2.24 Environmental Testing Program Evaluating the worth of manufactured goods is not limited to evaluating their function and performance and Peters Fruit Farms Inc. (Company) believes that environmental testing will further enhance, protect, and prolong the finished products, employee health and safety, and the environment. A crucial part of the worth of manufactured goods is in their quality. However, when quality defects occur after products have been put on the market, the cost is not limited to the significant amount that can be lost in the damages. The greatest loss is that of reputation. To avoid such damages, quality must be confirmed before a product is put on the market. Environmental testing not only confirms quality through such tests as simulation testing and biological testing, it also can be indispensable prerequisite to quality assurance. Environmental testing, such as food-contact surfaces and water source, has been deemed appropriate for integration and assessments of the Company’s operations. The testing will be conducted by accredited labs only within the scope of the accreditation and in-house sampling, as well. The sampling will be collected by the contracted lab or designated employees of the Company. The following tests have been implemented: Quarterly E. coli and Total Coliform of water sources by 3rd party lab and quarterly or more frequent in facility sampling Monthly Listeria samples Frequent ATP testing of food-contact surfaces of product Environmental Testing for Penicilium, Brown Rot, Sour Rot, as needed The Company understands the necessity for hygienic work environments and strives to sustainability in all operations. When a deviation of test results from tolerated amount occurs, a proper corrective action and retest will occur according to the level of deviation, area of selected test region, and level of risk to the finished product and/or employee health and safety. All test, corrective actions, and retests will be documented and retained for a minimum of two years. The Company may decide to employ the use of composite samples. Composite samples will consist of one swab sampling multiple surfaces. However, the Company will require that these composite samples must be from within the same Zone (described later). Operational surfaces separated into four(4) zones have differing importance based upon the likeliness of the surface to come into contact with the product, potential to harbor microbial contaminants, location of surface in relation to the product, product in raw or “processed” state, and likelihood of product to be adulterated. This risk assessment has been completed in the Microbiological Testing Zones by Management and will continue to be updated as processes change and need necessitates. The completed list of zones by number can be found in the Area Numbers by Zone. Doc. Name: FP 2.24 Title: Environmental Testing Date Created: March 19, 2014 Date Revised: June 29, 2015 Current Version 1.0.1.0 Page |1 Zone 1 - Product contact surfaces. These may include equipment surfaces and employee contact where the washed product comes in contact before final packaging. Such as: conveyors, productcontact water, employee hands, etc. Surfaces that are easily cleaned are not appropriate for multiple samples, instead focusing on high traffic surfaces that are more difficult to clean. Areas such as zipper joints of conveyors, grating, repaired or uneven surfaces. Also it is considered that the pack tables may be a point of detection since it is the last surface the exposed product touches before its final packaging and may accumulate runoff from belts and sizer cups located above it. The Company may consider holding all product ran and waiting for results before microbial testing and a subsequent washing of packing line. The Company has deemed that Aerobic Plate Count (APC) testing shall be conducted on zone 1 surfaces, as recommended by the designated lab. Zone 2 - Near or next to product contact surfaces. These may include equipment surfaces that are in proximity of or adjacent to product contact surfaces. Such as: exterior of conveyors, framework and housing of packing line equipment, exterior surfaces of product-contact water equipment , drains directly under packing line, cleaning tools, etc. The samples will be taken at half the frequency of Zone 1 samples. Areas that accumulate more moisture and water will be considered higher-risk of containing microbial contamination. Sampling of drains during production is not recommended because it is a dangerous sample to reach underneath the packing line while it is running and the process may spread the contaminants beyond the drain. However, the drain may be a useful tool to sample when investigating possible contaminations. Zone 3 - Sites within the production area but are not directly associated with the product, room environment, and surfaces within the higher-risk environment areas or rooms. Such as: walls, floors, doors, electrical panels, phones, drains not directly under packing line, hoses, wheels, forklifts, tools stored in the area, carts, undersides of equipment, etc. Sampling may take place in some of the following places: floors in the production area, packaging area, and cold storage rooms, drains (after production is finished and before sanitizing chemicals have been applied), walkways around packing line, phones, etc. Zone 4 - Areas just outside of the production area where the product is exposed. Such as: lunch room, hallways, shipping dock, forklifts not used in Zone 2 or 3, storage rooms, etc. Testing in Zone 4 can help to confirm that testing procedures are performed correctly by finding contaminants where they are expected and that preventative controls are successful. This may help detect possible entry points of contaminants. Refer to SOP 3.26 for ATP bioluminescent procedures and SOP 3.27 for Microbiological Swabbing practices. Doc. Name: FP 2.24 Title: Environmental Testing Date Created: March 19, 2014 Date Revised: June 29, 2015 Current Version 1.0.1.0 Page |2