If your products are enclosed in the production area then environmental monitoring is stil required but clearly there is less risk than in 'open and RTE product' production areas.
BRC Standard & Guidance:
4.11.8 ENVIRONMENTAL MONITORING
Risk-based environmental monitoring programmes shall be in place for pathogens or spoilage organisms.
At a minimum, these shall include all production areas with open and ready-to-eat products.
The aim of the environmental monitoring programme is to identify any potential risks in the production and open-product areas so that they can be appropriately managed and prevented from becoming the source of product contamination (which could lead to non-conforming product, a customer complaint or other incidents).
An effective programme can, for example, be used to:
• confirm the effectiveness of cleaning and hygiene activities and identify any areas that require further activity
• prevent product contamination by acting as an ‘early warning’ – identifying potential contamination from the site facilities before they affect products.
Risk-based environmental monitoring programme
The programme must be based on risk assessment. At a minimum this will include:
• a sampling protocol. It is important to ensure that the sampling method does not inadvertently create false positives (e.g. by allowing post-sampling contamination or growth of organisms) or false negatives (e.g. by killing organisms in the sample before the test is completed). Sampling must be appropriate for the target organisms, test methods and locations sampled; techniques may include swabs, air sampling, water/liquid samples etc.
• identification of suitable test locations, taking into account:
– significance of the area or equipment in terms of the potential to affect food safety; for example, food contact surfaces, non-food contact areas which are in close proximity to open products, and nonfood contact areas some distance away from open products (e.g. floors, walls and drains)
– areas or parts of equipment that are difficult to clean and could harbour pathogens
– areas of the site or equipment which previously tested positive
– areas where scientific literature has identified a specific risk (e.g. drains)
• frequency of tests, taking into account:
– products that support the growth of pathogens. These require a greater frequency of testing than those that do not support growth
– locations with previous positive results or an upward trend towards an action level (clause 188.8.131.52). These are likely to require increased testing to confirm the effectiveness of the action taken
• target organisms. These may include specific pathogens that present a risk to the product or environment (e.g. Listeria spp in wet environments or Enterobacteriacae in dry environments), specific spoilage organisms (e.g. yeast or mould) or indicator organisms (e.g. total plate count, total coliforms)
• test methods. Rapid on-site and laboratory tests are available, and sites should consider the requirements of section 5.6 when deciding which methods and/or laboratories to use
• evaluation of results. The significance of the results and any actions required must be considered (clause 184.108.40.206).