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Environmental Monitoring Thresholds for Indirect Food Contact Packaging

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Kevin.Murphy

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Posted 27 March 2026 - 02:35 PM

Good morning,

 

I have been searing for about a week now and no luck so hopefully someone here can help.

 

We produce indirect food contact packaging, and we are hitting a snag with SQF when it comes to our Environmental Monitoring results and what threshold we are comparing them too. I cannot find any information or thresholds for the type of work we do. Everything I see is direct food contact or food handling.

 

Does anyone have any information on thresholds we can use?

 

Thanks!  


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SHQuality

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Posted 27 March 2026 - 05:14 PM

What micro-organisms and indicators are you testing for and where in the facility are your samples taken?

 

As your packaging will go to facilities that also use direct food contact packaging, I would assume you should use similar standards and tresholds to ensure they will be able to maintain their hygiene throughout their facility. Is it a problem for you to reach those levels?


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Kevin.Murphy

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Posted 27 March 2026 - 05:29 PM

We are testing for the following:

E. coli

Presumptive Bacilius cereus

Yeast

Mold

Listeria

Salmonella

 

We are swabbing the belts on our die-cuter and folder/gluers.

 

The first year we did testing, the results came back as to small to measure on the equipment the facility had.

This year we used a different company and we had results come back with actual numbers be we don't know if they are acceptable or safe because we don't have a threshold to compare to.

 

We don't know where to find threshold numbers to us that make sense to what we are producing.


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Rassmutten

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Posted 27 March 2026 - 05:34 PM

I am having the same issue. I am also in packaging. I'm sure there is an answer someplace, but I don't know where it is.


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Kevin.Murphy

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Posted 27 March 2026 - 05:39 PM

Hopefully we can both find an answer here.

I am having the same issue. I am also in packaging. I'm sure there is an answer someplace, but I don't know where it is.


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Tony-C

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Posted 30 March 2026 - 11:04 AM

Good morning,

 

I have been searing for about a week now and no luck so hopefully someone here can help.

 

We produce indirect food contact packaging, and we are hitting a snag with SQF when it comes to our Environmental Monitoring results and what threshold we are comparing them too. I cannot find any information or thresholds for the type of work we do. Everything I see is direct food contact or food handling.

 

Does anyone have any information on thresholds we can use?

 

Thanks!  

 

Hi Kevin,
 
:welcome:
 
Welcome to the IFSQN forums.
 
Your EMP limits will vary with the type of food that your packaging is intended for. I would expect food contact packaging to match micro limits for a clean surface for food and thus the packaging contact surfaces should be of a similar standard, elsewhere less stringent. Given that there is quite a bit of information and links in these two topics, so we worth having a look through.
 
 
 
Kind regards,
 
Tony

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Hoosiersmoker

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Posted 08 April 2026 - 06:49 PM

We are an paperboard packaging manufacturer also. We did a swab several years ago on our equipment and raw materials, the first ever in our plant. Most of the swabs came back negative for any of the microorganisms you listed above. The ones that did show up were only a couple of PPM. After an extensive RA, we determined that, if a building that was nearly 90 years old, machinery that varied between 30 years and 2 years old, and several other surfaces and materials came back either negative or almost too low to measure for any microorganisms, there was a very low likelihood of the contamination from normal operations in the future. At the time (again, 9 years or so ago), we had the information and findings reviewed by the (SQF) technical director and he concurred granting an exemption. A couple of years later, we were told to show the findings to the auditor and he would make the determination if it was still valid. I review the RA annually and verify nothing has changed that could potentially introduce micros into our processes or products. We only did the one swabbing exercise. There are no inherent pathogens in paperboard which undergoes a kill step during manufacturing - steam / high heat. Our adhesives are all certified pure and as a result of chain of custody, all raw materials are delivered door to door. Incoming inspections ensure nothing contaminates our raw materials.

 

I have the original study, references, and submission to SQF if you're interested, just PM me


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Kevin.Murphy

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Posted Yesterday, 12:21 PM

We are an paperboard packaging manufacturer also. We did a swab several years ago on our equipment and raw materials, the first ever in our plant. Most of the swabs came back negative for any of the microorganisms you listed above. The ones that did show up were only a couple of PPM. After an extensive RA, we determined that, if a building that was nearly 90 years old, machinery that varied between 30 years and 2 years old, and several other surfaces and materials came back either negative or almost too low to measure for any microorganisms, there was a very low likelihood of the contamination from normal operations in the future. At the time (again, 9 years or so ago), we had the information and findings reviewed by the (SQF) technical director and he concurred granting an exemption. A couple of years later, we were told to show the findings to the auditor and he would make the determination if it was still valid. I review the RA annually and verify nothing has changed that could potentially introduce micros into our processes or products. We only did the one swabbing exercise. There are no inherent pathogens in paperboard which undergoes a kill step during manufacturing - steam / high heat. Our adhesives are all certified pure and as a result of chain of custody, all raw materials are delivered door to door. Incoming inspections ensure nothing contaminates our raw materials.

 

I have the original study, references, and submission to SQF if you're interested, just PM me

 

 

That would be great if you'd be willing to share your information with me. Not quite sure how to send a PM on here though lol.


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Hoosiersmoker

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Posted Yesterday, 02:15 PM

I tried to PM you the information. I've posted the information somewhere on here but too lazy to search for it. :)

 

I attached the letter contents.

Attached Files


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Kevin.Murphy

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Posted Yesterday, 03:05 PM

I tried to PM you the information. I've posted the information somewhere on here but too lazy to search for it. :)

 

I attached the letter contents.

I really appreciate this. I'll look it over with the rest of the SQF Team!


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