use, Lower Cost, More Compact.Non-biological, laser-basedNo gram stain requiredSimultaneous Identiiers TMVery low consumables costLow per-test costF e b r u a r y • M a r c h 2 0 1 3 23