15 replies to this topic

[Parkz58]

Hello,

 

We have a few large grain bins at our facility that have 24" round access doors on the sides.

 

These doors actually consist of two doors (see attached pic - sorry it's so small, that's all I can find)...an outer door that is very flimsy, and an inner door that is heavy duty.  The inner door swings inward, so it is not able to be opened until the grain level inside is below about 4' or so.  The outer door doesn't really have much for a latch or a place to lock it, and it's so thin and flimsy that it could easily be bent open if someone was sufficiently driven to do so.

 

We could obviously put just a tamper-evident seal on the flimsy outer door...but is that really sufficient?  No one would be able to access the grain until it was below the 4' mark because they couldn't open the inner door...but if the grain is below 4', they could access it quite easily.  Sure, we'd know the seal was broken...but we also have a shallow pile of grain (which, with a 27' bin, is still a significant amount!) that we must now treat as though it's contaminated.

 

We came up with an idea to modify the inner door to effectively lock it, but it would take some cutting, welding, etc. - before we do that, we wanted to hear if anyone else had any other thoughts or ideas.

 

FYI - we're not third-party certified, just FSMA-compliant (or trying to be...)

 

Thanks,

 

Brian

Attached Files

•  round_door.jpg   13.56KB   1 downloads

[Charles.C]

Hi Brian,

 

Grain not my area but Is there any particular reason why anyone would wish to tamper with the Grain ?, eg it's a frequent known event.

 

If not, one would assume that only a minimal safeguard is required.

[FurFarmandFork]

If you included CCTV pointed at the door, then if you found a broken seal you could just review the footage and determine if it was an actual event or someone just poking their head in without telling anyone. Just check on the seal before your old footage gets overwritten.

[Parkz58]

Charles.C, you are right - it's very, very low risk, in my opinion...but I'm just trying to be sure we comply with all Food Defense requirements, and that's not always very clear as to what constitutes "compliance".

 

FFF, we don't have surveillance cameras...otherwise, that would probably be a good idea.

[McForman]

We have the same doors on top of our silos and added a chain to the outside and a hook on the top to add a pad lock, I can take a picture on Monday and Send. 

[Parkz58]

Hello McForman,

 

Yes, pictures would be great - thanks!

 

Brian

[mgourley]

Charles.C, you are right - it's very, very low risk, in my opinion...but I'm just trying to be sure we comply with all Food Defense requirements, and that's not always very clear as to what constitutes "compliance".

 

FFF, we don't have surveillance cameras...otherwise, that would probably be a good idea.

 

I believe it is a FDA requirement that (especially) external storage tanks/bins be locked.

 

You have mentioned before the further goal of getting certificated to a GFSI scheme. All the major ones require it as well.

 

I doubt CCTV is in your budget, but then again you don't need a whole lot if you just want to monitor a couple hatches.

Would it be possible to fabricate something to replace the front door that could be lockable?

 

Marshall

[McForman]

Here are some pictures we welded chain links to bolts.

Attached Files

•  SAM_0289 1.jpg   279.8KB   0 downloads
•  SAM_0290.JPG   334.37KB   0 downloads
•  SAM_0291.JPG   327.83KB   0 downloads

[Parkz58]

Excellent - thanks, McForman!!

[McForman]

I was just checking to see if you added surveillance cameras and if yes how often do you watch them? I need to upgrade our system from 12 to like 53 and that's a lot of footage to review everyday. 

 

Thanks

Charles.C, you are right - it's very, very low risk, in my opinion...but I'm just trying to be sure we comply with all Food Defense requirements, and that's not always very clear as to what constitutes "compliance".

 

FFF, we don't have surveillance cameras...otherwise, that would probably be a good idea.

[Parkz58]

McForman,

 

No, we haven't added any video surveillance yet - still thinking through our plan at this point.

[wtheriot]

I think locks are going to be your best bet. It is low risk, however FSMA has a big focus on security (Preventing intentional adulteration). This means you need to show control over access to the "product". I believe locks would prevent you from having to face lots of questions during an inspection. I will add that cameras (CCTV) also cut down on alot of security questions that could come from an inspection / audit. I've been very fortunate to manage two facilities with CCTV. During audits, my food defense plan and cameras keep that section of an audit, easy. We have key card access to our building and cameras in all high / medium risk areas.

 

Keep this in mind as you are making yourself compliant. I would not want to be trying to answer lots of security questions with my only answer being "its low risk". A few well placed cameras and solid written procedures for food defense can go a long way.

[McForman]

Thanks, and yes we have key code locks on all doors, working on internal preventing, we do locker checks, chemicals are locked up, and monthly inspections on chemicals, cameras, and inventory. but I have a lot of open product through out the warehouse.

I think locks are going to be your best bet. It is low risk, however FSMA has a big focus on security (Preventing intentional adulteration). This means you need to show control over access to the "product". I believe locks would prevent you from having to face lots of questions during an inspection. I will add that cameras (CCTV) also cut down on alot of security questions that could come from an inspection / audit. I've been very fortunate to manage two facilities with CCTV. During audits, my food defense plan and cameras keep that section of an audit, easy. We have key card access to our building and cameras in all high / medium risk areas.

 

Keep this in mind as you are making yourself compliant. I would not want to be trying to answer lots of security questions with my only answer being "its low risk". A few well placed cameras and solid written procedures for food defense can go a long way.

[McForman]

McForman,

 

No, we haven't added any video surveillance yet - still thinking through our plan at this point.

Parkz58 are you testing compressor air, our product is low risk risk assessment said,  Since all beans processed at this facility will be cooked after they leave this facility, no biological factors are considered to be hazards at this facility, yet my auditor has raised the issue.

[MDaleDDF]

Everything we make is also cooked after leaving, but that doesn't absolve us of watching for biological hazards.  If compressed air touches food contact stuff, it's generally tested.   Do you path test finished product?   I don't know much about the bean biz....  but we test 1 finished product quarterly, along with air/water (annual), etc.

[McForman]

Everything we make is also cooked after leaving, but that doesn't absolve us of watching for biological hazards.  If compressed air touches food contact stuff, it's generally tested.   Do you path test finished product?   I don't know much about the bean biz....  but we test 1 finished product quarterly, along with air/water (annual), etc.

Thanks, no we don't path test finished product, only test product after harvest and then if a customer wants a special test.