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Risk Assessment to exclude Environmental Monitoring Program (EMP)

EMP Environment

Best Answer Scampi, 18 October 2018 - 12:40 PM

Well in my pre-assessment my auditor just told me in the report to do a risk assessment, she never mentions to do a few rounds of environmental testing, we low risk and we don't handle food. so I think a risk assessment could be fine. Let's see where folk's inputs goes!

  

 

So Jean, I would put a good RA together and forget the swabbing IF your RA deems it unnecessary, according to the code and SQFI only the RA is.....

 

"Environmental monitoring is not a mandatory requirement so exemption by a risk assessment is allowed.

 

Please let me know if you need further clarification or have additional questions.

 

All the best, LeAnn Chuboff"

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#26 Jean Carmona

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Posted 18 October 2018 - 05:39 PM

I am just starting to set up my organization's SQF Program and visited one of our sister plants this week regarding how they're currently maintaining their program - They recieved two excellents in a row. I asked about EMP and the Quality Manager stated that they perform random micro tests on finished goods product to prove that all their programs are working, in addition, this is also how they validate. An operation risk management assessment is also completed for this process. They have not had their audit on Ed. 8 yet, but I'll reply to this thread sometime in December after their audit if this sufficed the EMP.

 

Awesome Julie, Thanks! 



#27 Scampi

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Posted 18 October 2018 - 06:15 PM

an EMP isn't supposed to be performed on FG, it is for the plant itself where harbor points could affect the safety of your product.........so this will be a good one to get feedback from!

 

from the guidance

 

What does it mean? 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. This element outlines the specific conditions required in areas where foods are processed or handled. Conditions like these may contain pathogenic microorganisms and will support the formation of toxins or growth of pathogenic microorganisms, and has a likelihood of growth causing illness or injury to a consumer if not properly produced, processed, distributed and/or prepared for consumption. It may also apply to a food that is deemed high risk by a customer, declared a risk by the relevant food regulation or has caused a major foodborne illness outbreak (refer SQF Code, Appendix 2: Glossary).


Because we always have is never an appropriate response!


#28 Charles.C

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Posted 18 October 2018 - 08:32 PM

It's amazing how so much confusion can be generated regarding something which most (Packaging) people seem to agree is almost always of minimal risk towards Food Safety.

 

SQF,  you have a lot to answer for !. And seemingly so far very little official response ?


Kind Regards,

 

Charles.C


#29 Scampi

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Posted 19 October 2018 - 12:57 PM

I have to say Charles.......I've read through ALOT of manuals over the years.........and SQF is one of the WORST

 

Part of me (a very very very small part) feels bad for the auditors..........like this EMP, code says a MAJOR for not having a plan..............but the guidance says nope, that's not right.........

 

The "technical managers" and i'm using that term lightly should be raising their collective voices and saying this isn't right

 

At least government regulations get reviewed repeatedly by lawyers so at the VERY least the intent is clear..............maybe these GFSI folks might want to think about adding a lawyer or two to the mix when codes are being revised.............but then they wouldn't have to force us to change every year when they issue another revison because "we're sorry, we didn't get it right the first time"


Because we always have is never an appropriate response!






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