Sanitation Validation Frequency

I am just finalizing our SSOP and have no idea how often we need to validate effectiveness of our cleaning.

We make printed food paperboard packaging.

We used an outside lab for initial cleanliness status but that will get pricey if we have to do it daily/weekly.

The guidance documents do no give any guidance on frequency based on risk.

I was looking into the ATP swabbing products because this will probably be less expensive than constant lab visits.

I believe our pre-assessment auditor said that just sending out FG product to an analysis lab would suffice as well.   But how often?

All insight would be greatly appreciated.

Risk assessment.

Is the paperboard food contact?

What is the general cleanliness of your facility?

What food products are the paperboard used for?

etc.

I know that's not much of an answer, but without a little more detail, it's hard to suggest a reasonable course of action.

Marshall

Ditto to mgourley, but maybe I can provide some generic ideas. Bear in mind Ipacy that I don't know if you're under any FS standard (such as SQF), which will change the answers provided.

For my packaging suppliers, instead of a constant verification that each sanitation was effective, I asked for an annual validation/verification that the methods used were effective. E.g they would take an obviously dirty line, swab it for indicator organisms, then use their cleaning method, then swab again to ensure that the method used was effective at removing those microorganisms. Microbial data that demonstrates your methods are effective is more valuable than random swabbing IMO. I ask my suppliers to do this once per year for something like 5 surfaces, comes out to $100-200 in testing fees.

In response to testing your products, it's hard to say how helpful that would be. Suppliers obviously like more data over less, but my primary concern with packaging is that it becomes contaminated on an infrequent basis due to poor sanitation/GMP's in the facility (since FDA does not inspect). "End-item" testing does not help with this.

Finally, since you mentioned paperboard, a helpful microbial standard would be the paperboard "disintegration" standard in the raw milk ordinance of 250CFU/gram, which any dairies you may sell to are required to meet:

 

1. Paper stock shall meet the bacteriological standard of not more than two hundred fifty (250) colonies per gram as determined by the disintegration test. The paper stock supplier shall certify that their paper stock was manufactured in compliance with this Standard. This applies only to the paper stock prior to lamination.

I am striving for SQF compliance.  I have read on here, posted for the same industry that they send product to a lab monthly as verification of Cleaning and Sanitation.

I am also considering having the same lab come in every 3 months to swab as well.  But now the lab is asking me what are the testing the product for?  One question just leads to another.

For sanitation verification APC/SPC/HPC generally count the number of aerobic bacteria remaining on the surface to gauge how "clean" it is. Various standards exist.

One question just leads to another.

 

Yep, this stuff is complicated, that's why QA folks have job security. :)