7 replies to this topic

[ashleyjongkind]

Hi,

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!

[Charles.C]

Hi,

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!

 

Hi ashley,

 

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 -

 

(1)

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.

https://www.campdenb...RCGS-issue6.php

 

 

Notably from the BRC position statement -

 

(2)

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.

 

(3)

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 -

 

https://www.ifsqn.co...ng/#entry151322

 

and, maybe -

 

https://techni-k.co....onmental-clause

[Charles.C]

Hi ashley,

 

Also see this parallel thread/post -

 

https://www.ifsqn.co...ng/#entry155286

(Thanks Rosemary !)

[ashleyjongkind]

Wow, thank you. All the comments really helped me have a better understanding of what's needed!

By the way, we make thermoformed CPET food trays. (I forgot to mention)

Thanks again!

[ashleyjongkind]

I've attached our procedure for environmental testing. In BRC packaging issue 5 environmental testing was not required.

I'm just still a tad bit confused mostly because the auditor said "do not confuse this requirement with the environmental testing you already perform" well, i did just that, I am confused. LOL

[Adrian Smith]

Hi,  I am also struggling to understand this clause.  We have a risk assessment and if i'm not mistaken, the risk is so low that testing shouldn't be required due to prerequisite programmes we already have in place - is that correct? Or should swab (as an example) testing take place to meet the requirements of this clause?  It's the "Where appropriate" that throws me.  Without that, I would assume key areas such as; surfaces, hands,clothing, would need testing and the frequency should be based on the results?

 

So in essence, do I add a several columns on the end of our risk assessment, that includes; test methods; dates of sampling; results; & corrective action? 

 

regards,

Adrian

[Adrian Smith]

Hi,  I am also struggling to understand this clause.  We have a risk assessment and if i'm not mistaken, the risk is so low that testing shouldn't be required due to prerequisite programmes we already have in place - is that correct? Or should swab (as an example) testing take place to meet the requirements of this clause?  It's the "Where appropriate" that throws me.  Without that, I would assume key areas such as; surfaces, hands,clothing, would need testing and the frequency should be based on the results?

 

So in essence, do I add a several columns on the end of our risk assessment, that includes; test methods; dates of sampling; results; & corrective action? 

 

regards,

Adrian

[Charles.C]

I've attached our procedure for environmental testing. In BRC packaging issue 5 environmental testing was not required.

I'm just still a tad bit confused mostly because the auditor said "do not confuse this requirement with the environmental testing you already perform" well, i did just that, I am confused. LOL

 

Hi ashley,

 

You probably need to post yr risk assessment + auditor's actual comment/NC to get a (more) definitive answer.

 

I think the auditor may have meant that yr risk assessment was ok as stated (ie as per its use of non-pathogens) but incomplete due its missing consideration of either any pathogens or perhaps which specific pathogens (yr OP is unclear). (This "detail" is sort of haccp 101 IMO although some published hazard analyses seem to disagree).

(in this respect Rosemary's auditor was seemingly less rigorous).

 

@Adoqpc - as in food manufacturing this is handleable by risk "zoning" (eg see post linked below [although much wider zones are feasible IMO]) although the specific methodology is optional -

https://www.ifsqn.co...ng/#entry155448

Edited by Charles.C, 11 February 2020 - 07:37 AM.
edited