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 22.214.171.124 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.