Hi There, you have a busy weekend ahead of you don't you!
I have made a list of how I would do it and used Glass as the example. You would need to do this for each of the PRPs
My approach would be to
1. list all the PRP with the controls and monitors. This is mine for example below.
2. Create a policy /procedure for each (e.g. for glass would be how the company removes, substitutes, monitors and reports glass incidents).
3. Create an audit template for those needed.
4. Train those who need it (with records) Train the operators to do the daily glass checks on the high risk items.
5. Keep the records of all monitoring, auditing and reviews.
PreRequisites
prp1.docx 18.71KB
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Glass Policy
PURPOSE: All foreign matter in food is undesirable, butbroken glass is among the most serious hazards associated with food safety.
Thisrequires the company to identify all potential sources of broken glass/ glasslike material, to eliminate wherever practicable those sources and to properlymanage any incidents of glass breakage in an immediate and professional manner.
(NOTE:In the section "Glass Auditing and Recording" and subsequent sectionsof this document, the requirement includes any other fragmentable material suchas Perspex sited on food processing equipment or in the vicinity of rawmaterials, food packaging or exposed product, where fracture could result incontamination of foodstuffs).
SCOPE Raw materials Handling, Preparation, Processing Packaging and Storage Areas
RESPONSIBILITIES
Job Title / Function
Responsibilities / Accountabilities
All Personnel
Technical Manager
Glass audits are planned activities
PROCEDURE
TheTechnical Manager must ensure that regular glass audits occur and that anyglass present in manufacturing areas is eliminated or protected from breakageso as to minimise risk to product.
TheTechnical Manager must ensure that there is a programme in place to eliminateall glass in manufacturing, raw materials storage and product despatch areas asfar as is reasonably practicable.
Allemployees must be made aware of the need to immediately report any incidence ofglass breakage and the requirement to record any such incident.
2. Control of Glass
2.1 The following requirements apply to all areas wherefoodstuffs and packaging are stored, produced or awaiting despatch; engineeringstores and workshops; canteens; locker rooms; lavatories; clothing stores; and any other areawhere engineering, production, despatchand sales personnel may regularly visit while wearing or changing intoprotective clothing. Where requirements apply to the entire site this is madeclear.
2.2 Light fittings must be shielded with a plastic cover or thebulb/tube purchased with an integral shatterproof film. This includeselectronic fly killers.
2.3 External windows and skylights must be eliminated or fittedinternally with a shatterproof film which meets BS6206 or a Perspex sheet orother suitable material. All internal windows (including those in offices anddoors), must be of a Perspex type material or fitted with a shatter-proof filmon both sides, which meets BS6206. Theonly exception to this is armoured glass is fitted to the main windows withinthe packing hall which by there nature are not subject to a high probability ofshatter damage.
2.4 All instrument gauges must be free from glass. Glass incompressed air line filters should be replaced where suitable replacements areavailable.
2.5 Glass mirrors are not permitted on site. Mirrors inproduction offices, and production lavatories etc. must be coated withshatterproof film or replaced with a polished metal mirror.
2.6 Glass containers such as milk or soft drink bottles are notallowed in Production areas or Changing rooms, or Offices in the closeproximity to the factory. Within the canteen Canteen area Glass isrestricted where practicable.
2.7 All notice boards on site must be free from glass.
2.8 Where possible Glass will be replaced by shatterproof plastic material.
3. Glass Auditing and Recording
3.1 company has identified and recorded the location of allglass / brittle plastics on site on Glass &Hard Plastics – Register /Risk Assessment.
Glass Audit frequency and assessment of risk isdefined in by risk assessment. Some are daily and others are monthly
4. Glass Control and Incident Reporting
4.1 company has a systemised way of ensuring glass control andincident handling, this is defined in Section 5 below “Procedure to befollowed in the event of glass breakage” and records of activities recorded on “Glass and Hard PlasticsIncident Report” Doc P47.6
4.2 In the event of any glass being removed or disposed of, andprovided there is no product contamination suspected, removal and disposalshall be supervised by a person of line manager status or above. Supervisionshall include the time up to and including the clearance of the glass and anydebris off site i.e. outside the building to a compactor or other suitablemethod of contained disposal. .
