20 replies to this topic

[tsmith7858]

I have not seen to many topics of discussion on AIB Standards but if there is anyone with some insight I have a question on Section 2.5 Floors, Walls and Ceilings.

We have recently purchased a facility that is over 100 years old. It was producing product up until a year ago and sat empty for about 6-8 months. We cleaned things up and got things running again and are planning for a third party audit in early 2010.

The problem that I am seeing with AIB is that the building has wooden floors. The cost to replace them is to great and is not going to happen but Section 2.5 says that floors, walls and ceilings must be easy to clean and kept in good repair.

For ISO 22000, I know that as long as I put in a proper management process (cleaning schedule and enviro swabbing for validation) I will be fine but I am not sure if AIB will accept the same.

Any thoughts or experience with AIB?

[Charles.C]

Dear tsmith,

Product / process ? I assume it is not a high risk item. Also assume it is not wet.

Hv to admire yr knowledge of manouevrability within ISO 22000. Learnt from ISO 9000 perhaps.

Rgds / Charles.C

[tsmith7858]

Hv to admire yr knowledge of manouevrability within ISO 22000. Learnt from ISO 9000 perhaps.

Rgds / Charles.C

Yes, I have a strong background in 9000, in fact it is where most of my ISO knowledge comes from. I have learned about 22000 and the food industry in the last 18 months but I still have a long way to go...

Not a terribly high risk product but there are some ingredient of concern (milk and processed egg powder being the two highest). There are also some "wet areas" that they "shielded" with metal flooring but I am not sure it was much of an improvement from the wood that is underneath due to the construction method and seams.

It is an old building so maybe I can find a grandfather clause (or great-great-grandfather clause)!

[Charles.C]

Dear TSmith

Thks for the info. I can appreciate yr trepidations (yr products sound like potentially “significant” risk to me .) From memory AIB often use a sectioned / scoring system which may increase yr chances but I don’t know if they have a global major/minor/etc knockout type inclusion.

As an inspector, I hv met analogous situations where there was no specific evidence of an immediate risk but a typical GMP type requirement was not in place. A standard polite (good for business) summary phrase something like this is often invoked –

"As discussed and detailed above, although the majority of the checked food safety related aspects are satisfactorily met [to the XXX standard], a satisfactory certificate cannot be issued until XXXX is improved in the manner indicated."

At one time, the use of an intermediate “acceptable” format was fashionable but this became financially unpopular when sueing people became big business.

Hopefully someone here has direct experience to offfer.

Rgds / Charles.C

[tsmith7858]

Thanks for the feedback Charles, your theoretical statement is exactly what we fear might happen.

Hopefully someone has some insight and experience they can share.

We have an ISO 9000 stage 1 audit tomorrow and our auditor was involved in our ISO 22000 audit so I will be asking him some questions.

[Simon]

Thanks for the feedback Charles, your theoretical statement is exactly what we fear might happen.

Hopefully someone has some insight and experience they can share.

We have an ISO 9000 stage 1 audit tomorrow and our auditor was involved in our ISO 22000 audit so I will be asking him some questions.

That's a really difficult one TS. Although I have not AIB experience from a practical point of view I assume no product is stored on the floor and no product comes into contact with the floor. I'm sure you can ensure that this is the case if not already in place. If so then the risk to the actual product is minimal and as long as the floors are kept in a very good state of repair and clean then this should suffice. Even if the standard says "no wood" there needs to be an assessment of the actual risk to the product.

Regards,
Simon

[tsmith7858]

The ISO response was what I expected. As long as we do a risk analysis and monitor the situation, they will be satisfied.

Still not sure what AIB is going to say. After they were tied to the peanut issue at the beginning of the year they started to take a harder look at things. We should be coming up on an AIB audit for our other site in the next month or two so I will have to get a feel from the auditor at that point.

TS

[Charles.C]

Dear tsmith,

Well, it will also depend on the condition of the wood I guess, 100 yrs old teak ??

