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11.2.3 - Justify Glass Oven Doors by Risk Assessment

risk assessment sqf glass breakage

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#1 harrypotterOZ

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Posted 28 September 2015 - 10:47 PM

Hello All,

 

We have just had our SQF V 7.2 audit and the auditor challenged us on our glass oven doors. We use revent's single rack gas oven which has glass doors - these are not shatter proof and hence not compliant with clause 11.2.3 (SQF). 

 

Obviously, management has no intention of changing the glass doors but we may be given an exemption based on a risk assessment? Am planing to do one based on the history(No breakages ever), glass breakage policy, an effective pre-op check..

 

Has anyone been in a similar situation before? Any thoughts or comments will be much appreciated.

 

:helpplease:

 

 


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#2 Charles.C

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Posted 29 September 2015 - 02:53 AM

Hello All,

 

We have just had our SQF V 7.2 audit and the auditor challenged us on our glass oven doors. We use revent's single rack gas oven which has glass doors - these are not shatter proof and hence not compliant with clause 11.2.3 (SQF). 

 

Obviously, management has no intention of changing the glass doors but we may be given an exemption based on a risk assessment? Am planing to do one based on the history(No breakages ever), glass breakage policy, an effective pre-op check..

 

Has anyone been in a similar situation before? Any thoughts or comments will be much appreciated.

 

:helpplease:

 

Hi Harry,

 

There would appear to be a history involved -

 

http://www.komonews....-179774651.html

 

http://prestigegrill...your-oven-door/


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Kind Regards,

 

Charles.C


#3 harrypotterOZ

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Posted 29 September 2015 - 03:37 AM

Thanks Charles!

 

History - I was thinking more along the lines that all our oven glasses (within the factory) have been intact since their first installment which was roughly 20 years .. though i do not really know their longevity. 

 

it would be worth painting the glass i assume, but that would take the whole point of having a glass window :(


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#4 Charles.C

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Posted 29 September 2015 - 04:57 AM

Hi Harry,

 

I assume there are no temperature-compatible films which could be applied. Temperature =  ? This is one route for glass windows / ambient levels.

 

Add a metal shield/door in front ?

 

Also may depend on location / process / SQF zigzag tolerances of course.

 

Is it actually "certified" for Food manufacturing Applications ?


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Kind Regards,

 

Charles.C


#5 harrypotterOZ

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Posted 29 September 2015 - 07:06 AM

Hi Charles,

 

We have contacted the supplier and requested for their suggestions and recommendations - including a temperature compatible films. Yes, of course the tinted windows :)

 

Metal shield - Wire mesh is a good suggestion, Thanks!

 

When you say "certified" are you talking about the temp-compatible film or the glass - Glass is fitted by the approved oven manufacturer and yes they are suitable for food manufacturing applications.

 

Hmm...Location is a good parameter to consider for risk assessment.


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#6 Charles.C

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Posted 29 September 2015 - 09:27 AM

Hi Charles,

 

When you say "certified" are you talking about the temp-compatible film or the glass - Glass is fitted by the approved oven manufacturer and yes they are suitable for food manufacturing applications.

 

 

 

Hi Harry,

 

One comment - I'm not a SQF user but it seems to me yr equipment is unrelated to para. 11.2.3

11.2.3      Walls, Partitions, Doors and Ceilings

11.2.3.4    Doors, hatches and windows and their frames shall be of a material and construction which meets the same functional requirements for internal walls and partitions.

i.      Doors and hatches shall be of solid construction; and

ii.     Windows shall be made of shatterproof glass or similar material.

 

 

Looks IMO more relevant to 11.7.5.4 where the Guidance, if applicable, softens the Code

 

And yes, i was thinking about the glass.

If it's certified for the operating temperature and hygienically for Food Manufacturing Purposes, this surely equates to a COC. Just like Pyrex.


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Kind Regards,

 

Charles.C


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#7 harrypotterOZ

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Posted 30 September 2015 - 02:28 AM

Hello Charles,

 

With regards to 11.7.5.4 - During the audit, we raised  the point that the oven door is a door and not a "glass window" - but he was pretty adamant about raising it:( Even the spec for the oven says "double walled glass oven door".

 

Think we will do a short risk assessment based on location of glass door, food grade status, glass breakage policy and fight back on the "glass door" point.

 

Many Thanks!


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#8 Kellio

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Posted 30 September 2015 - 07:30 PM

Request  the Material Specification  form the manufacturer with a letter of conformity.  Make sure the specification is certified by the manufacturer own Quality or Industry certification (UL, ISO 9001, ect...) and states that it is food safe.

