Microbiological Environmental Monitoring Programme For Plastic Bottles

Dear Experts 

We are Manufacturing HDPE Plastic Bottles Used for Non-Food Packaging. We are certified to BRC ISSUE 5* and Our next BRC audit is scheduled in Nov-20. 

We are performing Swab test which is outsourced for our Bottles Inside and Outside and Workers Uniform.

Now as per 4.8.5 Clause what else we need to do, We do not have inhouse Microbiological Testing Facilities?

Best Regards

Javed

SAUDI ARABIA

*added by Charles.C,071020, presumably a typo. should be 6.

what are you swabbing for now?

what are you swabbing for now?

Don't you think swabbing bottles for micro is redundant? Bacteria don't grow on dry surfaces, they need moisture media to feed & grow. Well, unless BRC requires that, which I doubt...

Don't you think swabbing bottles for micro is redundant? Bacteria don't grow on dry surfaces, they need moisture media to feed & grow. Well, unless BRC requires that, which I doubt...

Olenazh, We got NC against the Clause 4.3.2 Based on Risk Assessment, the Microbiological and Chemical Quality of Water, Steam, Ice, air, Compressed air or other gases which comes into direct contact with Packaging shall be regularly monitored. These Shall present no Risk to Product Safety or Quality and Shall Comply with relevant legal regulation.

The Air used to Blow Plastic Bottles cannot be tested for Microbiological test but as it comes in direct contact to the bottles so we are doing Microbiological test for Bottles. 

Olenazh, We got NC against the Clause 4.3.2 Based on Risk Assessment, the Microbiological and Chemical Quality of Water, Steam, Ice, air, Compressed air or other gases which comes into direct contact with Packaging shall be regularly monitored. These Shall present no Risk to Product Safety or Quality and Shall Comply with relevant legal regulation.

 

The Air used to Blow Plastic Bottles cannot be tested for Microbiological test but as it comes in direct contact to the bottles so we are doing Microbiological test for Bottles. 

Even if it's Non-Food Packaging? BTW, if it's non-food, how it relates to Food Safety? 

Even if it's Non-Food Packaging? BTW, if it's non-food, how it relates to Food Safety? 

The Bottles are Used for Personal Hygiene Products. 

Don't you think swabbing bottles for micro is redundant? Bacteria don't grow on dry surfaces, they need moisture media to feed & grow. Well, unless BRC requires that, which I doubt...

My company just got a preaudit check. The new auditor didn't believe on that red text. We only had total 6 CFU/100cm2 in the latest test of our products but he said we must monitor the environment (surfaces which are frequently cleaned by organic solvents and no processing water exists) no matter what.

Even I showed BRC's p558 (2019) saying "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.", but he denied because BRC Issue 6 Guideline doesn't have such quote.

On the whole I would agree that swabbing the inside of the bottle is not needed based on the fact that the plastic will have been heated and melted at a fairly high temperature ( I don't know which polymer you use but most will be above 110C)

The air for blowing is a more likely source. If you have microbiological grade filters on your airlines, ideally at point of use, an occasional test on the air quality should suffice.

The red text in the earlier post is debatable. Bacterial vegetative growth may be unlikely in dry conditions, but they may survive, eg through spore formation and that is what the clause states.

If covid has taught us anything we know that viruses will survive on plastic packaging.

Unless I'm reading the NC incorrectly it applies to the sources of air, water, etc that come into contact with the bottle, not the bottle itself.  With that, I would focus on those sources versus testing the bottles specifically.  If you can show and prove the sources do not contaminate the bottle then there is no need to test the bottle.

If you wish to test the bottles I would recommend you work with a laboratory near you and send them the bottles for testing.  As Foodworker mentioned, you can have spores survive, or bacteria remain dormant on the surface.

However, if I were in your position my focus would be all the elements / sources that contact the bottle during the manufacturing process.

This thread is scrambled from diverse inputs/different related clauses, ie 4.8.5 (environmental related), 4.3.2 (non-environmental related), x.x (unknown)

Few Comments -

Post 5 - air can be tested. various threads here detail such.

Post 6 - BRC Packaging Standard's scope includes Cosmetics et alia

Post 8 - Change yr intended auditor if they cannot accept BRC's own publications. Previous threads here validate the quotation's auditorial applicability for Food Packaging.

Post 9 - IIRC, an earlier thread here demonstrated that the effective survival time for Covid-19 on specified packaging was very short.

To recap p558 -

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.

Regrettably, afaik, BRC did not elaborate on "most" however previous reported experiences here suggest that for specified Food Packaging  a program based on Enterobacteriaceae / Y&M  may be acceptable to BRC if a "low risk" scenario can be presented/justified.