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18 inch rule (pallet distance to wall)

SQF Code Pallets SOP Staging/Storing Pallets

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#1 Suzie B

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Posted 22 November 2014 - 08:38 PM

Hello All,

 

I have read the modules of the SQF code that apply to Storage & Distribution.  My boss insists there is a rule regarding pallets being stacked no closer than 18 inches to the wall.  It is something I vaguely remember reading somewhere, but I didn't find any mention of it in Modules 2 and 12.  Can anyone tell me where it speaks to that in the SQF Code?  I need to write the SOP, but I can't find a reference anywhere.  So I'm stuck. 

 

Suzie


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#2 Charles.C

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Posted 22 November 2014 - 11:51 PM

Hello All,

 

I have read the modules of the SQF code that apply to Storage & Distribution.  My boss insists there is a rule regarding pallets being stacked no closer than 18 inches to the wall.  It is something I vaguely remember reading somewhere, but I didn't find any mention of it in Modules 2 and 12.  Can anyone tell me where it speaks to that in the SQF Code?  I need to write the SOP, but I can't find a reference anywhere.  So I'm stuck. 

 

Suzie

 

Dear Respondents -

 

Please also see this thread / post to avoid repetitions -

 

http://www.ifsqn.com...use/#entry81327

 

 

@Suzie, a lengthy SQF forum discussion is here -

 

http://www.ifsqn.com...earance-debate/

 

And, AFAI can see, the conclusion was a myth although post 13 offers some near-relatives. :smile:

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


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#3 Suzie B

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Posted 23 November 2014 - 05:08 PM

Thank you, Charles. Once again you saved the day.  I ❤  this website! You have helped my stress level tremendously. When I get stuck, I know I'll find my answer here. Thank you


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#4 CMHeywood

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Posted 25 November 2014 - 11:34 PM

From what I've heard, the 18 inch rule comes from the AIB standard.  SQF is vague and states that you have to determine what distance is adequate to prevent contamination.  This means you have to do a risk analysis and have data to prove your conclusion.


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#5 erin.m.v

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Posted 13 April 2015 - 11:57 PM

Hi Suzie,

 

I address the 18" perimeter issue with a documented risk analysis.  This works for us because ALL of the products we store are fully enclosed in packaging, so the risk of contamination is negligible.  I am not sure what your situation is, but thought I'd pass this along in case it might help you some.

 

Attached File  Risk Analysis re 18 Inch Perimeter.pdf   190.46KB   159 downloads

 

All the best,

- erin -


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#6 MWidra

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Posted 14 April 2015 - 01:12 AM

From what I've heard, the 18 inch rule comes from the AIB standard.  SQF is vague and states that you have to determine what distance is adequate to prevent contamination.  This means you have to do a risk analysis and have data to prove your conclusion.

You are correct, AIB requires the 18 inch clearance from the wall.

 

Trust me, they carry rulers, or at least it feels like it.

 

Martha


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#7 bornyesterday

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Posted 05 April 2016 - 03:48 AM

I know this is an old post, but there are other standards that also cite the 18" inspection margin.  Not interested in figuring out which one came first, but thought I'd share.  I also heard that ASI Food Safety might also cite the margin, but I haven't found the exact reference

 

Silliker Food Processing Facilities Food Safety, Quality and GMPs
Audit Expectations Manual
February 2011
VI. Receiving, Storage, and Shipping
B. Storage
All storage facilities must have an 18 inch access around the interior perimeter of the storage area for sanitation and pest control activities.


PrimusGFS Standard
V2.1-2 – Nov 2015
2.24 Buildings and Grounds
h. Buildings should be well maintained to prevent pest entry:
vii. An 18" internal wall perimeter should be maintained within the facility to allow inspection and cleaning.


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#8 MWidra

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Posted 06 April 2016 - 03:32 PM

From what I've heard, the 18 inch rule comes from the AIB standard.  SQF is vague and states that you have to determine what distance is adequate to prevent contamination.  This means you have to do a risk analysis and have data to prove your conclusion.

We are inspected by AIB, and they are strict about the 18 inch rule.  I've never seen it anywhere else, and I've really looked.  So I think it's their thing.

 

That being said, it's not a bad idea, because once it gets less than 18 inches, it is harder for someone who is "portly", "dumpy" or "buxom" to fit through for pest evidence inspection, overall cleanliness inspection, and for tin cat maintenance.  So, it's not bad to have it in your food safety plan, just because everyone is not the same.

 

Martha


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#9 agasr

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Posted 15 April 2016 - 10:34 PM

Hi Suzie, 

As mentioned by others here, 18" comes from AIB.

 

That said, SQF Module 11 Guidance document specifies the 12" to be recommended distance from the wall for storage. Under, 11.6 Storage and Transport, 11.6.1 Cold Storage, Freezing, and Chilling of Foods, Page # 50.

 

In my view, that would be useful for Module 12 users too, the code is for Cold Storage, Freezing and Chilling of Foods (due to the lack of Module 12 Guidance document). 

 

I hope this helps!

