I disagree. What does the egg touch as it's cracked? What does the consumer touch as they crack the egg? I would argue that although the egg is "packaged" the exterior needs to be hygienic. People do not wash the outside of the egg before use!
I could be wrong but I also thought that an egg shell was semi permeable? Is that true? Actually it must be if they can pick up taint. Egg mayonnaise producing plants use chemicals so there must be suitable chemicals which will not taint your eggs.
I think your HACCP team need to consider the risks of contamination of the contents from the exterior first due to use by the consumer or customer (which I think would be there) and then decide what verification methods are required for your cleaning schedule.
Thanks - mayonnaise plants as a rule will not use shelled egg, rather buy in pasteurised liquid/powder egg.
Risk assessments have been completed and all are low risk (obv apart from Salmonella but there are stringent controls there), there are controls in place to ensure that dirty/soiled eggs are removed before packaging, when shells are contaminated with the yolk (protein) bacteria will grow but not so with the white but there are processes in place to remove these from class a production.
All the above has been considered but under normal cricumstances the shell should not come into contact with egg after cracking, the egg will be cooked so killing off most bacteria and consumers have always been advised to wash their hands after touching raw meat, poultry and eggs.
Im not opposed to the idea of swabbing but dont want to introduce a procedure that isn't really needed - there are enough of those flying about!
What would you suggest for a swabbing schedule?