Flexible Printing Swabbing
Hi
I need some help and guidance please.
I have started a new position with a flexible printing company (FOOD CONTACT) and they don't have a swabbing regime in place. What I am after is guidance to what I should be Swabbing, Frequency of swabbing and also what should I be looking for.
Thanks
Why would you swab in packaging? I understand it is food contact, but have you gone through and assessed risk? There really should be very minimal risk. The only swabbing in food contact packaging I have ever done is one set of swabs to have results to prove that my assessment was correct that there was no real concern to justify not having an Environmental Monitoring program for SQF.
I'd actually expect a company that was manufacture of food contact packaging not to have a swabbing program. Have audited many suppliers to with the companies I've worked for and no swabbing plan either.
Help me cover this by risk assessment please
REF 4.85 BRCGS Packaging Materials Standard
Hello
It depends if the microbiology of the produced direct food contact packaging material is a CCP then you have to test it for every reel or batch. If it is not a CCP then you should test the finished and the semi-finished products twice a year.
For the raw material you can test it once every 2 months.
In case you use water in production it should be tested also once a year.
You should have a test also the microbiology of the air once a year.
The way to risk assess it is to figure out what is the microorganism of concern. Work with your suppliers as I bet there is no microorganism of concern. Look into the science. Are there any studies or scientific evidence linking food contact packaging and micro contamination? Look further into your process, do the presses have dryers? Do you further laminate the film, i.e. extrusion lamination. If you do extrusion lamination, the temperatures used to laminate there alone pretty much risk assess you out. Create a risk assess matrix and show you went through the raw materials (suppliers provide some sort of certificate or statement), your process ( lamination, GMP's, etc.) and then you should be able to show a stable foundation that there in very minimal risk. If you are brave, Id suggest then getting some swabs and swab some areas on some equipment send for testing as further evidence to back you up.
I have done this at two different package facilities that are SQF with no issues from the auditors.
Help me cover this by risk assessment please
REF 4.85 BRCGS Packaging Materials Standard
The latest BRCGS standard recognises the microbiological risks because there are currently new developments in biomaterials and bioprocesses for packaging production. This is to address the ban of single-use materials by making composable and/or compostable materials.
For conventional materials (e.g. petroleum-based plastic and inorganic like glass or tin can), the risks remain so low and people have never encountered serious microbiological incidents of those. Even BRC (before the BRCGS rebranding) said so in the p558 statement.
Since the Issue 6 going effective, BRGCS hasn't explained this clearly so many (food major, not materials science) Auditors and inspectors insist that the packaging manufacturers have to take swab tests regardless the technology or result of risk assessment or tests finding nothing.
By the way, one purpose of this practice is to reduce the contamination of microorganisms from packaging to contained stuff. While the pharmaceutical industry has already got instructions for communication between drug & packaging producers, the food industry still lags behind on this matter, AFAIK. A pharmacy plant sets limits of microbes (example 1000CFU/g for pills), and based on their process (e.g. measured 500 CFU/g) they then send microbio requirements (e.g. 200 CFU/100cm2) to packaging suppliers after calculating the contact surface area of the packaging.
Also, I would love that if anyone can help me to get such similar standards for food processors.