3 replies to this topic

[JonRiley]

Hey everyone! I'm relatively new to the whole SQF packaging world, and trying to figure out the environmental monitoring part. The code does not give a whole lot of guidance, either, aside from testing must be done twice a year. From what I've seen in my company's records, we test for Aerobic Plate Count and Total Coliforms, and that is it. Does it make sense to test for mold as well? And should we even be testing Total Coliforms on product contact surfaces, as that seems to be a test for water sources? I guess it could be to verify that the water we are using to clean is clean?

 

Also, as a follow up question, does anyone know what the limits should be on these tests? What I gathered from the FDA's Bacteriological Analytical Manual (chapter 3), is that Aerobic Plate Count is normal between 30 and 250. But I have seen nothing for limits on Total Coliforms.

 

Background information: this is for polystyrene foam packaging for food applications.

 

Any insight you can provide would be immensely helpful! Thanks.

[acarver]

I found the EMP to be particularly frustrating as there is not a "right or wrong,"  so getting started or even finding direction is pretty difficult. The plan you create (and follow) needs to fit your facility and situation and we are all just a little different.

 

The best resource I found was to speak directly to my lab rep. She got me moving in the right direction regarding what, how often, etc. and then I was able to create a program with the information I received from her. She also was able to provide me with the acceptable limits information. Don't forget to add to your plan your CA if something comes back out of the acceptable limits. 

 

Good luck!

[Tony-C]

Hi Jon,

 

Welcome to the IFSQN forums.

 

I would be adding Y&M to your monitoring (air and surface) because most of the pain I have had with packaging has been with Y&M contamination.

 

I understand that you are manufacturing packaging but you might find the Micro. Guidelines for Food Contact Surfaces forum useful.

 

Charles C, has posted a Compilation of International Micro. Guidelines for food contact surfaces, 2000 onwards

 

Kind regards,

 

Tony

 

[Scotty_SQF]

What is your risk? 

 

If it's very low (negligible), risk assess yourself out of it.  Have scientific data to back you up and maybe do a set of swabs once to prove it.  One company I worked at we did a risk assessment, it was negligible risk and we had scientific articles showing that there was no link to biological survival on plastic film.  The other company, we risk assessed and again negligible and this time I swabbed, raw material, product contact surfaces, finished goods and before cleaning and after cleaning.  All swabs (tested for APC, E. coli, Salmonella) came back with virtually nothing.  I used that as my basis on why it is not necessary to implement an environmental monitoring program.  Never had an issue with any of these methods for SQF audits.

 

If you have risk, then it is a different story for you.  

 

Just wanted to throw it out there that while it is mandatory, so you cannot simply ignore, you can put together a risk assessment and then an SOP to back you up that one may not be necessary.