10 replies to this topic

[Phil Renaldo]

For food grade warehouse we are storing ambient bagged starch goods.  We have waste receptacles located at each set of docks.  My question is per the standard, it indicates "containers holding food products or packaging shall be covered or closed" under 6.5.  While we do have lids on our receptacles, the operators do not always close the lids after they discard waste.  We are mainly using these to throw debris in from sweeping out trailers before loading.  Is it a direct violation of the standard to have these open?

[SQFconsultant]

Yes.

[FurFarmandFork]

Glen, can you expand further? I don't have the standard in front of me but the section of code Phil posted referred only to "containers holding food products or packaging". Is there a clause that says all garbage cans, dumpsters, etc. need to be covered?

[Phil Renaldo]

Yes, that was my confusion as well...

[FurFarmandFork]

Some other topics for various other certifications:

http://www.ifsqn.com...they-need-lids/

http://www.ifsqn.com...d-or-uncovered/

 

 

Generally, it seems the impressions on the forum are that covered trash cans are required as a pest prevention (flies, rodents, odors) measure. I would argue that if you limit waste to non-food items (such as dust, dirt, pallet pieces) then you probably don't have to have these covered.

 

An alternative proposed by some forum members were funnel lids, which limit access and are arguably "covered". https://www.uline.co...wE&gclsrc=aw.ds

 

If you've got a trash can full of food-waste (dirty packaging, stuff from production floor, lunch items) that will likely attract flies or other vermin, it's going to be a reasonable issue for an auditor to go after. Otherwise it's a grey area as noted above in the section of the code you identified.

[Charles.C]

IMEX this is a favorite auditorial target, both internal and external.

Sort of (rightly or wrongly) mentally equated to dirt, pests, sanitary ignorance, etc.

[redfox]

Hello,

 

According to BRC V7,

 

4.12

Waste/waste disposal

Statement      

of Intent

Waste disposal shall be managed in accordance with legal requirements and to prevent accumulation, risk of contamination and the attraction of pests.

 

4.12.1

Where licensing is required by law for the removal of waste, it shall be removed by licensed contractors and records of removal shall be maintained and available for audit.

 

4.12.2

External waste collection containers and rooms housing waste facilities shall be managed to minimise risk. These shall be:

 

• clearly identified
• designed for ease of use and effective cleaning
• well maintained to allow cleaning and, where required, disinfection
• emptied at appropriate frequencies
• covered or doors kept closed as appropriate.

 

4.12.3

If unsafe products or substandard trademarked materials are transferred to a third party for destruction or disposal, that third party shall be a specialist in secure product or waste disposal and shall provide records which include the quantity of waste collected for destruction or disposal.

 

 

Hope it could help.

 

regards,

redfox

[Phil Renaldo]

Hello,

 

According to BRC V7,

 

4.12

Waste/waste disposal

Statement      

of Intent

Waste disposal shall be managed in accordance with legal requirements and to prevent accumulation, risk of contamination and the attraction of pests.

 

4.12.1

Where licensing is required by law for the removal of waste, it shall be removed by licensed contractors and records of removal shall be maintained and available for audit.

 

4.12.2

External waste collection containers and rooms housing waste facilities shall be managed to minimise risk. These shall be:

 

• clearly identified
• designed for ease of use and effective cleaning
• well maintained to allow cleaning and, where required, disinfection
• emptied at appropriate frequencies
• covered or doors kept closed as appropriate.

 

4.12.3

If unsafe products or substandard trademarked materials are transferred to a third party for destruction or disposal, that third party shall be a specialist in secure product or waste disposal and shall provide records which include the quantity of waste collected for destruction or disposal.

 

 

Hope it could help.

 

regards,

redfox

I think this applies to Food Processing-no?  We have an outdoor dumpster that is not covered at all, and has never been questioned during audit.

[Charles.C]

I think this applies to Food Processing-no?  We have an outdoor dumpster that is not covered at all, and has never been questioned during audit.

 

Yes. Seems the S&D standard is less agressive although Best Practice would surely be to cover.. Maybe BRC haven't noticed the laxity yet.

 

We got a (BRC-food) comment because there was a small hole in one lid.

 

i also agree not so simple if you have a jumbo "bin" involved. It's hard enough to hygienically get the stuff in already.

 

But maybe there's a Regulatory aspect involved also. Open = Fire hazard ?

Edited by Charles.C, 17 April 2018 - 04:41 PM.
edited

[Tony-C]

Hi Phil,

 

If they hold food or packaging, which it seems is quite likely then they should be kept closed or be self closing:

6.5.2 X
External waste collection containers and compactors shall be managed in such a manner as to contain products and not attract pests.
Containers holding food products or packaging shall be covered or closed.

 

It seems to me that you have containers of a compliant design, it is a case of managing the situation to get your people into the habit of keeping them closed as much as possible.

 

Kind regards,

 

Tony

 

[Sarahr78]

 

Hi Phil,

 

If they hold food or packaging, which it seems is quite likely then they should be kept closed or be self closing:

6.5.2 X
External waste collection containers and compactors shall be managed in such a manner as to contain products and not attract pests.
Containers holding food products or packaging shall be covered or closed.

 

It seems to me that you have containers of a compliant design, it is a case of managing the situation to get your people into the habit of keeping them closed as much as possible.

 

Kind regards,

 

Tony

 

 

The interpretation guidelines on clause 6.5.2 x states "Food residues leaking from compactors, and spillages around skips and compactors, shall be cleared up as they occur" 

 

I agree with Tony's comment in the fact its down to the management of ensuring the bins are closed once finished with. 

 

We have fallen foul of this during an audit some years ago. We received a non conformance because one of our lids on a general waste bin had been left open. We have also fallen foul of having mixed waste in a segregated bin.i.e general waste found in a plastic bin.

 

We have also had issues with crisps packets and sandwich wrappers etc were an office waste bin has been emptied into a general waste skip for collection. We had difficulty in proving to our auditor that the consumption of food/drink only took place in designated areas and the waste bin from that area had been placed into the larger skip ready for collection.

 

I should add that we are a finished goods warehouse.  

 

Hope this helps