My instinct is that introducing such a system will be an expensive logistical nightmare.
Hi Peter,
Great to have you on board. With regards to swab tests for hands and everything else, lots of people forget that this would really depend on the sensitivity of the process and the industry you are in.
If we refer to secondary packaging materials, as the name goes, it is not a direct food contact materials hence, GMP applies. However, if we refer to primary packaging materials which are direct food contact, we may have to perform our hazard analysis in further depth.
Firstly, all foods are processed and packed in a suitable manner to protect the integrity of the "finished products" (unless unsuitable packaging materials (p/m) or designs are used ) which may render products to possible compromises.
Therefore, even with the presence of microbes in the food (if introduced from workers on p/m, it is often limited and under controlled
modified environment condition and therefore, proliferation is never allowed.....hence product remains safe to eat.
The scenario is different if we refer to products that requires further cooking or processed prior ot consumption. It would also be different if the p/m is used for meat and fish based products etc.
For the general food industry, I feel hand washing is therefore more important than hand swabbing. However, if we are providing p/m for the infant milk industry, this is a totally different ball game.
By the way, cost of p/m are already escallating. Getting into unnecessary applications can only further escallate end product cost versus advantages gained that may not quite necessary or relevant to the industry.
I guess challenging the opinion of the auditor is probably justified in this case.....Does hand swabbing guarantee food safety?
Regards
Charles Chew