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#1 skredsfan

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Posted 18 December 2012 - 02:00 PM

We currently produce secondary packaging materials with the intention of producing direct-food contact packaging in the future. I'm currently developing our CGMP's, Prerequisites, etc. Here is our current procedure regarding Food & Drinks on the production floor. FOOD IS NOT PERMITTED ON THE PLANT FLOOR AT ANY TIME. DRINKS ARE ACCEPTABLE, BUT MUST BE IN A SPILL PROOF CONTAINER, AND CANNOT BE KEPT ON EQUIPMENT OR MACHINES OF ANY KIND.

I realize that soda's, sports drinks, etc. could be an attractant for pests. Can I simply revise our current procedure to say FOOD IS NOT PERMITTED ON THE PLANT FLOOR AT ANY TIME. WATER IS ACCEPTABLE, BUT IT MUST BE IN A SPILL PROOF CONTAINER, AND CANNOT BE KEPT ON OR NEAR ANY DIRECT FOOD CONTACT EQUIPMENT OR MACHINERY?

Am I opening myself up for a violation for even permitting water on the plant floor? I'd love to hear some thoughts on this! Thanks


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#2 skredsfan

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Posted 18 December 2012 - 04:53 PM

Anyone have any thoughts on this?


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#3 Setanta

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Posted 18 December 2012 - 05:02 PM

It looks like this just went up today, so please give folks a chance to answer. :biggrin:

First of all, are other beverages allowed in your production area?

If not, you do need to specify water in those spill resistant cups. Is your production area excessively hot? Why do you need water out on the floor? Isn't a drinking fountain less of a mess issue?

I have worked in a very warm facility and we did have water only cups allowed. But truthfully is was a hassle and there were spills. I would see if you could go to a drinking fountain situation or just elimate it all together.

My thoughts

S.




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#4 Charles.C

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Posted 18 December 2012 - 05:13 PM

Anyone have any thoughts on this?

Dear skredsfan,

Not a packaging person but maybe below is of interest -

Here is a quote from a large UK food receiver's expectations -

Food / drink must not be consumed in production and storage areas (except water when provided by site).

Offices within production / storage areas must be managed so that they do not pose a risk to product. Equipment must be kept to a minimum to allow easy cleaning. Eating and drinking is not permitted in these offices, with the exception of plain drinking water.

Maybe "packaging companies" are less concerned but i don't see why they should be if intended for food use. :smile:

Rgds / Charles.C

PS - do note that as currently stated, yr text implies glass containers would be acceptable ??

PPS- in another thread I challenged the water exclusion also but it is a fact that water dispensing locations seem to be almost ubiquitous in food processing environments such that auditors seem to ignore their presence.
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#5 skredsfan

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Posted 18 December 2012 - 06:50 PM

Currently, we allow other beverages (non-alcoholic :biggrin: ) as long as they're in a spill proof container. I plan to make it a water only policy once we implement our HACCP System. A portion of our production area is climate controlled, but most of it is not. In the summer it's extremly hot inside the facility. We have some water fountains but not enough of them to accomodate every department.

It looks like this just went up today, so please give folks a chance to answer. :biggrin:

First of all, are other beverages allowed in your production area?

If not, you do need to specify water in those spill resistant cups. Is your production area excessively hot? Why do you need water out on the floor? Isn't a drinking fountain less of a mess issue?

I have worked in a very warm facility and we did have water only cups allowed. But truthfully is was a hassle and there were spills. I would see if you could go to a drinking fountain situation or just elimate it all together.

My thoughts

S.





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#6 skredsfan

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Posted 18 December 2012 - 07:00 PM

Chales

We have a no Glass Policy in place . In my opinion, water in a spill proof container poses no significant risk to packaging materials or finished product as long as it isn't kept near packaging materials, equipment and/or machinery. Maybe an auditor won't have the same opinion?? I don't want to set myself up for a violation.