5. Glass & Glass LikeMaterial Breakages
5.1 In the event of any glass or other fragmentable materialbeing broken or found to be cracked or broken, the prime duty is to preventdespatch of product that may have been contaminated. Any suspectmaterials/product must be scrapped.
5.2 Where any glass or other fragmentable material has beenbroken or damaged and does not pose any threat to product safety this should,following investigation, be highlighted insitu using marker pen so that futureglass audits can be used to monitor that its condition is not deteriorating. Arisk assessment must be completed to determine how quickly a repair needs to be made and agreed with theengineering team.
5.3 Contaminated plant/process must cease production until athorough clean down has been completed. The process may only restart with thepositive approval of a senior member of the Factory Management Team. On days this must be either the TechnicalManager or the Quality Systems Manager. This authority must be formallydocumented on the Glass breakage Clean Up incident report form.
All pieces of broken glass, etc. and any othermaterials involved in a possible contamination incident shall be retained untilinvestigations and any laboratory analysis is complete. A sample of the brokenglass shall be securely retained for x years.
5.4 In the event of a glass breakage incident potentiallycontaminating Retailers Own Label product then the customer may need to beinformed via the appropriate account management channels as specified inindividual retailer codes of practice.
5.5 In the event of a glass breakage, the area and all equipmentwithin a 10 metre radius, must be cordon off where space permits. Where spacerestrictions exist, precautions should be taken to cordon off an appropriatearea. No unauthorised movement through this area either in or out is permittedwithout the express permission of a senior site manager.
5.6 Consideration must be given to any persons PPE and shoes thatpotentially have been contaminated during the incident or during the clearingof the glass. Shoes soles should be inspected before leaving thequarantined / clean up area. All personnel within the designated “Risk”area, or who are involved in the clean-up following a breakage incident mustchange their overalls. Standard Garments must be bagged and marked as suspectglass contaminated and collection and launder arrangement made with the laundry.Under no circumstances must garments be placed in the soiled garment containersprovided by the laundry. Paper overallsmust be bagged and disposed of into external waste skips.
5.7 The production equipment that may have been affected must bedismantled for in-depth inspection and cleaning. Reassembly of the equipment must not takeplace until inspected by senior management. Any product and/or raw materials, which may have been contaminated, mustbe scrapped.
5.8 Personnel wearing glass spectacles orcontact lenses must report breakage as a glass incident.
5.9 All cleaning equipment used to clean up glass breakagesbagged and must be removed immediately from the department and thrown away.
5.9.1 Vacuum cleaners should not be used for glass clean-up operations. Where such a need exists to use vacuumequipment due to the nature and accessibility of the process / production areathen this must be authorised by the Technical Manager who both assess the needto use a vacuum and if considered unavoidable will issue instruction inrelation to the cleaning or disposal of the vacuum unit. In all cases as aminimum the hose and vacuum tools will be bagged and immediately thrown awayand vacuum cleaned and filters replaced before the vacuum cleaner is positivelyreleased back to process. Where this cannot be achieved immediately the vacuumcleaner will be made inoperable and secured outside processing or raw materialstorage areas.
5.9.2 Air lines must not under any circumstances be used during a glass breakageclean up, due to the risk of spreading the contaminate.
5.9.3 Pressure washers may not be used during a clean up incident due to therisk of spreading the contaminate.
Glass monitor /audit form
Basically just a list of the glass/brittle hard plastic items for audit. High risk for daily audits, and low risk for weekly or monthly depending on the risk assessment you do based on proximity to product, likelihood of breaking, likelihood of the breakage being noticed immediately or not. etc.
Good luck
Sharon ( Dewsbury England)
