I am way behind on getting our SQF manual updated to Edition 8. Currently, I am working on section 2.4.8 - Environmental Monitoring. Right now, the only environmental monitoring we do is ATP Swabs. We do not swab for any pathogens or indicator organisms. In our plant, we manufacture acidified foods, with most of the foods being in the 2.5-3.9 pH range. (Sauces, pickled items, dressings, etc.). These foods are thermally processed and we have certain CCPs that are checked on a regular basis (pH, temp, etc.). We also send off samples from every run of acidified product to a laboratory to be tested for APC, E.Coli, Yeats, Molds, Salmonella, and Lactic Acid Bacteria.
According to the new SQF Module 2 Guidance Document "An environmental monitoring program must be in place for food processes that are handled, exposed, stored, processed or packed. This program should be included for food processes of all risk levels." It then goes on to say "An environmental monitoring program (EMP) is a program which includes pathogen swabbing to detect risk in the sanitary conditions of the processing environment and is a verification of the effectiveness of the pathogen controls that a management site has in place for high risk foods (refer Appendix 2: Glossary of Terms)."
According to the Appendix 2: Glossary of Terms -
High Risk Food Food or food product with known attributes for microbiological growth, physical or chemical contamination, or which due to a process type may allow for the survival of pathogenic microbial flora or other contamination which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak.
Low Risk Food A food containing high acid that is not known to support the growth of pathogens; a food that is subject to a full cook prior to consumption.
So, my question is, do we have to swab for pathogens/indicator organisms or can I do a risk analysis saying that the food we produce is low risk? Or am I looking at this completely wrong. I am still new to this field and am still learning.