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#1 Cronkk

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Posted 16 November 2016 - 05:11 PM

Hello,

 

I work in a distribution center where we sell beer and wine already in its final packaged form and no repacking is done.  We just pick the product and send it to the customer.  My questions is does the FDA require that a distribution warehouse have shatterproof/protective glass and lighting that is over product?

 

Im unable to find anything about it in the FDA Food Code 2013.

 

Thank you everyone.


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#2 Charles.C

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Posted 16 November 2016 - 09:57 PM

Hello,

 

I work in a distribution center where we sell beer and wine already in its final packaged form and no repacking is done.  We just pick the product and send it to the customer.  My questions is does the FDA require that a distribution warehouse have shatterproof/protective glass and lighting that is over product?

 

Im unable to find anything about it in the FDA Food Code 2013.

 

Thank you everyone.

 

Hi biddlecom.

 

I'm a bit puzzled, why would you not want to have such protected items in a food environment ?

 

IMEX (and seemingly auditors) it's basic GMP.


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Kind Regards,

 

Charles.C


#3 Ryan M.

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Posted 17 November 2016 - 02:50 PM

Well...it can be terribly expensive depending on their setup.  I've been in that situation before with warehouse/distribution centers that are built some time ago with no thought to covers or shatterproof bulbs.

 

To the OP.  No, not a requirement in FDA Food Code 2013 or in the new FSMA regulations.  However, you will need to address this "hazard" somehow for your FSMA regulations as it is a hazard even though the products are packaged/sealed.  What if the glass ends up around the opening of the container, someone opens it, and the glass falls inside?  While very rare, it CAN happen.  The easiest way is to regularly audit and inspect.  Document the inspections and have a documented SOP in the event of breakage.

 

Per FSMA you will need a food safety plan for the facility.  That may only include your glass light hazards.  If you have refrigeration for products, that will need to be included as well if any of those products need temperature control for safety (milk/dairy is a good example).

 

Hi biddlecom.

 

I'm a bit puzzled, why would you not want to have such protected items in a food environment ?

 

IMEX (and seemingly auditors) it's basic GMP.


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#4 Cronkk

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Posted 17 November 2016 - 02:59 PM

Well...it can be terribly expensive depending on their setup.  I've been in that situation before with warehouse/distribution centers that are built some time ago with no thought to covers or shatterproof bulbs.

 

To the OP.  No, not a requirement in FDA Food Code 2013 or in the new FSMA regulations.  However, you will need to address this "hazard" somehow for your FSMA regulations as it is a hazard even though the products are packaged/sealed.  What if the glass ends up around the opening of the container, someone opens it, and the glass falls inside?  While very rare, it CAN happen.  The easiest way is to regularly audit and inspect.  Document the inspections and have a documented SOP in the event of breakage.

 

Per FSMA you will need a food safety plan for the facility.  That may only include your glass light hazards.  If you have refrigeration for products, that will need to be included as well if any of those products need temperature control for safety (milk/dairy is a good example).

Thank you for the response.  We do have a glass and brittle plastic SOP and new PC plan in place.  I was just wondering if FDA quoted it anywhere because our safety guy is wanting to take off our light plastic coverings due to them melting when the bulb is improperly installed.  I explained to him that's fine and we should but we need to replace it with something else in order to keep glass breakage out of our product.  He thought it was odd that we need to have light coverings for product that is in its final packaged form.  I explained to him why we need it and showed him the text from our NSF audit that requires it.  I was more just wondering if FDA had a blurb in their code to further my point.


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#5 Ryan M.

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Posted 17 November 2016 - 03:06 PM

Got it...can't you address it with the manufacturer or construction company and designed/installed the light fixtures?  Sounds like their problem.  

 

 

Thank you for the response.  We do have a glass and brittle plastic SOP and new PC plan in place.  I was just wondering if FDA quoted it anywhere because our safety guy is wanting to take off our light plastic coverings due to them melting when the bulb is improperly installed.  I explained to him that's fine and we should but we need to replace it with something else in order to keep glass breakage out of our product.  He thought it was odd that we need to have light coverings for product that is in its final packaged form.  I explained to him why we need it and showed him the text from our NSF audit that requires it.  I was more just wondering if FDA had a blurb in their code to further my point.


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#6 Cronkk

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Posted 17 November 2016 - 03:23 PM

Got it...can't you address it with the manufacturer or construction company and designed/installed the light fixtures?  Sounds like their problem.  

We are just going to take them all down and get new ones.  Just have to justify the cost and reasoning for shatter proof and breakage coverings.


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#7 Charles.C

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Posted 17 November 2016 - 03:33 PM

Thank you for the response.  We do have a glass and brittle plastic SOP and new PC plan in place.  I was just wondering if FDA quoted it anywhere because our safety guy is wanting to take off our light plastic coverings due to them melting when the bulb is improperly installed.  I explained to him that's fine and we should but we need to replace it with something else in order to keep glass breakage out of our product.  He thought it was odd that we need to have light coverings for product that is in its final packaged form.  I explained to him why we need it and showed him the text from our NSF audit that requires it.  I was more just wondering if FDA had a blurb in their code to further my point.

 

Hi biddlecom,

 

Don't know if globally all auditors are the same but the first action an auditor makes when entering a cold store is to look up to see if they have an easy NC.

 

The ceiling lights are so high that the shielding is barely visible so one auditor even requested a forklift to take him up. At -18degC that's real devotion to duty ! One room was enough.

 

But it's true that a significant investment is involved in a large area. Plus the cleaning.


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Charles.C


#8 Ryan M.

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Posted 17 November 2016 - 03:37 PM

Not sure where you are located in the US, but converting to LED's can help justify the cost with reduction in energy usage.  The added benefit of LED is shatterproof built in.

 

 

We are just going to take them all down and get new ones.  Just have to justify the cost and reasoning for shatter proof and breakage coverings.


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#9 Charles.C

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Posted 17 November 2016 - 03:43 PM

Not sure where you are located in the US, but converting to LED's can help justify the cost with reduction in energy usage.  The added benefit of LED is shatterproof built in.

 

Hi rmills,

 

Not USA and still a fairly low-tech environment except for Cinemax. :smile:


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Kind Regards,

 

Charles.C


#10 Ryan M.

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Posted 17 November 2016 - 03:45 PM

HA...my question/comment was pointed to the OP.  Here in California in the US it is all about energy conservation...as such the pervasiveness of our hybrid cars, blah.  With that, the government provides incentives for companies to install or rehabilitate equipment with energy conservation in mind.

 

 

Hi rmills,

 

Not USA and still a fairly low-tech environment except for Cinemax. :smile:


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