Have had some very bad experiences with wooden pallets used in cold stores (for many people the only cost acceptable option and usually accepted by auditors in that location for that reason). So I would be very cautious indeed if I was the auditor.

Rgds / Charles.C

[Tony-C]

I have not seen to many topics of discussion on AIB Standards but if there is anyone with some insight I have a question on Section 2.5 Floors, Walls and Ceilings.

We have recently purchased a facility that is over 100 years old. It was producing product up until a year ago and sat empty for about 6-8 months. We cleaned things up and got things running again and are planning for a third party audit in early 2010.

The problem that I am seeing with AIB is that the building has wooden floors. The cost to replace them is to great and is not going to happen but Section 2.5 says that floors, walls and ceilings must be easy to clean and kept in good repair.

For ISO 22000, I know that as long as I put in a proper management process (cleaning schedule and enviro swabbing for validation) I will be fine but I am not sure if AIB will accept the same.

Any thoughts or experience with AIB?

AIB requires the floors to be impervious, BRC tackles this by requiring wood to be sealed and splinter free. With an old site you may struggle to pass the Maintenance for Food Safety section and from memory < 140 in any section leads to an audit failure and an unsatisfactory rating. I presume this is a dry area and well sealed and that your metal shields have drainage ? as AIB requires adequate drainage as well.

All you can do in the short term is gather as much evidence in your favour to persuade the auditor the risk is minimal.

Regards,

Tony

[Charles.C]

Dear tsmith,

It’s an interesting topic.

I looked up some (hopefully) relevant AIB documents (not too sure about the thread "2.5" reference) which are enclosed below – audit checklist and interpretative document (for retail products) respectively.

 AIB___GenFSChecklist.pdf   175.24KB   154 downloads

 AIB___CSRetail.pdf   82.63KB   184 downloads

Several items include "floors" but the only directly related items in present discussion seem to be respectively –

156 - Floors, walls, and ceilings were cleanable and kept in good repair.

IV.2.4 - Floors, walls, and ceilings shall be of such construction as to be adequately cleanable and kept in good repair.

The word “adequately” would appear to be the flexibility factor although of questionable usage IMO (satisfactorily??).

Surprised cannot see any other mention of material requirement anywhere. But good luck for you. I am sure many other standards are less generous.

After studying the defect classification system, I (overall) think you hv a good chance if the floor is in good condition and the dry surrounding well-organised on the day. (I did notice a few typical auditor protection exclusion comments here and there but this is something you hv to live with and may require local knowledge also)

As a quick opinion, I liked the up-frontedness of the AIB assessment system but as per the above comments, not quite sure how strong their evaluation should be rated. I did notice an extremely detailed list of required cooking conditions (ex US Food Code?) and an amazingly comprehensive section on pest control (in line with their key businesses perhaps). In contrast, I also noticed their requirement on refrigeration thermometers to be only +/- 2degC, unusually generous IMO.

Rgds / Charles.C

[tsmith7858]

Tony and Charles,

Thanks for your feedback. Both of you make some good points. The reference of Section 2.5 is from the "AIB International Consolidated Standards for Inspection: Prerequisite and Food Safety Programs" which was just released this year.

Tony,

The "impervious" statement is in the minor requirements and my experience with the auditors so far indicates that a statement in minor requirements is more of a "we would like to see this but...". I think that is my out on this one but I am not positive.

Charles,

The documents you attached look like older audit forms from the previous revision of the consolidated standards. They have tightened up a bit but as mentioned above, there are still some statements that leave you with an arguementative way out.

Thanks again for your insight,

TS

[tsmith7858]

We had an unannounced audit from AIB this week at our main facility and I had the chance to ask the auditor about the wooden floors in the other facility. He stated that as long as they are in good condition and we can show a maintance schedule and a good wood policy that it would be acceptable.

Eases my mind a little bit but we also scheduled an audit for December which means we have a lot of work to due in the next month!!!

