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#1 loria

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Posted 20 May 2014 - 02:23 PM

We have been asked to obtain SQF certification, which we embraced until our consultant told us that we need a lunch room. We are a very small facility with extremly high sanitation procedures and a highly seasonal component to our product flow, with summer being the busiest.  During winter we have just 3 to 4 production employees.  They live less than 700 feet from the plant.  During summer we add about 4 or 5 additional production staff.  Most production staff live within a few miles of the plant and others are a short bicycle ride away.  Traditionally employees either go home for an hour lunch break or eat outside at a nice shaded table with a lovely view.  We do have a small conference room that might otherwise be used for a lunchroom, but we cannot add plumbing to this room.  There is no other space for a lunchroom.  Any space that could be allocated on the production floor would mean discontinuing one of our production lines. I am interested how others have handled this for a very small facility. 


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#2 afend

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Posted 20 May 2014 - 03:10 PM

Most likely you can get an exclusion. 


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#3 Charles.C

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Posted 20 May 2014 - 11:07 PM

Dear Ioria,

 

or eat outside at a nice shaded table with a lovely view.

 

 

"outside" is a little ambiguous. Is this within yr facility's outside boundary or totally external to the factory ?

 

Does the (to be) audited standard state that there must be a lunchroom ?. Seems unlikely but very easy to check.

 

The standard's specific text will presumably apply but if none of the staff eat within the overall facility layout, it seem's unlikely that an auditor would expect to see a lunchroom. I would expect the auditor is more likely to be interested in how you control the in/out flow of workers within yr overall sanitation program.

 

If the shaded table is not external to the facility, the specific text will presumably again control - the sanitation control is likely to be similarly dominant IMO.

 

Or did the consultant's remark relate to an observed visual sanitation "deficiency" ?

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


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#4 Avila

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Posted 21 May 2014 - 03:29 AM

Dear Loria,

I'm assuming that those shaded tables are in open area e.g. park/garden within the facility. Long time ago before we have a lunch room, park is the most favorite place for lunch (nice place with various plants). If so, lunch room is a mandatory requirement.

Rgds,

Avila


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#5 Quality Ben

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Posted 21 May 2014 - 06:16 AM

Hi Loria,

 

I think you need to determine exactly why they have recommended you need a lunch room? Have they said that it is required? If so, why?

Question them to get a definitive answer...is it because they are concerned about outside pathogens on clothing etc?

There may be a way to prove an exemption by your sanitation / uniform regimes etc.

If you can prove that there is no risk then you will not need a lunch room - run a risk assessment on every concern they have and then use this information to prove your case.

 

Ben


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#6 Avila

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Posted 21 May 2014 - 07:49 AM

BRC Global Standard issue 6

Clause 4.8.9 :

All food brought into manufacturing premises by staff shall be appropriately stored in a clean and hygienic state. No food shall be taken into storage, processing or production areas. Where eating of food is allowed outside during breaks, this shall be in suitable designated areas with appropriate control of waste.

Clause 4.8.10

Where catering facilities are provided on the premises, they shall be suitably controlled to prevent contamination of product (e.g. as a source of food poisoning or introduction of allergenic material to the site)


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#7 loria

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Posted 26 May 2014 - 02:33 PM

Dear Earth,

 

Could you give me more information on how an exclusion might be obtained?


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#8 loria

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Posted 26 May 2014 - 02:55 PM

Charles C and others- thank you for your comments.  The lunch table provided is outdoors.  It is on a deck that is adjacent to the processing facility and is on the same parcel of land.  There is an umbrella for shade on sunny days.  Staff remove their processing outer garments, and don the processing garments after the lunch period ends.

 

If the solution is for none of the staff to eat on premises, we can easily adopt and enforce a policy that staff must go home for lunch.  Most go home already.  This seems a bit silly, but not onerous to enforce.

 

Under SQF Ed. 7, 11.3.10, Lunch Rooms, states:

     11.3.10.1  Separate lunch room facilities shall be provided away from a food contact/handling zone.

     11.3.10.2  Lunch Room Facilities shall be:

          i.    Ventilated and well lit;

          ii.   Provided with adequate tables and seating to cater to maximum number of staff at one sitting;

          iii.  Equiped with a sink serviced with hot and cold potable water for washing utenils;

          iv.  Equiped with refrigeration and heating facilities enabling them to store or heat food and to prepare non-  alcoholic beverages if required, and

          v.  Kept clean and free from waste materials and pests.

 

As I stated in my original post, a conference room is available, but cannot be plumbed to accommodate a sink.  Could we make a policy that lunches brought from home must be self contained (such as a sandwich) and not require dishwashing; ie., disposable utensils or containers only.  What are your thoughts?  Again, thank you for your assistance.

