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#1 Compliance Guy

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Posted 12 September 2017 - 08:35 AM

Hi,

 

I have bee asked to carry out a risk assessment for this particular scenario. I am dealing with such scenario for the first time so I was wondering if you guys can advise on this please?

 

We have hired a contractor who are planning to spray paint the ceiling above the production lines and Senior Management has said that production should go ahead and lines shouldn't be stopped.

 

So contractors have came up with a plan to cover each production line by a thick sheet of polyethylene film suspended in the air right above it. Having said that we do have food grade packaging

 

What factors would you take into consideration whilst doing a risk assessment and would you do it on a standard template? 

 

I have already asked for these:

 

  • MSDS
  • SOP

 

Appreciate your time to read and reply to this.

 

Many Thanks


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#2 rdeboer1986

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Posted 12 September 2017 - 01:58 PM

Yes, sometimes it is hard to live with the decision of Senior Management.

 

In my opinion plastic sheets cover some of the paint but, you will probably get aerosol from the paint spray which will 'float' through your facility and end up in places you don't want. That can be a risk of chemical contamination to your food grade packaging.


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#3 Gerard H.

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Posted 13 September 2017 - 07:49 AM

Good Morning,

 

Agree with the previous post of De Boer, about the aerosol, which goes everywhere, thus ending also on the packaging. In that case it is not complying anymore.

 

There are other issues raising by this way of working:

  • Human Safety risk - the employees will also breath the spray of the painting. Second point is that painting the roof and working on the ground can lead to dangerous situations (objects falling down or collisions against the gauntries)
  • You work with people, so in the future, every effort to convince them to produce high quality products will be like "Blowing in the wind"

I hope you will succeed to convince the senior management, that they need to change their decision and their attitude.

 

Kind regards,

 

Gerard Heerkens


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#4 Parkz58

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Posted 13 September 2017 - 09:19 PM

Maybe I'm alone in this, but I would likely literally pitch a fit if management tried to pull this.

 

There is no way that I can think of that will allow for a guarantee that a painting job being performed over the top of product will not potentially contaminate the product.

 

In my opinion, this is a job that needs to be done when production is shut down...and all equipment is removed, or at the very least, covered...and then all equipment is cleaned and inspected prior to start-up.

 

Maybe I'm overly cautious...but I don't think I am.


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#5 CMHeywood

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Posted 13 September 2017 - 09:31 PM

Get the senior manager's position in writing.  Helpful if you have email or some other written communication showing you mentioned your concern to the senior manager.

 

As described in the responses above, even though the contractors will be spray painting the ceilings, there will be a lot of paint aerosol in the air.  That's why the contractors will be wearing face masks.

 

Does the senior manager want to take responsibility for any paint getting into the machines, into your products, or people breathing it into their lungs?  Have him buy a can of spray paint and spray it while he is wearing his best clothes (preferably white) and see how much paint he gets on himself even when in a closed room with no air movement.

 

SQF talks about paint in the various modules:  "Paint used in a product handling or contact zone shall be suitable for use and in good condition and shall

not be used on any product contact surface."


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#6 Ryan M.

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Posted 14 September 2017 - 03:46 AM

Try to compromise and see if they will allow rolling and brushing of the paint.  I know from experience...the paint will get into / onto A LOT of things even if you have plastic sheeting underneath.  ALsol consider the air handling systems....that will carry the paint aerosols elsewhere as well.  Just a bad idea to "spray", bad, bad, bad...kind of like pressure washing while in production.


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#7 Mesha

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Posted 14 September 2017 - 05:30 AM

Also consider the possibility of absorption of odor of paint by the product getting manufactured.


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Regards,

 





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