Thanks,

TS

Edited by tsmith7858, 06 November 2009 - 04:27 PM.

[Simon]

We had an unannounced audit from AIB this week at our main facility and I had the chance to ask the auditor about the wooden floors in the other facility. He stated that along as they are in good condition and we can show a maintance schedule and a good wood policy that it would be acceptable.

Eases my mind a little bit but we also scheduled an audit for December which means we have a lot of work to due in the next month!!!

Thanks,

TS

Thanks for the feedback TS. I'm interested what could be a maintenance schedule for the floor and what that might include? Getting someone to rub their hands on it and check for splinters? Just kidding, I would be interested to know how you are considering to implement that in practice.

Regards,
Simon

[Tony-C]

Dear tsmith,
As a quick opinion, I liked the up-frontedness of the AIB assessment system but as per the above comments, not quite sure how strong their evaluation should be rated. I did notice an extremely detailed list of required cooking conditions (ex US Food Code?) and an amazingly comprehensive section on pest control (in line with their key businesses perhaps). In contrast, I also noticed their requirement on refrigeration thermometers to be only +/- 2degC, unusually generous IMO.

Rgds / Charles.C

Hi Charles

I found the AIB audits to be one of the most comprehensive and would value their evaluation based on personal experience in the UK. Their controls for chill goods state 4deg C maximum which is quite stringent.

Where are you quoting the +/- 2 deg C from as I can't find it and totally agree sounds extremely generous?

Regards,

Tony

[Charles.C]

Hi Tony,

Where are you quoting the +/- 2 deg C from

Pg 15, 2nd link my earlier post -

 refrig.thermom..png   12.19KB   27 downloads

Rgds / Charles.C

[Tony-C]

Hi Charles

Okay I have found it now. It is in a different place in the new standards:

1.22.1.2 Temperature-sensitive materials are stored to maintain
appropriate internal temperatures:
• 40°F or 4°C or below

1.22.1.4 An air temperature thermometer accurate to +/- 3˚F or
2˚C is provided in all refrigerators and freezers.

This is from the retailer standard not the prerequisite and food safety. I agree 2 deg c is a little lenient but 4 deg C max. sort of compensates.

Thank you

Tony

[tsmith7858]

We had our AIB pratice audit last week and the auditor was satisfied with general observation and monitoring of our wooden floors. I wrote it into our SSOP for machine cleaning to inspect the surrounding floors and report any issues. It will also be included inthe cleaning checklist which is signed off by operators that did the cleaning and the QA person the inpsected the cleaning.

TS

[Simon]

We had our AIB pratice audit last week and the auditor was satisfied with general observation and monitoring of our wooden floors. I wrote it into our SSOP for machine cleaning to inspect the surrounding floors and report any issues. It will also be included inthe cleaning checklist which is signed off by operators that did the cleaning and the QA person the inpsected the cleaning.

TS

Great work TS, I'm glad it worked out for you. Seems pretty logical and simple to me. Did you get and nonconformities or a clean sweep (pardon the pun)?

Regards,
Simon

[tsmith7858]

We had a pretty good list of findings but we knew most of them going in and were using the practice audit to measure the auditor response as well as to drive home some points to people that did not think we needed changes.

They do not grade practice audit but a review of the findings would indicate that we would have received a passing score.

TS

[Simon]

We had a pretty good list of findings but we knew most of them going in and were using the practice audit to measure the auditor response as well as to drive home some points to people that did not think we needed changes.

They do not grade practice audit but a review of the findings would indicate that we would have received a passing score.

TS

It's all part of continual improvement. Never ending.

[jgarnica]

I have fairly good expirience with AIB and when it comes to floor, walls, and ceiling, you just have to make sure that it is on a cleaning schedule, pest control logs, and maintained fairly clean. Now you have to make sure you have it on your daily, weekly, and monthly cleaning schedule. Another thing is that their are no major crack or holes, as long as you do all of that you should have no issues.

Regarda,
Jose