 

Regards, 


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#10 mgourley

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Posted 16 April 2016 - 04:31 PM

18 inches, AFAIK, is an AIB standard and should be considered a "best practice".

At a previous employer, we had AIB audits and did not have the requisite clearance in some storage areas.

We did however call out those areas and had documented inspections of those areas to ensure there was no pest activity. We also had it on a schedule to move the "stuff" that was against the wall out to clean and inspect..

 

Never had a problem.

 

Marshall


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#11 FurFarmandFork

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Posted 29 June 2017 - 03:11 PM

Quickly looked up one of these threads to add some info. There was an FDA warning letter today addressing this issue that gives some insight into how FDA might enforce.

 

"Your firm failed to provide sufficient space for placement of equipment and storage of materials as is necessary for the maintenance of sanitary operations, as required by 21 CFR 110.20(b)(1). Specifically, multiple pallets with finished product packaging were stored directly against the walls of the receiving and distribution warehouse in such a manner to impede proper inspection and cleaning by your employees and/or your pest control operator. Also, this issue was brought to your attention and recorded in the documents supplied to you by your pest control official on multiple occasions."

 

They got in trouble a lot for ignoring the notes of the pest control provider and REP's were found on the perimeter under pallets. So an egregious situation but I figured one more reference on this topic wouldn't hurt.

 

https://www.fda.gov/...7/ucm564513.htm


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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


#12 MWidra

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Posted 29 June 2017 - 05:00 PM

Quickly looked up one of these threads to add some info. There was an FDA warning letter today addressing this issue that gives some insight into how FDA might enforce.

 

"Your firm failed to provide sufficient space for placement of equipment and storage of materials as is necessary for the maintenance of sanitary operations, as required by 21 CFR 110.20(b)(1). Specifically, multiple pallets with finished product packaging were stored directly against the walls of the receiving and distribution warehouse in such a manner to impede proper inspection and cleaning by your employees and/or your pest control operator. Also, this issue was brought to your attention and recorded in the documents supplied to you by your pest control official on multiple occasions."

 

They got in trouble a lot for ignoring the notes of the pest control provider and REP's were found on the perimeter under pallets. So an egregious situation but I figured one more reference on this topic wouldn't hurt.

 

https://www.fda.gov/...7/ucm564513.htm

Even more interesting was that this is an inspection against the OLD GMPs, not the new ones, which are contained in 21 CFR 117. Wonder what they will find when the plant comes under FSMA, probably in August.

 

Martha


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#13 Charles.C

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Posted 30 June 2017 - 02:29 AM

Hi Suzie, 

As mentioned by others here, 18" comes from AIB.

 

That said, SQF Module 11 Guidance document specifies the 12" to be recommended distance from the wall for storage. Under, 11.6 Storage and Transport, 11.6.1 Cold Storage, Freezing, and Chilling of Foods, Page # 50.

 

In my view, that would be useful for Module 12 users too, the code is for Cold Storage, Freezing and Chilling of Foods (due to the lack of Module 12 Guidance document). 

 

I hope this helps!

 

Regards, 

 

The actual quote is -

The tops of refrigerated rooms are to be covered with a rodent-proof material. Inaccessible cavities need to be
sealed to prevent the access of rodents or other pests.  Storage racks and shelving need to be constructed of
a non-corrosive material and easily cleanable.  The product on these racks or shelves should be at least 30 cm
(twelve inches) from walls and 150 mm (6 inches) off the floor to prevent contamination and allow for
adequate air circulation around the product (refer 11.2.3).

 

 

Curiously, there is no equivalent separation comment for dry storage although the 6in from floor is reiterated.

 

As a purely practical note, I agree Martha's Post 8, but space inches are  like gold-dust to storage plannners.


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Kind Regards,

 

Charles.C


#14 GMO

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Posted 30 June 2017 - 06:13 AM

Thanks everyone.  I had AIB in a previous factory and had that 18 inch rule in my head too but you're right other standards just say you need accessibility.  I personally don't treat this as it has to be enough space for a person to do a little jig in comfort behind pallets, simply that if there was a suspected issue or an inspection, they can access without having to move pallets so I don't treat this as a strict rule anymore, just if I can get down as a fairly tall and not fat but not thin woman, I can assume reasonably that someone else would be able to.


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#15 bornyesterday

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Posted 04 July 2017 - 04:31 AM

Since the subtopic of cold room was brought up, I should clarify that, for the most part, the inspection margin was for ambient temp storage, not refrigerated nor freezer storage.


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#16 bornyesterday

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Posted 04 July 2017 - 04:42 AM

Since the subtopic of cold room was brought up, I should clarify that, for the most part, the inspection margin was for ambient temp storage, not refrigerated nor freezer storage.

 

rephrase: I should clarify that in my experience, I have not witnessed any processors or distributors provide an 18" inspection margin in their refrigerated or freezer storage.


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#17 GMO

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Posted 04 July 2017 - 08:51 PM

rephrase: I should clarify that in my experience, I have not witnessed any processors or distributors provide an 18" inspection margin in their refrigerated or freezer storage.

 

I have seen this in chilled and frozen areas.  I've also known of mouse issues in chilled stores so it is valid.


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