Dear skredsfan,

Not a packaging person but maybe below is of interest -

Here is a quote from a large UK food receiver's expectations -


Maybe "packaging companies" are less concerned but i don't see why they should be if intended for food use. :smile:

Rgds / Charles.C

PS - do note that as currently stated, yr text implies glass containers would be acceptable ??

PPS- in another thread I challenged the water exclusion also but it is a fact that water dispensing locations seem to be almost ubiquitous in food processing environments such that auditors seem to ignore their presence.


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#7 Simon

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Posted 18 December 2012 - 07:44 PM

The view of the BRC/IOP Packaging Standard is that you can have water dispensers at suitable locations in production (i.e. away from direct work area / product). If an operator wants a drink they go to the dispenser and take a drink in a conical disposable paper cup. That's it. Easy to implement and control.

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Simon


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#8 mgourley

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Posted 19 December 2012 - 10:23 AM

I agree with Simon.
With your stated goal of moving toward food contact packaging, you are going to have to do this anyway.
Implement it now and change the culture.

Marshall


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#9 skredsfan

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Posted 19 December 2012 - 12:37 PM

Thanks Everyone! I love this site :thumbup:


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#10 Chris Domenico

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Posted 19 December 2012 - 08:42 PM

Speaking from personal experience, you would be wise to act according to Simon and Marshall's input. :smarty:

Eventually, you are going to have to pull the trigger. If you take baby steps to get there, often times that is perceived as "waffling" and you might find that your credibility has been damaged, in which case - good luck getting the rest of the policies to stick.


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#11 oronogirl

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Posted 20 December 2012 - 07:55 PM

Hi there. We just finished our certification process for SQF as a primary food contact packaging supplier. We do allow water only in translucent spillproof (love that word - thank you!) containers. We have written a risk assessment for this as it is in contradiciton to the SQF code. Heat and all of the safety risks associated with that are very prevalent in our workplace environment. And the safety of our employee is paramount to the food safety of our product. Our auditor agreed with our statements and water is allowed. On occasion personnel re-use containers (such as Gatorade). Our policy is that the labels must be removed. Our auditor had concerns with this and stated that any "re-usable" container should be identified - particularly with some form of identification as to the ownership of the container (i.e., name, initials, etc.)
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#12 Charles.C

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Posted 20 December 2012 - 11:20 PM

Hi there. We just finished our certification process for SQF as a primary food contact packaging supplier. We do allow water only in translucent spillproof (love that word - thank you!) containers. We have written a risk assessment for this as it is in contradiciton to the SQF code. Heat and all of the safety risks associated with that are very prevalent in our workplace environment. And the safety of our employee is paramount to the food safety of our product. Our auditor agreed with our statements and water is allowed. On occasion personnel re-use containers (such as Gatorade). Our policy is that the labels must be removed. Our auditor had concerns with this and stated that any "re-usable" container should be identified - particularly with some form of identification as to the ownership of the container (i.e., name, initials, etc.)

Dear oranogirl,

Thks for the interesting post. IMEX auditors only readily go along with significant divergences from the "Standard", risk assessed or not, for exceptional reasons. (since the auditor is also auditable :smile: ).

Can you clarify the particular nature of your plant such that you were obliged to implement unusually "risky" (at least from a typical SQF POV) tolerances regarding worker's drinking options, eg management disinclined / location unable to install adequate temperature control of the working environment, atypical workforce ?

I am impressed that you were able to risk assess the probability of your rule relaxation with regard to the likely safety of any future food product. Or was this a "negative" verification approach, ie simply based on an observation over X years that your choice had not created any "incidents" as far as you were aware ?

Similar to hygienic debates over what constitutes "acceptable" jewelry options, a conditional procedure such as you describe is often avoided by management due to reported cases, sometimes anecdotal, of significant confrontations over interpretation. The route of banning every conceivable hazard can be alluringly attractive.