 

I hope this helps,

 

Kellio


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#9 SQFconsultant

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Posted 30 September 2015 - 09:15 PM

You won't be able to get an "exemption" after the fact (since the audit has been done.)

 

You can however run a risk analysis now and use supporting information from the manufacturer to justify leaving the glass intact as it is without the need to coat/film it, etc. and adding a metal grid is a waste of time not to mention adding another layer of problems.

 

You should be able to have the corrective action taken care of this way and making mention that glass is on the glass register and monitored, etc. for breakage along with information from MFG.


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Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#10 harrypotterOZ

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Posted 01 October 2015 - 12:16 AM

Thanks Kellio.. yes we have requested the manufacturer for a spec n COC.

 

Thanks GOC... :)


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#11 Charles.C

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Posted 01 October 2015 - 05:04 AM

You won't be able to get an "exemption" after the fact (since the audit has been done.)

 

You can however run a risk analysis now and use supporting information from the manufacturer to justify leaving the glass intact as it is without the need to coat/film it, etc. and adding a metal grid is a waste of time not to mention adding another layer of problems.

 

You should be able to have the corrective action taken care of this way and making mention that glass is on the glass register and monitored, etc. for breakage along with information from MFG.

 

Hi GOC,

 

Thanks for the interesting comments.

 

I deduce you agreed with the NCR/paragraph cited as reported in OP ?  Iif so, a little elaboration would be appreciated.

 

Regarding “exemption” It does appear feasible to challenge an SQF audit result, eg –

 

http://www.ifsqn.com...ode/#entry54210

 

http://www.ifsqn.com...nts/#entry58154

 

http://www.ifsqn.com...-21/#entry61650

 

http://www.ifsqn.com...ion/#entry58261

 

However I could not find any reported instances of actual “challenges”. ???!!


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Kind Regards,

 

Charles.C


#12 harrypotterOZ

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Posted 01 October 2015 - 06:28 AM

Hello Guys,

 

Just FYI -

 

We did agree to raise it as a Minor (halfheartedly though)... he was keen to raise it as Major. But we challenged it as he did not witness any actual crack or damage on any of the glass panels. Here's the extract from the car report: "There is no documented evidence of the oven glass being shatter proof - Not complying with SQF 7.2 L3 Clause 11.2.3.1 Walls, Partitions, Doors & Ceilings".

 

Thanks to u guys, we have submitted the risk assessment with the relevant documents  and will hopefully get it approved by end of next week. 

 

Regarding exemptions: Pretty sure that we can seek exemptions even after its been raised as a CAR during an audit - we have been granted a couple form other customers - though this is the first one we are seeking from SQF body  :ejut:  besides, the auditor advised us to seek an exemption!


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#13 Setanta

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Posted 01 October 2015 - 12:54 PM

Hello Guys,

 

Just FYI -

 

We did agree to raise it as a Minor (halfheartedly though)... he was keen to raise it as Major. But we challenged it as he did not witness any actual crack or damage on any of the glass panels. Here's the extract from the car report: "There is no documented evidence of the oven glass being shatter proof - Not complying with SQF 7.2 L3 Clause 11.2.3.1 Walls, Partitions, Doors & Ceilings".

 

Thanks to u guys, we have submitted the risk assessment with the relevant documents  and will hopefully get it approved by end of next week. 

 

Regarding exemptions: Pretty sure that we can seek exemptions even after its been raised as a CAR during an audit - we have been granted a couple form other customers - though this is the first one we are seeking from SQF body  :ejut:  besides, the auditor advised us to seek an exemption!

Wow that's dangerously close to consulting!   :giggle:


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-Setanta                 WeepingAngela.gif

 


#14 Dr Vu

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Posted 01 October 2015 - 02:10 PM

out of curiosity .....do you "open" and  "close" the inspection on the oven windows ie. do you check beginning of shift and end of shift to ensure nothing is broken ?


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A vu in time , saves nine

#15 harrypotterOZ

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Posted 04 October 2015 - 09:48 PM

Yes Dr Vu, we have started doing start up & shut down checks on the glass oven doors.


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#16 ladytygrr

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Posted 05 October 2015 - 12:51 PM

Thanks for posting this, HarryPotterOZ. I was on the floor on Thursday and just realized the doors to our oven are glass. It's one of those things you can easily take for granted and just look right over. 

 

I'm adding it to our list of items to add to our risk assessments that we should cover preemptively rather than hoping our auditor doesn't notice!  :shades:


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#17 harrypotterOZ

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Posted 07 October 2015 - 02:55 AM

No worries :)


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