I have a question relevant to environmental monitoring...I've been reading through a ton of forums on here about this standard (2.4.8) in SQF Edition 8 and there seems to be a lot of discussion, and dare I say, confusion around it...and I'm one among the many.
So, here's the deal:
We're a dry spices and dry blends "manufacturing" and packaging company. I put "manufacturing" in quotes, because we're not really manufacturing anything. All we do is just bottle spices (and only select few) from the pallet loads of spices we get from our suppliers. We're actually primarily a distribution company. All our spices come in pre-sterilized from our suppliers and have COAs with them.
We have a dedicated packaging room for packaging-of-spices process, which we basically maintain as a clean room with rigorous SSOPs, sterilewear requirements, etc. We have Ecolab supplying us our sanitation products. We ATP swab the food-contact surfaces before and after each packaging run.
Our process is a dry process and facility--in fact water is a no-no for our process. We have 2 drains on the floors of our packaging room and they have caps on them (we can remove the caps for cleaning and sanitation of the room which is done when there is no food around, and just really for mopping).
With regard to RTE, it's tricky because spices can either be an RTE or a non-RTE depending on who the end-user is. Our customers though are generally food manufacturers or food service companies for and my guess is at least 80% of the time most of these spices, especially the ones we package, are going to undergo another kill step (i.e. cooking), but we operate under the assumption that they may not.
Last year we implemented an Environmental Monitoring program, and really our biggest pathogenic risk is Salmonella. However, we included swabbing for Listeria for the drains.
In our most recent swabbing, we got a positive hit for Listeria spp. (not specifically mono) for one of our drains, as drains are to wont to have. We did not get any positive hits for listeria on any other surface though.
Just to be on the safe side though, we cleaned and sanitized the entire room like crazy, and added extra precautions (more quat sanitizers, an additional chlorine cleaning step for the drains specifically), spraying various surfaces with isopropyl alcohol (food contact surfaces, rims of the drains--the ones already with caps on them, shoes--even though we wear boot covers on top) , etc. We also promptly held and sent several products for testing for Listeria and all came back negative (thank goodness!). Of course, after cleaning and sanitizing like crazy, I went on a Listeria swabbing frenzy (of all zones 1-4) and all came back negative, including the ones for the drains (thank goodness!)
Basically, short of burning the building down (which is what I sometimes feel these standards seem to call for! ) , we did whatever we could reasonably do to make sure Listeria wasn't a threat to our products (and it really isn't, given that it's dry spices and low pH).
We have our re-cert SQF audit coming up very quickly in a few days, and I don't know if this is just my pre-audit jitters and stress, but I was hoping the community could help shed some insight as to...:
1) Did we do all the right things in terms of responding to Listeria in the drains? Am I/we missing something? I mean, from what I'm reading it seems basically inevitable and as long as it's contained there (which it is), it should be fine, yes?
2) Since we're a dry environment and our products have a low pH and spices are not likely to foster the growth of listeria mono, my analysis of this risk is actually low. We're just swabbing for listeria in the drains honestly just based on a passing comment from our auditor last year. Anyone disagree or see something I might be missing? i.e. just shed some light on this?
3) I suppose I'm just worried that if our auditor sees a record of a positive hit for listeria in our drains, he's going to freak out, even though we have documentation and measures in place to show that it's controlled for and taken care of...and frankly, not really a risk for our products (I mean for crying out loud, spices were the FIRST food safety mechanisms of antiquity. Just saying!)
Mind you, we're a small business so already SQF, and all of this for the environmental monitoring alone, has costed a pretty penny and a pretty minute...
I can't help but sometimes feel that all of these nit-picky GFSI standards are sometimes ridiculous and unreasonable (i.e. not practical) or are designed to be inhibitory to business (i.e. a big-corporation scheme to crush competition from small businesses, knowing that the latter would have to really stretch thin by way of finances and personnel to meet standards like this). (Sorry, this last bit is a bit rant-y, but it's really frustrating!)
Edited by spiceprincess, 17 June 2019 - 05:21 PM.