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#1 00half

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Posted 18 July 2018 - 07:46 PM

Greetings everyone,

 

I am preparing for our Audit at the end of the month and came across the 2.4.8 Environmental Monitoring section in module 2.  From everything I have looked up and read, plus with the implementation notes, this section seems to be a bit redundant in regards to the HACCP plan we already have in place. 

 

Am I wrong?  What are the major differences between the two?  Does anyone have any examples of an Environmental Monitoring Program that they have used in the past? 

 

Just looking for some guidance in developing a plan, or just trying to see if it is even necessary at all if we already have a Food Safety HACCP Plan in place.  Our facility only deals in food packaging manufacturing so we have no food stuffs in our facility ever.

 

 Thank you



#2 Scampi

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Posted 18 July 2018 - 08:02 PM

Do you mean SQF? not FSSC?


Because we always have is never an appropriate response!


#3 Charles.C

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Posted 18 July 2018 - 08:14 PM

Do you mean SQF? not FSSC?

 

Based on previous posts, you are probably correct.

 

@oohalf

Am I wrong?  What are the major differences between the two?  Does anyone have any examples of an Environmental Monitoring Program that they have used in the past?

 

two = ? ie redundant how ?

 

IIRC there are 2-3 recent threads here on EMP/Packaging/SQF


Edited by Charles.C, 18 July 2018 - 08:27 PM.
moved, expanded

Kind Regards,

 

Charles.C


#4 00half

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Posted 18 July 2018 - 08:16 PM

Do you mean SQF? not FSSC?

Oh no, I totally wasn't paying attention, I do mean for SQF sorry :(


Edited by Charles.C, 30 July 2018 - 09:11 PM.
thread moved to SQF


#5 00half

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Posted 18 July 2018 - 08:24 PM

Based on previous posts, you are probably correct.

 

@oohalf

two = ?

 

IIRC there are 2-3 recent threads here on EMP/Packaging/SQF

The two being Environmental Monitoring Program and the HACCP Plan



#6 00half

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Posted 18 July 2018 - 08:27 PM

I will repost this in the SQF section if necessary



#7 Scampi

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Posted 19 July 2018 - 01:17 PM

So i don't have the packaging module in front of me, but if it is listed as MANDATORY in the packaging module then it is mandatory that you prepare a risk assessment but NOT mandatory that you swab if your assessment says the risk is low

So if you already have an EMP in your plan, all you need is the risk assessment to back it up

 

if not, then a risk assessment that says it's not required for your product/facility


Because we always have is never an appropriate response!


#8 clrmwebb4350

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Posted 26 July 2018 - 04:29 PM

Greetings! I too am struggling with this section on environmental monitoring. Any input is appreciated! My company manufactures valves, covers, pistons etc for the food industry (mainly dairy.)

 

I actually thought we were covered with air, water, and monthly microbiological testing of our valves until I read this thread. So what I have  gathered so far, is that I need to:

 

1) Do a HACCP analysis to determine risk

2) Conduct swabbing for Salmonella and Listeria

3) I will need a zoning map and written plan 

4) Sampling to be done  weekly? monthly?

5) Reaction plan for positive findings.

 

Also create a PEM team. Am I missing anything? Can anyone confirm that we actually do need to do this even though my company does not hold, store, process or manufacture any food ingredients? Many thanks!



#9 Scampi

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Posted 30 July 2018 - 04:18 PM

re-read the section of the code........for food processing only the risk assessment is mandatory and that determine IF you have an EMP


Because we always have is never an appropriate response!


#10 clrmwebb4350

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Posted 31 July 2018 - 02:38 PM

​SQF 8 Food Packaging code

 

2.4.8 Environmental Monitoring
2.4.8.1 A risk-based environmental monitoring program, for known or expected concerns, shall be in place for
all processes in the manufacture of food packaging.
2.4.8.2 The responsibility and methods for the environmental monitoring program shall be documented and
implemented.
2.4.8.3 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.
2.4.8.4 Environmental testing results shall be monitored and corrective actions (refer to 2.5.3.1) implemented
where unsatisfactory trends are observed.



#11 Scampi

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Posted 31 July 2018 - 03:36 PM

ok, but in the manufacturing code it DOES NOT say (mandatory) beside the section header

2.4.8 Environmental Monitoring
2.4.8.1 A risk-based environmental monitoring program shall be in place for all food and pet food manufacturing
processes.
2.4.8.2 The responsibility and methods for the environmental monitoring program shall be documented and
implemented.
2.4.8.3 An environmental sampling and testing schedule shall be prepared, detailing the applicable pathogens or
indicator organisms to test for that industry, the number of samples to be taken and the frequency of sampling.
2.4.8.4 Environmental testing results shall be monitored and corrective actions (refer to 2.5.3.1) implemented
where unsatisfactory trends are observed
 
Like it does for this
 
2.5.1 Validation and Effectiveness (Mandatory)
2.5.1.1 The methods, responsibility and criteria for ensuring the effectiveness of all applicable elements of the
SQF Program shall be documented and implemented. The methods applied shall ensure that:
i. Good Manufacturing Practices are confirmed to ensure they achieve the required result;

 

 

So double check your code, if it does not say mandatory, you need only produce the risk assessment that will explain why you are NOT performing an EMP


Because we always have is never an appropriate response!


#12 clrmwebb4350

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Posted 31 July 2018 - 04:14 PM

Scampi,

I agree it is not mandatory but how do I justify not having a EMP program ? Should I swab and see what the results are? 



#13 Scampi

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Posted 31 July 2018 - 04:31 PM

No, you need to perform a risk assessment (micro hazards that may be present against any PRPs and/or kill steps that the material is exposed to) that is specific to your plant, process, geographic area etc

 

For example, my FG has a e coli and salmonella risk inherent in my ingredients, but my FG undergoes a very intensive kill step plus pH values that is validated to kill all the pathogens of concern ergo, an EMP for me is a redundant expense

 

So you need to understand your pathogens of concern (if any), and how they may be controlled

 

You can swab, be also swab your FG and really understand your process and what pathogens may be in your environment.....if your risk assessment is not robust enough, you run the risk of a non conformance for not having performed the RA as well as you should have


Because we always have is never an appropriate response!


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#14 clrmwebb4350

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Posted 31 July 2018 - 04:36 PM

Thank you for the clarification. I will do the risk assessment and see where that leads me. I think you are correct though and my risk should be low. 



#15 Charles.C

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Posted 31 July 2018 - 06:27 PM

 Also see this thread -

 

http://www.ifsqn.com...ng/#entry121131


Kind Regards,

 

Charles.C





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