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SQF 2.4.8 Environmental Monitoring for Packaging Manufacturers


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#1 QC/WC

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Posted 01 September 2020 - 06:11 PM

Hello we are a flexible film packaging supplier and we are debating whether or not to test for EB=Enterobacteriaceae or to do regular ATP testing. We are low risk for any pathogens/bacteria according to our hazard analysis but since this is required by SQF standards we must swab and perform/have an environmental testing schedule. I want to scan only for ATP because these results will let us know if there is any living organism present on the surface scanned, this would to include EB because its living, however we will not know exactly what is present on the surface through ATP testing, we will only know that the results show something living is present. A consultant we talked to suggested that we at minimum test for EB as it is an umbrella for many bacterial gut germs found on dirty hands/lack of hygiene so we were going to go through with that but now we find that ATP testing is perhaps most reasonable seeing as how we are low risk anyways and if we find anything living we will send it to a lab and find out what it is then, but EB testing right of the bat seems excessive. Please let me know if other packaging manufacturers only do ATP as well and if this is suitable for the SQF standards for environmental testing for packaging. 

 


#2 olenazh

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Posted 01 September 2020 - 06:22 PM

I hope, somebody from packaging industry will reply, as it's quite interesting: I was always sure that dry surfaces don't support any micro growth, and have done pretty many tests as per customer requests (I swabbed plastic cups, lids, bottles for TC & E. Coli) Those tests always came back negative. So having said that, I'm just curious: if there's no micro on dry surfaces, including plastic films, why you still have to do it? Simply comply with SQF requirements?



#3 QC/WC

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Posted 01 September 2020 - 06:51 PM

I hope, somebody from packaging industry will reply, as it's quite interesting: I was always sure that dry surfaces don't support any micro growth, and have done pretty many tests as per customer requests (I swabbed plastic cups, lids, bottles for TC & E. Coli) Those tests always came back negative. So having said that, I'm just curious: if there's no micro on dry surfaces, including plastic films, why you still have to do it? Simply comply with SQF requirements?

 

yes, we have to do it only for SQF requirements. 



#4 SQFconsultant

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Posted 01 September 2020 - 11:19 PM

".yes, we have to do it only for SQF requirements. "

 

Been in SQF consulting for 12 years, most of our packaging clients that are SQF are not doing this -- just because something is a "requirement" doesn't make it a mandatory - run risk assessments, look at your past results, has anything come up?  If no, document that and request an exemption.  Just contact your CB.

 

I think I just saved you some money and I was not that consultant you talked too. :) 


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#5 Timwoodbag

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Posted 02 September 2020 - 01:22 PM

Everyone I have encountered so far agrees that for SQF you need an Environmental Monitoring Program, but you do not need swabbing to be a part of the program unless you are a high-risk product.  We monitor Temp and Humidity in storage, we do moisture content testing on Green Coffee Beans, but have never swabbed.  Just scored a 97 this past week!!



#6 QC/WC

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Posted 02 September 2020 - 04:41 PM

".yes, we have to do it only for SQF requirements. "

 

Been in SQF consulting for 12 years, most of our packaging clients that are SQF are not doing this -- just because something is a "requirement" doesn't make it a mandatory - run risk assessments, look at your past results, has anything come up?  If no, document that and request an exemption.  Just contact your CB.

 

I think I just saved you some money and I was not that consultant you talked too. :) 

thank you for your feedback. According to our risk analysis we are at low risk so that's why we feel we should do micro testing and we plan to do it quarterly at the beginning to have the data to prove our low risk and then phase into only annual testing. With that said is ATP testing okay for us? 



#7 QC/WC

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Posted 02 September 2020 - 04:42 PM

Everyone I have encountered so far agrees that for SQF you need an Environmental Monitoring Program, but you do not need swabbing to be a part of the program unless you are a high-risk product.  We monitor Temp and Humidity in storage, we do moisture content testing on Green Coffee Beans, but have never swabbed.  Just scored a 97 this past week!!

what is the product that you guys make/produce? we are in packaging. how did you get out of micro testing? Did you ask for an exemption ? how did you know the best route to take. 



#8 Sharon (Dewsbury)

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Posted 03 September 2020 - 10:38 AM

Hi 

We are food packaging manufacturers . We are high hygiene, BRC certified , printed carton board for food contact. We are not SQF Certified.

BRC gives the option to justify Environmental Monitoring EM (or not) by Risk Assessment. Check the SQF clause for the actual detail of the requirement.

We spoke to raw material suppliers, considered the chemicals and temperatures during processing of raw materials and our product, also looked at , storage, temps, historical findings, a literature search on line etc and concluded that the risk was very low and EM was not necessary.

