the auditor we had back in January suggested we do random testing around the plant once a quarter for a year, if everything comes out OK then use that data to prove we are low risk and should not have to test anymore but if a test comes back positive to test that same spot once a month for 3 months to see if it tests positive again.
I mostly liked yr SOP using Enterobacteriaceae (ETB) in the parallel post/thread -
from the SQF8 Code -
2.4.8 Environmental Monitoring
184.108.40.206 A risk-based environmental monitoring program, for known or expected concerns, shall be in place for all processes in the manufacture of food packaging.
220.127.116.11 The responsibility and methods for the environmental monitoring program shall be documented and implemented.
18.104.22.168 An environmental sampling and testing schedule, appropriate to the nature of the product, shall be prepared, detailing any applicable pathogen (s), (i.e., Bacillus spp. in paper or paper products), the number of samples to be taken, and the frequency of sampling.
22.214.171.124 Environmental testing results shall be monitored and corrective actions (refer to 126.96.36.199) implemented where unsatisfactory trends are observed.
As I interpret the above It would appear the first requirement is to do a risk assessment regarding pathogens. I assume this gave a negative result. (And why not indeed !) (or perhaps the choice of ETB was a "compromise" in view of its partial pathogen associations [see below])
Unlike the auditor I do not see any suggestion of criteria so as to discontinue the sampling/testing program. More the opposite (see red above).
IIRC BRC provide a simple decision tree for the user to decide if their Product is high/low risk. Seems a worthwhile route IMO to help guesstimate reasonable sampling procedures / frequencies (cf the non-SQF post 7).
ETB is an indicator test. A positive result for ETB is not regarded as a positive pathogen detection (although it could be). Whether it is more "appropriate" than other indicators, eg APC/Coliform/E.coli measurements is subjective, ie a matter of opinion. Strictly speaking one probably needs more than one of the above-mentioned 4 options to get a meaningful hygiene evaluation. (Y&M might also be a further option for Packaging systems ?)
The limits for Food EMP indicators are typically based on just cleaned/sanitised scenarios or similar criteria.(see the food link in parallel post/thread -
The usual approach to developing monitoring procedures like EMP is to do a Zoning analysis + use a boosted sampling/testing scan-frequency which can then be scaled down if results are adequately "compliant". However a simple production layout should not necessarily need a "full-blown" zoning analysis IMO.
JFI I attach the GFSI Benchmarking Food Packaging Criteria - seems no specific mention of EMP testing Thank you SQF.
GFSI Food Packaging,Benchmarking_Requirements_v7.1_Part3_m.pdf 407.96KB