Here is the guidance for food manufacturing.....while I understand it's not packaging.....if it works for FOOD then by nature, should also work for food contact packaging
The SQFI website got an update yesterday, but alas, still no guidance for packaging and I cannot even get the code section to load so I cannot have a good look at the language used
However, this is where some of the confusion stems from
"What do I have to do? The process flow is particularly relevant for high risk processes where the product is subject to handling or exposure after a “kill-step.” This includes (refer to 11.7.1) segregation of the post-process end from the raw material end of the process; controlling pedestrian walkways to avoid personnel contamination; dedicated tools and equipment post-process; dedicated staff servicing the post-process end; and dedicated uniforms for staff working post-process. The reference to the environmental monitoring program is self-explanatory, but is worth repeating as it is considered mandatory for areas in which high risk food is processed, handled or exposed. Failure to have an effective environmental monitoring program will result in a major non-conformance.Which is not quite TRUE, the actual requirement is for a RISK ASSESSMENT that covers all possible entry and contamination points. If you perform this portion well and come up with a negligible risk, then I don't understand why you would even perform baseline sampling---particularly in something like plastic extrusion or glass containers.
An environmental monitoring program (EMP) is a program which includes pathogen swabbing to detect risk in the sanitary conditions of the processing environment and is a verification of the effectiveness of the pathogen controls that a management site has in place for high risk foods (refer Appendix 2: Glossary of Terms). Swabbing must include not only the smooth, accessible parts of the process, but also the transfer points, bearings, etc., where product is likely to build up.
Here's some research into packaging and pathogens
So, like any other process, you really need to understand WHAT pathogens you should be concerned with and HOW likely they are to be present on your finished goods BEFORE you even start a risk assessment
SQFI explained to me that the reason this was changed for V8 was that they were seeing alot of really poorly composed risk assessments that were put together in a haphazard way of trying to eliminate swabbing............like the basic risk analysis for a HACCP plan, garbage in, garbage out. You have to be willing and able to be objective and impartial when performing a risk assessment.
The research above all relates to food contact paperboard only.........on a quick scan it seems MOLD is the #1 concern followed by Bacillus spores........so if you have reason to believe you've got bacillus in the plant, then your RA would tell you to swab for it............
Edited by Scampi, 17 October 2018 - 12:36 PM.