15 replies to this topic

[mikeq]

Hello to all.  I work for a packaging company.  Make boxes only.  Was curious how anyone in similar situation handled the Environmental Monitoring requirement.  Did you just perform an risk analysis assessment?  Any help would be appreciated.  Thanks,

 

[Charles.C]

Hello to all.  I work for a packaging company.  Make boxes only.  Was curious how anyone in similar situation handled the Environmental Monitoring requirement.  Did you just perform an risk analysis assessment?  Any help would be appreciated.  Thanks,

 

Hi mike,

 

Is there a standard involved  eg BRC etc ?

 

food contact ?

[mikeq]

I work a packaging company.  We make boxes only.  I have an upcoming audit and trying to work on environmental monitoring.  Since we don't make or pack food products.  I would think that this would be very low risk.  I was thinking about doing a risk assessment.  Anyone out there in my business that has perform a risk assessment on environmental monitoring.  I would appreciate any help.  Thanks. 

Edited by Charles.C, 26 April 2020 - 01:36 AM.
moved

[Charles.C]

Hi Mike,

 

No need to make duplicate topics. It causes confusion.

 

I assume you have already read the various existing SQF threads on this topic.

[mikeq]

Charles thanks for the reply.  But I was unable to find anything on what I am looking for that is why I created the post.

Edited by mikeq, 26 April 2020 - 12:03 PM.

[Simon]

What goes in the boxes...food?

Sent from my SM-G950F using Tapatalk

[mikeq]

SQF standard

[mikeq]

dry noodles

[mikeq]

paper board

[Charles.C]

I work a packaging company.  We make boxes only.  I have an upcoming audit and trying to work on environmental monitoring.  Since we don't make or pack food products.  I would think that this would be very low risk.  I was thinking about doing a risk assessment.  Anyone out there in my business that has perform a risk assessment on environmental monitoring.  I would appreciate any help.  Thanks. 

 

Hi mike,

 

From one of yr previous threads (see link below), I deduce your product will eventually be in direct contact with food. This is likely not low risk. (If not direct contact,it likely is categorised as low risk.)

 

https://www.ifsqn.co...nt/#entry158824

 

The SQF expectations for risk assessment/Env. monitoring program (EMPG) may be oriented accordingly (see pdf attached below).

 

As you may have deduced from previous (most recent 2019) SQF packaging threads, there has been considerable uncertainty as to what SQF have expected for EMPG for both  packaging and food. It took SQF a long, long time to issue their Guidance material for Packaging..

 

For SQF the nearest product/posts I could see to yr product were those of Hoosiersmoker (H).. However IIRC the latter's boxes were not direct food contact so probably rated as low risk. "H" appeared to achieve exemption to SQF via a preliminary submitted swabbing program which vaguely correlates to the minimum suggested requirements in SQF Guidance material, ie -

 

 SQF8 Guidance Packaging, clause 2.4.8.pdf   179.05KB   16 downloads

 

So the intended use of your product  may be "critical" . Please confirm.

[Hoosiersmoker]

It's likely low risk as a result of it being dry food only? Yes, risk assessment, if your risk assessment comes back with no or very low risk you might consider requesting an exemption however, if you do simple swabbing and get zero (or very low) count results and don't mind repeating this every year, that is all that is really required for packaging manufacturers. Our exemption apparently requires annual re-submission, which I have never heard of. Our exemption states that if there are no changes to facility, equipment or process, no further action is needed on our part, just the annual review of the risk assessment.

[Charles.C]

It's likely low risk as a result of it being dry food only? Yes, risk assessment, if your risk assessment comes back with no or very low risk you might consider requesting an exemption however, if you do simple swabbing and get zero (or very low) count results and don't mind repeating this every year, that is all that is really required for packaging manufacturers. Our exemption apparently requires annual re-submission, which I have never heard of. Our exemption states that if there are no changes to facility, equipment or process, no further action is needed on our part, just the annual review of the risk assessment.

 

Hi Hoosiersmoker,

 

Packaging not my area however BRC appear to generally consider that  Packaging with direct food contact has "elevated risk". 

 

SQF Packaging Standard lacks clarity IMO but I agree that their Standard seems to focus on the (intended) Product's status.

[mikeq]

I work for a box company that start producing food contact paperboard boxes.  For my environment risk assessment.  Anyone in similar industry.  Did you take swab samples?

Edited by Charles.C, 14 May 2020 - 07:56 PM.
moved, repetition

[Hoosiersmoker]

There being little to no opportunity for the introduction of pathogens into your process (depending on your sources), like us, your swabbing should bear that out. I swabbed areas all over the shop, from regularly cleaned surfaces to infrequently cleaned surfaces and found NO pathogens and used that data as part of the evidence for the exemption we were granted. I attached a sample of the risk assessment. This is just the setu-up, you will fill in areas and machines specific to your operations - gluers, printers, die cutters etc. Hopefully it will help you.

Attached Files

•  Environmental Risk Assessment Example.pdf   653.86KB   23 downloads

Edited by Charles.C, 14 May 2020 - 07:56 PM.
moved

[mikeq]

Hoosiersmoker thanks for the information.  What 3rd party company did you use?  Was it local to your area?

Edited by Charles.C, 14 May 2020 - 07:54 PM.
moved

[Charles.C]

Hi mike,

 

Hope you have finally managed to reach a conclusion.