Rgds / Charles.C
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#13 Rosemary4

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Posted 21 December 2012 - 10:06 AM

In the summer when it was warm/hot and we have machines running the Production Area gets hot. We only have one water fountain in the canteen, so to overcome the need to keep leaving the area to get a drink outside of break times, I agreed the staff could have plastic bottles of water, with screw tops, kept on the Supervisors desk away from the machines and packing area. This has worked well.


Whilst going to audit a plastic film manufacturer in Europe, the staff had plastic bottles of water, with screw tops, at the end of their thermoforming machines. I personally thought it was too close but their BRC auditor had okayed it. Different interpretations of the Standard I guess.


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#14 Charles.C

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Posted 21 December 2012 - 11:08 AM

In the summer when it was warm/hot and we have machines running the Production Area gets hot. We only have one water fountain in the canteen, so to overcome the need to keep leaving the area to get a drink outside of break times, I agreed the staff could have plastic bottles of water, with screw tops, kept on the Supervisors desk away from the machines and packing area. This has worked well.


Whilst going to audit a plastic film manufacturer in Europe, the staff had plastic bottles of water, with screw tops, at the end of their thermoforming machines. I personally thought it was too close but their BRC auditor had okayed it. Different interpretations of the Standard I guess.


Dear Rosemary,

Precisely.

I had similar trepidations when i was confronted by an array of energy drinks in an employee locker. Future destination / usage uncertain. :smile:

Also met one customer whose response to "BRC okayed it" was "So what" ? ;)

Rgds / Charles.C
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#15 skredsfan

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Posted 21 December 2012 - 12:39 PM

Thanks for the responses everyone :thumbup: . I love hearing different points of view on these kind of topics! This site is great and has been a very valuable source of information as I write our Food Safety Management System.


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#16 BAC

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Posted 08 January 2013 - 06:23 PM

use a water fountain.

Or, have a water cooler with conical cups so they have to discard them after use.

Releting to pressure to have drinks is just opening the door to trouble.


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#17 gaardendan

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Posted 02 March 2013 - 06:45 PM

I'd love to see what the risk assessment for this looks like. Any chance of sharing it?


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#18 rosstaylor2440

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Posted 20 March 2013 - 04:21 AM

There is already lots of advices are published out of which i would mostly appreciate these, there wouldn't be any thing wrong if allowed water in a spill proof container,
And No permission for other beverages .

Nice thread!


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#19 jherculees1

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Posted 05 January 2015 - 03:30 PM

I am new to this , but doesnt this border on micro management ? Controlling the smallest portions of an employees actions? We are still humans after all not machines and drinking fluids is a need not a want for the human body . I think it borders right up there with putting a time clock on the bathroom door. No proffesional with a degree would be treated that way why should any factory worker ? even employees at mcdonalds and walmart and such jobs have drinks on the floor and go to the restroom as needed , 

 

as long as production and factory streamlining are managed well , theres no reason to need to manage drinking water . even an animal is given a water bowl after all !

 

 

thanks


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#20 it_rains_inside

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Posted 05 January 2015 - 04:27 PM

I am new to this , but doesnt this border on micro management ? Controlling the smallest portions of an employees actions? We are still humans after all not machines and drinking fluids is a need not a want for the human body . I think it borders right up there with putting a time clock on the bathroom door. No proffesional with a degree would be treated that way why should any factory worker ? even employees at mcdonalds and walmart and such jobs have drinks on the floor and go to the restroom as needed , 

 

as long as production and factory streamlining are managed well , theres no reason to need to manage drinking water . even an animal is given a water bowl after all !

 

 

thanks

 

Dear jherculees1, 

:welcome:  to IFSQN!

 

While you do make a valid point on trying to retain employee liberties, you will see through aspects of the GFSI certification process that many things  happening in food processing / food container manufacturing are controlled. From what you wear to what/ how you can consume food or beverages on the floor. This GMP is deeply rooted in contamination risks. What risk is there that an employee may spill a beverage on food contact material? Or in a product? Or continue the spread of germs from the mouth onto the hand (when re-capping a beverage container) 

 

If you can demonstrate control over the risks - then I would say doing whatever you want is fair game. If you cannot demonstrate how you are controlling these risks ( i.e. because you cannot) then you must find a solution that still satisfies the original goal but mitigates the known risks. 