We found studies on line that showed our raw materials actually suppressed growth of microorganisms due to the processing, the absorption of the material and the chemicals used. So as long as you have GMP the risk should not become significant.



#9 ARKotulak

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Posted 03 September 2020 - 02:18 PM

We did micro testing for years over several different manufacturing plants, raw material and finished product. The results were always negative. Based on this years of data, and the inherently low risk for packaging, we stopped performing the testing. We completed a risk assessment and applied for an exemption with the CB. The CB issued a letter that we show to the auditor during the audits. This CB audits ~35 of our plants.



#10 Charles.C

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Posted 03 September 2020 - 03:40 PM

hello we are a flexible film packaging supplier and we are debating whether or not to test for EB=Enterobacteriaceae or to do regular ATP testing. We are low risk for any pathogens/bacteria according to our hazard analysis but since this is required by SQF standards we must swab and perform/have an environmental testing schedule. I want to scan only for ATP because these results will let us know if there is any living organism present on the surface scanned, this would to include EB because its living, however we will not know exactly what is present on the surface through ATP testing, we will only know that the results show something living is present. A consultant we talked to suggested that we at minimum test for EB as it is an umbrella for many bacterial gut germs found on dirty hands/lack of hygiene so we were going to go through with that but now we find that ATP testing is perhaps most reasonable seeing as how we are low risk anyways and if we find anything living we will send it to a lab and find out what it is then, but EB testing right of the bat seems excessive. Please let me know if other packaging manufacturers only do ATP as well and if this is suitable for the SQF standards for environmental testing for packaging. 

 

Hi qc/WC,

 

Unfortunately the assumed correlation in above between bacteria and ATP is basically unsound. This is frequently spelled out in ATP texts.

 

Previous SQF threads here indicate variability in SQF's auditorial expectations regarding the nature and depth of environmental testing for food / food packaging. Seems to be a case of  do the risk assessment then Suck it and See !


Kind Regards,

 

Charles.C


#11 Timwoodbag

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Posted 08 September 2020 - 12:31 PM

what is the product that you guys make/produce? we are in packaging. how did you get out of micro testing? Did you ask for an exemption ? how did you know the best route to take. 

 

Hello, we are Coffee Roasters, so about as low risk as it gets.  However, we nitpick the guidance and call upon industry standards to argue our stance on not swabbing anything.  

 

What do I have to do?

The process flow is particularly relevant for high risk processes where the product is subject to handling or exposure after a “kill-step.” This includes (refer to 11.7.1) segregation of the post-process end from the raw material end of the process; controlling pedestrian walkways to avoid personnel contamination; dedicated tools and equipment post-process; dedicated staff servicing the post-process end; and dedicated uniforms for staff working post-process. The reference to the environmental monitoring program is self-explanatory, but is worth repeating as it is considered mandatory for areas in which high risk food is processed, handled or exposed. Failure to have an effective environmental monitoring program will result in a major non-conformance. An environmental monitoring program (EMP) is a program which includes pathogen swabbing to detect risk in the sanitary conditions of the processing environment and is a verification of the effectiveness of the pathogen controls that a management site has in place for high risk foods (refer Appendix 2: Glossary of Terms).



#12 Charles.C

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Posted 08 September 2020 - 03:12 PM

Hello, we are Coffee Roasters, so about as low risk as it gets.  However, we nitpick the guidance and call upon industry standards to argue our stance on not swabbing anything.  

 

What do I have to do?

The process flow is particularly relevant for high risk processes where the product is subject to handling or exposure after a “kill-step.” This includes (refer to 11.7.1) segregation of the post-process end from the raw material end of the process; controlling pedestrian walkways to avoid personnel contamination; dedicated tools and equipment post-process; dedicated staff servicing the post-process end; and dedicated uniforms for staff working post-process. The reference to the environmental monitoring program is self-explanatory, but is worth repeating as it is considered mandatory for areas in which high risk food is processed, handled or exposed. Failure to have an effective environmental monitoring program will result in a major non-conformance. An environmental monitoring program (EMP) is a program which includes pathogen swabbing to detect risk in the sanitary conditions of the processing environment and is a verification of the effectiveness of the pathogen controls that a management site has in place for high risk foods (refer Appendix 2: Glossary of Terms).

 

Thks.

Also refer Post 10.

As you say, there are multiple SQF threads here reflecting my comments/above ^^^. Basically, particularly for opined "Low Risk",  there exists a documentation of a succession of arguments between SQF and the user. With, IIRC, seemingly variable conclusions.


Kind Regards,

 

Charles.C


#13 Fred73

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Posted 17 September 2020 - 03:11 PM

Very interesting topic, I believe you should do a risk analysis and as a consultant friend of me used to say "risk-assess you out of that clause". So explain and show how you validate that you do not have or need an EMP. 

Good luck.






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