We provided our CB with the attached Environmental Monitoring Risk Assessment. They were satisfied with this for our NC.
Thanks for the examples.
I assume the dry "beans" = mung beans. If otherwise some comments may be inaccurate.
I also assume the input is microbiologically more or less as "from the source".
"Beans" not my area of expertise but offhand, IMO, you may have been lucky with yr appointed auditor, eg -
(a) IMO the EMPG is, safety-wise, primarily about verifying the control/prevention of cross-contamination rather than growth.
(b) L.monocytogenes not mentioned as a potential environmental contaminant.
(c) afaik 0.85 is the current FDA safety cut-off for pathogen growth/water activity (albeit based on S.aureus).
(d) Personnel not mentioned as potential vectors of contamination.
(e) Micro. Validation/Verification Studies only one time per year, based on Salmonella only.
(f) The "kill" time quoted for Salmonella (5log reduction?) looks improbable for, say, mung beans (eg Campden,2014).
(g) The "clostridium botulinum" referred maybe requires an additional tag as to type, eg A, E etc).
(h) The statement "pathogens are not a concern" (due to subsequent processing) may well be product/haccp-wise valid but, if the occurrence is due to environmental cross-contamination, it implies a failure of the cleaning/sanitising program.
Regardless, appreciate your uploading.
Edited by Charles.C, 01 October 2019 - 11:58 AM.