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Do we need to do a pathogen test each year to confirm that as a dry facility there are no pathogens?

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MEM

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Posted 24 October 2024 - 06:48 PM

Plastic food packaging facility.  Completely dry facility.  we have done a risk analysis showing that as a dry facility there is not a pathogen issue. Do we need to do a pathogen test each year to confirm this risk analysis?  This auditor is saying yes, but no others have.

 

Also, does testing our finished product for microbial issues address environmental testing?  We thought so as they are built in the environment, but the auditor say no.  I offered air plate testing and she also said no, that if we aren't swabbing the walls and floors, ect. we aren't covering the "environment"

 

Thoughts? 


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kconf

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Posted 24 October 2024 - 07:17 PM

The auditor is right. If you are asking if you ever have to do env monitoring, then yes. At least annually.

 

I have seen it the other way around, facilities doing more env testing than testing each lot they produce. 


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MEM

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Posted 24 October 2024 - 07:24 PM

The auditor is right. If you are asking if you ever have to do env monitoring, then yes. At least annually.

 

I have seen it the other way around, facilities doing more env testing than testing each lot they produce. 

We do other environmental testing annually, I'm just asking specifically about the Pathogens.


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clrmwebb4350

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Posted 24 October 2024 - 07:28 PM

We are SQF Packaging certified and we do pathogen testing annually. We test for Salmonella and Listeria. If we have a positive, we test until we have three negatives in a row. We are also a dry environment  and have had positives for both. Thankfully, our customers have a kill step, so our risk is low. 


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kconf

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Posted 24 October 2024 - 07:31 PM

Yes, even the pathogens. 


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MEM

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Posted 24 October 2024 - 08:14 PM

We are SQF Packaging certified and we do pathogen testing annually. We test for Salmonella and Listeria. If we have a positive, we test until we have three negatives in a row. We are also a dry environment  and have had positives for both. Thankfully, our customers have a kill step, so our risk is low. 

how many samples do you take per size of facility?


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clrmwebb4350

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Posted 24 October 2024 - 08:24 PM

4.  Procedure The manufacturing facility will be tested annually for Salmonella and Listeria by means of swabbing randomly chosen locations in each department. The swabbing will be taken from three “zones.” Zone 1 is considered a direct food contact zone and is not swabbed. A minimum of three samples from zones 2-4 must be taken annually from each area. Larger sample sizes and more frequent testing will be conducted if a food safety risk is identified or if a positive finding is identified.  Zones are defined below:

 

Zone1 – Product Contact Surfaces such as production equipment, utensils, conveyors, etc.

 

Zone 2 – Areas adjacent to Zone 1. In general, this is the area where environmental contamination is most likely to affect the safety of the product (e.g., equipment covers, framework, maintenance tools, machine shielding, housings, etc.).

 

Zone 3 - Nonfood contact surfaces that are not close to zone 1. If zone 3 is contaminated with a pathogen, it could lead to contamination of zone 2 through employees’ actions or movement of machinery (e.g., phones, hand trucks, walls, floor, drains, etc.).

 

Zone 4 - Areas remote from the product processing areas. If zone 4 is not maintained in good sanitary condition, it can lead to cross contamination of zones 1, 2, and 3 (e.g., office areas, locker rooms, maintenance room, etc.).

 

After randomly swabbing each department, the swabs will be sent to a 3rd party ISO: 17025 certified labs to be analyzed 


Edited by clrmwebb4350, 24 October 2024 - 08:26 PM.

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