Apologies for the late reply. Yes, I cannot agree more that EMPG for RTE salads is quite complicated!
Yes, we focus on L.monocytogenes - and the spec is not detected for both the finished product and environment. We test our finished products for Salmonella and E.Coli, which are associated with salad.
We do have a validated shelf life, 2 days beyond product life, for extra safety.
The High Care area and Low Risk Area are completly segragated - different rooms - where product enters high care on a conveyor belt straight from the decontamination wash.
Listera is the main focus, and it's not like we have a problem. I know how it sounds, we do some odd detections, and that's it, the factory was build in 2018 so fabrication is excellent. We do have a rigorous cleaning regime in both low-risk and high care areas. I choose to have the same cleaning regime in both areas, although I've been told by my chemical supplier technical team that it's overkill.
We wash our salad leaves in of course, validated wash with Peroxyacetic Acid.
This includes striping accessible parts of machines, brushing, chemical clean with Caustic and Sodium hypochlorite chemical and then disinfectant spray. (I know that we already have a desinfecting agent in out main chamical). We clean the whole room, apart from walls which are cleaned every other week. I change the main cleaning chemical to acidic once a week for two days to change ph.
Then through swabbing, we verify cleaning in both High Care and Low Risk at least 6 hours after cleaning is completed to prevent false negatives.
I have lots of points in Low Risk for indicators (TVC, ENT) and little less for Listeria - those are completed before production.
In High Care we verify cleaning with indicators (TVC, ENT) and we do Listeria after cleaning and also in production for most critical points - i.e. filling tubes used for all products running throughout the day.
Mid production cleaning - only water to remove debirs- leaves from previous run.
In my previous employments (same industry), treating low-risk product areas like high care was never common. There was no swabbing programme there either.
Since we do not have a "kill step" but reduction only, keeping my low riks open product area in nearly the same standard as high care is essential. Neglecting it may lead to the growth of Listeria to the levels the decontamination wash would reduce, but still, those levels will be unacceptable since Listeria spec is "not detected". There is a biofilm formation issue as well.
I thought that zoning would be the best industry standard, but i just couldn't make it work with my Low Risk. I definately do not want to stop verifying low risk as I strongly believe its too important.
Thank you so much for all the attachments, I am very gratefull for your time. I am going to read those today!