Environmental monitoring program for non-food contact packaging

Hello all!

This is the first time I am opening a discussion  :shades: ...

I am looking to create an EMP for a food packaging manufacturing facility. I am not finding very much information (as in none) through my research that truly applies to my facility, however.

Please let me provide some background:

Our facility does make food packaging material, but does not manufacture anything that comes directly into contact with any food. We do however, make materials that you could say are food-contact "adjacent". For example, the outer lidding layer for a yogurt container, but not the foil layer underneath.  For this reason the Quality Manager deemed it appropriate that the facility be SQF certified, both to stay ahead of the game and make it attractive to customers.

Our processes are extrusion, laminating, and slitting. The facility itself is kept regulated for humidity; conditions are dry and warm. We do not introduce any food materials to our production floor. The chemicals we use during processing are abrasive. Material is also further manufactured by our customers through cutting, die cutting, printing, etc.

So my main questions are:

1. What pathogens would you plan to monitor?
2. At what sampling frequency would you monitor after establishing a baseline?
3. Are indicator organisms sufficient to monitor, and THEN proceed with further testing as necessary? 
4. Any other advice you can of for making the plan robust enough for an auditor, but not overkill?

Thank you so much for your thoughts and time in advance.

Hello all!

 

This is the first time I am opening a discussion  :shades: ...

 

I am looking to create an EMP for a food packaging manufacturing facility. I am not finding very much information (as in none) through my research that truly applies to my facility, however.

 

Please let me provide some background:

 

Our facility does make food packaging material, but does not manufacture anything that comes directly into contact with any food. We do however, make materials that you could say are food-contact "adjacent". For example, the outer lidding layer for a yogurt container, but not the foil layer underneath.  For this reason the Quality Manager deemed it appropriate that the facility be SQF certified, both to stay ahead of the game and make it attractive to customers.

 

Our processes are extrusion, laminating, and slitting. The facility itself is kept regulated for humidity; conditions are dry and warm. We do not introduce any food materials to our production floor. The chemicals we use during processing are abrasive. Material is also further manufactured by our customers through cutting, die cutting, printing, etc.

 

So my main questions are:

1. What pathogens would you plan to monitor?
2. At what sampling frequency would you monitor after establishing a baseline?
3. Are indicator organisms sufficient to monitor, and THEN proceed with further testing as necessary? 
4. Any other advice you can of for making the plan robust enough for an auditor, but not overkill?

Thank you so much for your thoughts and time in advance.

Hi Lindg,

Welcome to the Forum (!) and thks for the context although I admit (not a Packaging person) to being slightly uncertain as to yr  "outer lidding layer". I deduce you meant a laminate.

Regarding queries 1-4 et al -

I assume you have already studied the SQF Packaging Codes relevant clauses and their (EMP) Advice ?

The "need" for an EMP program is derived from a risk assessment.

The details of an implemented EMP program are similarly determined, typically through a zoning layout (many refs here to typical food sampling/testing schemes).

This is a "relatively"  new Packaging request  by SQF and there seems to be some uncertainty over their minimum requirements.

Can maybe try this thread (and especially, currently, see Post 53 + it's sublink[>Post6]) covering 1.5 years to get some awareness of SQF's  apparent thought progression  -

https://www.ifsqn.co...ring-packaging/

You can see that currently,  the conclusion may be (eg Post 53) that  you can "maybe" petition for an "exclusion" based on accumulating appropriate  "evidence". However it is not 100% clear how SQF are generally evaluating their requirements.

For implemented EMPs, the SQF requirements also seem "hazy" in that some people are including pathogens, others seemingly (acceptably) not. Offhand, I would have thought the latter option should be acceptable for a non-fcs but only speculation.

Hi Lindg,

 

Welcome to the Forum (!) and thks for the context although I admit (not a Packaging person) to being slightly uncertain as to yr  "outer lidding layer". I deduce you meant a laminate.

 

I assume you have already studied the SQF Packaging Codes relevant clauses and their (EMP) Advice ?

 

Yes to both :thumbup:

 

Can maybe try this thread (and especially, currently, see Post 53 + it's sublink[>Post6]) covering 1.5 years to get some awareness of SQF's  apparent thought progression  -

 

https://www.ifsqn.co...ring-packaging/

 

You can see that currently,  the conclusion may be (eg Post 53) that  you can "maybe" petition for an "exclusion" based on accumulating appropriate  "evidence". However it is not 100% clear how SQF are generally evaluating their requirements.

 

For implemented EMPs, the SQF requirements also seem "hazy" in that some people are including pathogens, others seemingly (acceptably) not. Offhand, I would have thought the latter option should be acceptable for a non-fcs but only speculation.

The thread you provided was very helpful! I agree, however, it is unclear as of yet what the minimum requirements are. The policy has evolved (still evolving I imagine!) *relatively* recently, and the auditors are likely still evolving as well to what they will perceive as permissible. I believe the most logical next step is to gather the information to create a baseline.

Thank you, and take care!!

It might be useful to to spend some money up front to establish what species of bacteria are in the raw materials, in your facility, maybe even on competitor's packaging products.  By identifying what species (including non-pathogens) are potentially around, one can then save money by targeting testing and establishing the testing schedule at monthly or even quarterly. 

That said, if it were me I would also separately swab for the usual pathogenic bacteria in the air conditioning ducts and drain pipes, any infrastructure that hangs over the production line, the underside of the low spots on the roof where leaks could come in, floor drains, those sort of places. This also will pay for itself in the long run by establishing baselines and (hopefully) eliminating locations of concern.

And if I had to guess, I'll bet you find Salmonella somewhere.