I have posted my risk assessment here.
To Previous poster....I was including my situation because not all members have a high risk/high care product that would require environmental swabbing. So i felt it was worth adding
2.4.8 Environmental Risk Assessment and Program.docx
2.4.8 Environmental Monitoring
2.4.8.1 A risk-based environmental monitoring program shall be in place for all food and pet food manufacturing
processes.
2.4.8.2 The responsibility and methods for the environmental monitoring program shall be documented and
implemented.
2.4.8.3 An environmental sampling and testing schedule shall be prepared, detailing the applicable pathogens or
indicator organisms to test for that industry, the number of samples to be taken and the frequency of sampling.
Hi Scampi,
Just to note that this thread was initiated for Packaging whereas above quote/attachment are Food oriented although the Packaging Code text is anyway very similar.
(Risk matrix/Table in attachment have somewhat unconventional labelling IMO but i daresay this is subjective).
There is also a 2.4.8.4 in both Food/Packaging/Standards -
2.4.8.4 : Environmental testing results shall be monitored and corrective actions (refer to 2.5.3.1) implemented where unsatisfactory trends are observed.
So many "shalls" to be shortly ignored !
the SQF Manufacturing Food Guidance has this intriguing comment -
The reference to the environmental monitoring program is self-explanatory, but is worth repeating as it is considered mandatory for areas in which high risk food is processed, handled or exposed. Failure to have an effective environmental monitoring program will result in a major non-conformance.
I agree, as I think you have interpreted, that the above may logically imply that EMP is not mandatory for "Low Risk Food"( SQF defined as "A food containing high acid that is not known to support the growth of pathogens; a food that is subject to a full cook prior to consumption"). The Guidance should have been more specific regarding EMP for both High and Low Risk Foods IMO. As I understand, IYEX, food auditors accept that "risk-based" can be interpreted to mean that EMP may be omitted for Low Risk foods.
Unfortunately there is no Guidance document for SQF Safety Packaging Code afaik so Packaging auditors may not interpret "risk-based" options as discussed above but only in relation to an implemented EMP sampling/frequency . Especially in view of clause 2.4.8.4. I guess only time/experience will tell or perhaps an appearance of a Packaging Guidance. Or an SQF site announcement.
Edited by Charles.C, 07 June 2018 - 11:44 AM.
edited