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2.4.8. Environmental Monitoring - Packaging


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#51 Charles.C

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Posted 12 June 2019 - 12:25 PM

It's a Non-Mandatory element, so I guess if they determine that it does apply to you, you MUST comply with all parts of it and, unfortunately for us, their starting point was that it applies to everyone whether or not it actually does. We were able to demonstrate that our existing efforts and low risk processes adequately eliminate, or reduce to an acceptable level, the risk. I was interested to find that the stated pathogen in (SQF) 2.4.8.3, Bacillus, is not necessarily harmful, it is in fact present in most human digestive tracts naturally and does not typically survive paper making or our printing processes according to a 2015 study: Reference: "Health safety of food contact paper evaluated by in vitro toxicological methods", Adam Vavrouš, Marketa Dvorakova, Kristina Kejlova, Dagmar Jírová September 2015.

 

I do think that elements that are added are added to all codes without proper vetting to determine if they are applicable. I guess the "Shoot first and ask questions later" approach is applied here. Add them and then let the sites prove they are not needed, which is great until it costs someone their certification. It seems to be a somewhat lazy approach on SQF's part.

 

Hi Hoosiersmoker,

 

It may be that SQF have relented somewhat for Packaging rather than Food. Or maybe the number of Complaints has reached a tipping point.

 

Can compare to this recent Foodie one -

https://www.ifsqn.co...ng/#entry140903

 

"Bacillus" is actually the genus. Bacillus spp. references an arbitrary species within the genus.

You are correct that not all Bacillus spp are pathogens. Curiously the parallel clause for food does not contain this sweeping generalisation.


Kind Regards,

 

Charles.C


#52 Hoosiersmoker

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Posted 12 June 2019 - 12:34 PM

I think that's what is happening. They add elements for all codes, food mfg, packaging, distribution, retail etc. then let the sites make arguments for the element's validity instead of trying to determine if the element is applicable before requiring it. They just aren't doing their homework. I know within our cooperative group (all paperboard carton manufacturers) that there has been much head scratching over this.



#53 Charles.C

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Posted 07 August 2019 - 03:20 AM

I think that's what is happening. They add elements for all codes, food mfg, packaging, distribution, retail etc. then let the sites make arguments for the element's validity instead of trying to determine if the element is applicable before requiring it. They just aren't doing their homework. I know within our cooperative group (all paperboard carton manufacturers) that there has been much head scratching over this.

 

Hi Hoosersmoker,

 

Just noticed  from yr recent post in another thread that a preliminary swabbing program was included as part of the justification for applying for exemption.

 

https://www.ifsqn.co...ht/#entry146132


Kind Regards,

 

Charles.C


#54 QC/WC

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Posted 01 September 2020 - 06:09 PM

hello we are a flexible film packaging supplier and we are debating whether or not to test for EB=Enterobacteriaceae or to do regular ATP testing. We are low risk for any pathogens/bacteria according to our hazard analysis but since this is required by SQF standards we must swab and perform/have an environmental testing schedule. I want to scan only for ATP because these results will let us know if there is any living organism present on the surface scanned, this would to include EB because its living, however we will not know exactly what is present on the surface through ATP testing, we will only know that the results show something living is present. A consultant we talked to suggested that we at minimum test for EB as it is an umbrella for many bacterial gut germs found on dirty hands/lack of hygiene so we were going to go through with that but now we find that ATP testing is perhaps most reasonable seeing as how we are low risk anyways and if we find anything living we will send it to a lab and find out what it is then, but EB testing right of the bat seems excessive. Please let me know if other packaging manufacturers only do ATP as well and if this is suitable for the SQF standards for environmental testing for packaging. 






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