Check list: monitoring plan environmental pathogens

Discover which steps you still need to take

From March 2025, all food businesses (except slaughterhouses and cutting plants) in Belgium are required to have implemented a monitoring plan for environmental pathogens according to the GM4 autocontrol module. Does your monitoring plan already meet these requirements? Find out which steps you still need to take with this free checklist.

Answer the questions honestly and as accurately as possible. Don't fully understand a question? Then chances are that you have not yet (sufficiently) implemented the section in question or that you are not fully aware of the content of the module. In that case, answer with ‘No’ or ‘I don't know’. After completing the questionnaire, you will receive advice that suits your company and you will discover which steps you still need to take.

The monitoring plan according to GM4 should be based on a detailed risk analysis, determining what analyses are needed, where they should be carried out and how often. An insufficiently substantiated/executed plan leads to A2 deficiencies during an ACS audit. Moreover, GFSI standards such as IFS, BRCGS and FSSC 22000 also require a well-thought-out and well-substantiated environmental monitoring plan. During a GFSI audit, you must be able to demonstrate compliance with current laws and regulations.

More insight and practical tools?

Do you want more insight into the content of the module and practical tools to get started? Then register for the Open Training GM4 on December 9, 2025.

Checklist Monitoring Plan Environmental Pathogens

Question 1: Beyond standard hygiene monitoring (e.g. contact plates or ATP testing), are specific samples taken to detect pathogens such as Listeria, Salmonella, or Bacillus cereus in the production environment?*

Question 2: Has it been clearly established which raw materials can be responsible for the introduction of environmental pathogens, and which specific pathogens are involved for each raw material?*

Question 3: Has the risk profile of the sector been clearly identified, and is it used to set the frequency of annual sampling? In addition, is a specific risk profile established for each production process and its associated end products?*

Question 4: Has the company been classified into risk zones for environmental pathogens?*

Question 5: Have all niche places and places where biofilm could potentially develop within the production area been identified?*

Question 6: Does the list of contact points cover all direct and indirect surfaces, including those in storage and social areas?*

Question 7: Is the selection of sampling points in the plan based on a thorough risk analysis, and is the sampling method for each contact point clearly justified?*

Question 8: Are samples taken just before the start of the activities, as well as during and at the end of the activities?*

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