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Environmental Monitoring 2.4.8 Low Risk RAW shelled nut facility


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Sabear

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Posted 24 April 2018 - 08:33 PM

We currently do not have an EMP set up. We are a low risk RAW shelled nut facility. We have no kill steps as our product must go for further processing. So we do not control salmonella (know risk for raw peanuts). Looking at the guidance document 2.4.8.1 states "A risk-based environmental monitoring program shall be in place for all food and pet food manufacturing processes."

But if you look at the "what do I have to do" it states this is mainly for high risk processes, or for processes that have a kill-step.

 

Currently, we just let our customers know that we do not control this.

 

Just looking for guidance on what to do, or what others have done with a similar process.

The only testing we do is yearly on the water and air in the facility.

 

We had the SQF 8.0 Audit earlier this year and the auditor didn't mention us not having one. But they were pretty focused on other areas we came up short.

 



Tavish101

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Posted 25 April 2018 - 01:56 AM

We just had our desk top audit and received a Major Nonconforming for not having a program either-we are considered low risk based on our suppliers and dry blending. We will be now using AccuClean to test for proteins. 



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FurFarmandFork

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Posted 25 April 2018 - 02:34 PM

But if you look at the "what do I have to do" it states this is mainly for high risk processes, or for processes that have a kill-step.

 

 

That may mean you have a less robust program since you are not high risk. However, the guidance is explicit: 

 

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..Failure to have an effective environmental monitoring program will result in a major non-conformance.

 

 

Key word is effective. It doesn't need to look like one from a high risk environment in terms of corrective actions, but you should not be harboring known pathogens (e.g. salmonella) in your facility even if the product is "raw". Frankly, any nut manufacturer that isn't taking salmonella contamination seriously just because they're going to be roasted downstream isn't giving enough credit to recent nut-associated outbreaks.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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Sabear

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Posted 25 April 2018 - 05:59 PM

Thank you both for your input. I wanted to bring it up with the big boss, and this information will help me persuade them into having this done. As the next audit might point this out since we've fixed the other NC we received.

Does anyone have an recommendations or advice on the frequency we should start testing to establish a baseline? Or perhaps a template for how they carry out their EMP.



FurFarmandFork

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Posted 25 April 2018 - 10:32 PM

Generally monthly is a pretty standard non-robust program. Start with zone 2 areas and move out from there. The key is that your program should be based on the fact that the listeria may be coming from your PRODUCT, which means that your program goal is not to eliminate it from the product, but to make sure that your product does not "seed" biofilms in your manufacturing areas so that listeria is then always contaminating the product.

 

To the point:

 

In a raw product listeria coming in>expected, can't control

In raw products leaving your facility, listeria it came with is expected, listeria you added is not acceptable and should be controlled.

 

Similar philosophy to refrigerating raw meats, just because you're going to cook them later doesn't mean you don't have to refrigerate them and can leave them on the floor for later, you need to ensure that downstream kill steps (5 log reductions or higher) are going to actually be effective, and you don't end up putting out so much contaminated product that it overwhelms the kill step, and fingers your facility as the issue.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

Charles.C

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Posted 26 April 2018 - 03:02 AM

Hi Sarah,

 

Some standard texts on the topic (especially the GMA ones) are here -

 

http://www.ifsqn.com...am/#entry119334

(env 6,7,8)

 

http://www.ifsqn.com...ls/#entry100060

(env2)


Kind Regards,

 

Charles.C


idealdreams

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Posted 30 April 2018 - 06:33 PM

The code says a risk-based environmental monitoring program must be in place. Salmonella, like you mentioned, is a known hazard in raw peanuts, but if you're not roasting them (or using some other thermal kill step), then you are correct - per FSMA, you would need to notify your customers that the product is not roasted or treated and it is their responsibility to control the hazard in their own way.

 

This doesn't mean you don't need any environmental monitoring program, it means the program you have in place can be a little less robust, based on a risk assessment. For example, assessing employee hygiene - do you require your employees to change/sanitize footwear, don new PPE, etc., before handling raw nuts to avoid contamination with other environmental pathogens? Just because you're not controlling the potential salmonella hazard in your raw nuts doesn't mean your personnel can wear filthy soiled footwear into your facility, right? So in your case, a part of your environmental monitoring could be observing your employee's hygiene routinely or could even be swabbing for other pathogens, such as Listeria, on a routine basis.

 

There are many factors to consider, and the robustness of your EMP will be based on those factors (i.e. the risks). Just because you're low risk doesn't mean you can get away without an EMP. You still need one, it just doesn't need to be as robust as another manufacturer's would, say, if they do roast their nuts to control salmonella.

 

Good luck!



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