3 replies to this topic

[CSturm]

Hi I'm new to this forum and a new SQF Practitioner. So, I hope this question wasn't answered somewhere I couldn't find.

We produce paperboard cartons for food contact and none food contact packaging. Been SQF certified for several years and have tested out of environmental monitoring, with a daily sanitation requirement on all of our machines. I'm looking to reduce our sanitation requirements. Only a couple of our machines actually produce the food contact packaging. Are there any requirements I'm missing that would prevent me from eliminating the disinfection (sanitation) requirements on the machines that do not run food contact packaging? We would maintain our GMP policies and facility cleaning requirements. We would also keep our PM and machine cleaning requirements for those machines not running food contact packaging. I would just remove the disinfecting (sanitation) steps. Then I would like to reduce it further to only disinfecting (sanitizing) machines that run food contact right before the job is run. Less than 1% of our jobs are food contact...So this reduction, if allowed, would greatly reduce cleaning overhead. I'm assuming that after implementing any changes I will have to backup the change with a restarted environmental monitoring. However, touching on that requirement would be nice also.

[Tony-C]

Hi CSturm,

 

 

Welcome to the IFSQN forums

 

This is the sort of thing I would treat as a process change and have a project where you conduct trials on one machine, monitor the results and then if everything is okay roll it out across your other machines.

 

My concern is how to monitor this ‘project’ and provide evidence that removing the disinfection step has no detrimental effect on the food contact packaging. My questions would be; do your specification include microbiological limits for your packaging? do you monitor the microbiological quality of your packaging? what environmental monitoring do you currently do?

 

Kind regards,

 

Tony

[liberator]

Agree with Tony and as he asked, what environmental monitoring do you do? What specs are on the packaging? Is this a requirement for your customer, and there are specs agreed to with the customer? If so, you'll have to go down the path to get agreement on any changes were you to remove the sanitisation step. 

 

What micro tests are you doing currently (if any) on your direct food contact packaging? You'll need to have some historical data to work with to argue any changes. What is the product that is being packed in the cartons you manufacture that is direct food contact? This will also heavily influence what you need to do. 

 

I think removing the sanitisation on the non-food contact packaging lines makes perfect sense.

[CSturm]

Hi all,

I've been looking into your advice.

I have a follow up question.

Are these same requirements for indirect food contact packaging?