FDA- CFR for environmental testing for Food Storage and distribution

Hi All,

just looking for clarification on FDA's requirement on environmental monitoring. 

Our company strictly stores & distributes food products, product is not exposed to environment. Boxes come in & out... literally our inventory moves quick. 

To my knowledge, unless you manufacture expose & handle product to the environment you are required to have an environmental program depending on potential pathogens to be introduced. In our case, we do not do anything to the product, not even recoup broken cases or repack any products.

I don't think FDA 21 CFR 117.165 is clear enough on noting this unless I'm missing the context or i'm looking at the wrong CFR please attach the link. 

I appreciate the help in advanced!

- Rosa G

See -

https://www.ifsqn.co...ty/#entry185962