3 replies to this topic

[shookimogh]

Hi Folks,

We are a non-food contact paper bag manufacturer and we recently had our audit. During the audit, we had an NCR for no environmental risk assessment plan, as we do not swab or air sample. the auditor asked us for an EMP RA to prove we do not require environmental monitoring.  however we are not food contact. The auditor mentioned that your EMP RA must be match with you HACCP plan.  In our HACCP only our incoming paper board is associated with Bacillus spp. and mold which is considered low risk. all other biological hazards are considered NONE. is this EMP RA in compliance with our hazard analysis? other than paper, biological hazard is considered NONE for everything else. I have attached EMP and part of our process for comparison. 

I appreciate your prompt response. 

Attached Files

•  Screenshot 2026-08-03 142747.png   31.32KB   0 downloads
•  Screenshot 2026-08-03 142829.png   37.18KB   0 downloads
•  Environmental RA.docx.xlsx   318.05KB   20 downloads

[shookimogh]

 

Hi Folks,

We are a non-food contact paper bag manufacturer and we recently had our audit. During the audit, we had an NCR for no environmental risk assessment plan, as we do not swab or air sample. the auditor asked us for an EMP RA to prove we do not require environmental monitoring.  however we are not food contact. The auditor mentioned that your EMP RA must be match with you HACCP plan.  In our HACCP only our incoming paper board is associated with Bacillus spp. and mold which is considered low risk. all other biological hazards are considered NONE. is this EMP RA in compliance with our hazard analysis? other than paper, biological hazard is considered NONE for everything else. I have attached EMP and part of our process for comparison. 

I appreciate your prompt response. 

 

please help as I'm having hard time with this one NCR.

[beautiophile]

IMO, you can add EMP items below your RA list as you posted here. You break down the (production) environment into elements such as air, water, machine parts/surfaces which contact with your materials, working employees, etc. These element titles are on the left, then you develop the right columns in the same way of your materials.

Edited by beautiophile, 04 August 2026 - 01:32 AM.

[Tony-C]

Hi shookimogh,

 

I appreciate that your bags are non-contact but we still don’t want them to be covered in bacteria or molds that could cross-contaminate contact the packaging/food when handled by the consumer.

 

You must have methods of cleaning verification and this could possibly be tied in together with some exposure plates for air monitoring to form an acceptable ‘EMP’?

 

Kind regards,

 

Tony