Hi Charles,
Yes, the packaging is direct food contact.
We were audited by certifying body (according to FSSC 22000 v.5.1 additional requirement), as per auditor, we have to verify if EMP is applicable to us since the packaging is not susceptible to microbial growth. The question is, by how? and the correction we submitted to CB was "Establish verification of pathogens to determine the applicability of risk-based EMP in the organization" and they accepted it.
Hi po6,
Re ^^(red) - Sorry but this phrase is (to me) not "English meaningful".
Additionally, potential microbial Survival is also important together with Growth.
IMO the answer to your "how" is by risk assessment, eg if you can prove that, say, "pathogens," do not survive on your packaging, the risk is negligible. Therefore not necessary to do EMPG for "pathogens" (But also see next para).
I'm not familiar with specific FSSC22000 text on EMPG but, as in other Standards, "Pathogens" may not be the only microbial species of interest.
The EMPG situation to which you refer may be similar to that which has occurred in BRC Packaging Standard for which can see the analysis detailed here (and in sub-linked material) -
https://www.ifsqn.co...nt/#entry171684