Help me understand environmental monitoring for a NOT-RTE processing environment? I have loaded list of questions.
1. What exactly is the purpose?
Is it verifying hygienic zoning? is it validating sanitation practices? Is it proving a sterile environment? Stroking the GFSI ego? Selling swabbing kits? All ranting aside it is clear that I will have to do this thing so I need to know the PRIMARY objective so that it can be done properly.
Process Haccp requires risk assessment. The risk assessment includes hazards from the environment. A significant hazard (or associated PRP) requires monitoring.
2. What kind of repercussions am I inviting by swabbing for indicator organisms in an environment that will likely have some level of contamination, after all we are washing dirt off of roots in this environment (its not going to be hygienic). What do I have to react to exactly? Do I have the leeway to survey for a period of time and then set my own action levels. Is it okay to accept a baseline pathogen load?
Covered via surface swabbing micro. standards/guidelines. Detailed elsewhere in forum. eg -
On a related note - is zone 1 really zone 1 prior to a kill step? I'm not saying that it is okay for raw material processing surfaces to be filthy, but we can't honestly expect to find them sterile can we?
depends on definition of zone 1
3. Can I limit the swabbing to only certain areas within the facility or even within the supply chain? We create a WIP item in our own facility but the final product is packaged at another location (all of it prior to kill step). Would an EMP at the final packaging site be sufficient?
Covered via Scope of haccp plan / Risk Assessment / Sampling Plan.
I maybe understand at some level the value of EMP but I also fear that it is opening up a Pandora's box for a facility in which field debris is being washed from roots. I also don't understand the logic of taking EMP to that level, once you pass the kill step where do you stop, the field? Do we need to be sanitizing dirt?
We are likely hiring a consultant to set this up but I am really curious what the community has to say.
Thanks in advance
Additionally, Regulatory Requirements, if any, would prioritize.