 


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#9 Charles.C

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Posted 26 May 2014 - 09:09 PM

Dear loria,

 

The term "ventilated" is somewhat ambiguous IMO.

 

Might not exclude an outside arrangement if the other criteria are matchable. Must a room have roof/walls ?. :smile:

 

Al fresco cuisine perhaps ?

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#10 Caboose

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Posted 10 July 2014 - 06:33 PM

From SQF Ed. 7.2

 

"2.4.2.2 The supplier shall ensure the food safety 
fundamentals described in the relevant subsequent 
modules of this Code (i.e. modules 3 – 15) are 
applied, or exempted according to a risk analysis 
outlining the justification for exclusion or evidence 
of the effectiveness of alternative control measures 
to ensure that food safety is not compromised." 
 
From an older SQF Ed. 5 from 2010: a specific note for the site requirements exclusion
 
"Note: Exclusions to these requirements or alternative methods of control are permitted however they are 
to be supported by a detailed risk analysis outlining the basis for any exclusion or alternative control 
measure to demonstrate food safety and quality (level 3) is not compromised."
 

As far as I can tell you just have to be able to give an auditor proof that you did a risk assessment for not having in-house lunch facilities (how not having in-house facilities will not effect your product safety/you have implemented policies to prevent this deviation from code from impacting your product's safety, as well as reasons why having in-house lunch facilities would not be feasible) for you to justify an exemption.

 

Would it be possible to provide employees with heating/cooling tools? If a small fridge with a microwave on top would be large enough for your maximum employees (and could fit in a non-production room?) That could possibly cover 11.3.10.2 (iv).

Could you provide disposable utensils for your employees? That could possibly cover 11.3.10.2 (iii).

 

Other than iii and iv the other parts don't say "indoors" but rather "well ventilated" as Charles indicated...unless "Facilities" means indoors.

 

Thoughts? Any SQF auditors around?


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#11 Tony-C

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Posted 14 July 2014 - 07:48 AM

BRC Global Standard issue 6

Clause 4.8.9 :

All food brought into manufacturing premises by staff shall be appropriately stored in a clean and hygienic state. No food shall be taken into storage, processing or production areas. Where eating of food is allowed outside during breaks, this shall be in suitable designated areas with appropriate control of waste.

Clause 4.8.10

Where catering facilities are provided on the premises, they shall be suitably controlled to prevent contamination of product (e.g. as a source of food poisoning or introduction of allergenic material to the site)

 

BRC Food Safety requirements are irrelevant given this is in the SQF Packaging forum

 

Charles C and others- thank you for your comments.  The lunch table provided is outdoors.  It is on a deck that is adjacent to the processing facility and is on the same parcel of land.  There is an umbrella for shade on sunny days.  Staff remove their processing outer garments, and don the processing garments after the lunch period ends.

 

If the solution is for none of the staff to eat on premises, we can easily adopt and enforce a policy that staff must go home for lunch.  Most go home already.  This seems a bit silly, but not onerous to enforce.

 

Under SQF Ed. 7, 11.3.10, Lunch Rooms, states:

     11.3.10.1  Separate lunch room facilities shall be provided away from a food contact/handling zone.

     11.3.10.2  Lunch Room Facilities shall be:

          i.    Ventilated and well lit;

          ii.   Provided with adequate tables and seating to cater to maximum number of staff at one sitting;

          iii.  Equiped with a sink serviced with hot and cold potable water for washing utenils;

          iv.  Equiped with refrigeration and heating facilities enabling them to store or heat food and to prepare non-  alcoholic beverages if required, and

          v.  Kept clean and free from waste materials and pests.

 

As I stated in my original post, a conference room is available, but cannot be plumbed to accommodate a sink.  Could we make a policy that lunches brought from home must be self contained (such as a sandwich) and not require dishwashing; ie., disposable utensils or containers only.  What are your thoughts?  Again, thank you for your assistance.

 

As you have posted in the SQF Packaging forum I am assuming that you are manufacturing food packaging and in that case the specified requirements are not so stringent:

 

Module 13: Food Safety Fundamentals - Good Manufacturing Practices for Production of Food Packaging
13.3.9 Lunch Rooms
13.3.9.1 Separate lunch room facilities shall be provided away from packaging handling or storage areas. Lunch rooms shall be kept clean and tidy and free from waste materials and pests.
13.3.9.2 Signage in appropriate languages instructing people to wash their hands before entering the food processing areas shall be provided in a prominent position in lunch rooms and at lunch room exits.

 

Regards,

 

Tony


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