 

Edit** It is our jobs to fully understand the requirements that have been set (whether that be internal policy, local legislation or GFSI standards) AND to help the floor employees understand why these rules exist. Without the "why" they are just rules....... "We do not allow personal beverage containers on the production floor because of a risk of contamination to the products, BUT you can consume these products in the designated break areas, and we do have water fountains available on the floor"  


Edited by it_rains_inside, 05 January 2015 - 04:33 PM.

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#21 it_rains_inside

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Posted 05 January 2015 - 04:39 PM

Anyway... I digress.

 

Skredsfan,

 

Here is a link to a recent thread of similar subject matter. 

 

http://www.ifsqn.com...oduction-floor/ 

 

My guess is there is plenty more if you poke around. 


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#22 Carol88

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Posted 26 January 2015 - 08:59 PM

Hi we are a juice concentrate processing plant and we have no food or chewing in processing area but are allowed water only in your personel plastic bottle without a removable top ( that is no removable top to drink from). This comes under both GHP & Foreign Matter Contamination


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#23 MWidra

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Posted 26 January 2015 - 10:11 PM

We have a separate building for food grade production, which is a bit away from the building with the lunch room.  We have a little shed outside the production building that has a water cooler in it.

 

This production building is not climate controlled, and it gets extremely hot in there in the summer.  Workers are allowed and encouraged to drink water or other clear beverage in that shed area every 15 minutes during the extremely hot times of the summer.  They do not have to take a break, this is part of their working time.

 

But they are not allowed to eat at the shed area, nor can they take the drinks into the production area.  Both AIB and the state health department inspect us, and they agree with this set up.  So putting water fountains/coolers in the hall or other non/production area adjacent to your production floor and allowing workers to use that for water for hydration  should be fine.

 

I used to work in a laboratory.  We handled radioactivity and some hazardous chemicals.  We could not eat or drink in the lab.  My office was within the lab.  Guess what, I could not have a cup of tea in my office.  Or a bottle of water.  But there was a VERY good reason for infringing on my liberties and micromanaging my liquid input.  If I wanted a drink, I left the area to get it.

 

BTW, it was also self imposed, since I was the safety officer and the radiation safety officer there.

 

Sometimes, people have to change what they are used to doing when they accept a job making food or food packaging for the common good.  Like IRI said, as long as the reason for the rule is explained, it's a lot easier.

 

Martha


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#24 Charles.C

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Posted 27 January 2015 - 03:46 AM

Dear All,

 

Not that the posts are uninteresting, far from it, but do note that this thread is effectively 2 years old.

 

Rgds / Charles.C


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#25 Simon

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Posted 27 January 2015 - 09:34 AM

I am new to this , but doesnt this border on micro management ? Controlling the smallest portions of an employees actions? We are still humans after all not machines and drinking fluids is a need not a want for the human body . I think it borders right up there with putting a time clock on the bathroom door. No proffesional with a degree would be treated that way why should any factory worker ? even employees at mcdonalds and walmart and such jobs have drinks on the floor and go to the restroom as needed , 

 

as long as production and factory streamlining are managed well , theres no reason to need to manage drinking water . even an animal is given a water bowl after all !

 

 

thanks

 

Control of restroom breaks in terms of whether they are allowed, their frequency and duration is not mentioned in these standards. 

 

Employees have designated breaks to eat and drink as they wish.  Whilst on the factory floor working they can still access drinking water, but in a controlled manner such as at a water fountain / dispenser with conical cups.  So you walk to the dispenser to take a drink rather than having drinks on work benches, machines etc.  This is the norm in the food industry and is an accepted basic requirement of most certification standards and GMP codes of practice.  If you run a food industry business in the 21st century this is expected and you have a choice to comply and supply or deny and die (as a business :smile:).  I don't think it is treating employees badly in any way.


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