We recently completed our BRC Food Packaging Audit (issue 5).
We received and A grade but we had a minor finding for not completing the risk assessment for P558 position statement for environmental testing.
I'm having a little trouble with this. The auditor said not to confuse this with the risk assessment I already have for environmental testing that we already do. We test packaging area, hands and clothes for APC, yeast and mold.
We are a manufacturer of CPET food trays for the ready to eat market.
The auditor also said the packaging we produce is very unlikely to cause any harm. Really we should just exclude ourselves from this additional environmental testing through the risk assessment.
I'm not a food microbiologist so i know very little about what type of pathogens i would need to include on this risk assessment.
Does anyone have any recommendations on how to close this non-conformance?
Thanks in advance!
You omitted to mention what yr product/process is ??
I deduce the auditor's criticism was that you omitted to include any mention/assessment of potential microbial safety hazards ? (ie clause 4.8.5)
Some literature comments -
As packaging is produced through a substantial thermal or chemical process, the raw materials should not be able to transfer microorganisms to the final product. Therefore, the microorganisms that would be sampled for are those that have been introduced from the environment, rather than having been there in the first place. These organisms can potentially contaminate the packaging and therefore pose a risk of contamination to the food product. So, we should be testing for what allows microorganisms to contaminate the processing environment and packaging product: personnel, surfaces, water and air.
Notably from the BRC position statement -
Most packaging materials are unsuitable for the survival and growth of pathogens and therefore will not require an environmental monitoring programme to be in place.
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)
(Actually BRC's text above is inaccurate since "Listeria", Enterobacteriaceae are not specific pathogens ! )
From a quick look in the Literature, the most commonly (albeit infrequently) referred (specific) potential environmental pathogens for Food Packaging Production seem to be S.aureus, L.monocytogenes, Salmonella spp.
I deduce the auditor (implicitly) accepted that yr product complies with the second quoted comment above so that the latter then offers a direct exclusion route to testing for any of the 3 species noted above.
If you would like to see some previous comments/links on this topic, can try this post/thread -
and, maybe -