AIB Documents - Chemical Control and Glass Control Programs

Hello Everyone,

I am looking for some examples for a few standards pertaining to AIB, Nonfood Contact Manufacturing Facilities. I have started to write these procedures, and I am trying to keep these procedures simple, but I am getting caught up on certain requirements.

5.9 Chemical Control Program
- Chemical Approval (Can this be an overlap of a purchasing ISO 9001:2008 standard procedure?)
- Concentration Verification (Not sure how in depth this needs to be, no chemicals are used over the PELs, and STELs)
- Actual Usage and Inventory Control (Process inks are bought on consignment and some chemicals are bought in such small quantities, does this need to be logged as well)
- Can an Haz Com Program meet this requirement?

5.12 Glass, Brittle Plastics, and Ceramics Program

- The problem I am having is with conducting the inventory requirement and identifying all the glass, and Brittle Plastics in the facility. On past inspections the forklift lights were a problem, but I am having trouble distinguishing which are of the brittle variety, and which are not. Also, I am concerned about glass gauges, and controls that are on the machinery. The facility allows for no glass bottles into the facility and our building light system has guards to protect if there was ever a breakage. From an inside view there does not seem to be much of a risk with glass or brittle plastic affecting food safety at this facility.

Any help would be greatly appreciated.

Hello Everyone,

I am looking for some examples for a few standards pertaining to AIB, Nonfood Contact Manufacturing Facilities. I have started to write these procedures, and I am trying to keep these procedures simple, but I am getting caught up on certain requirements.

5.9 Chemical Control Program
- Chemical Approval (Can this be an overlap of a purchasing ISO 9001:2008 standard procedure?)

I am not familiar with the ISO Standard, but as long as it includes an Approval Authority and a Purchacing Authority (people) it should satisfy AIB.

- Concentration Verification (Not sure how in depth this needs to be, no chemicals are used over the PELs, and STELs)

If you have bulk chemicals that are diluted to a specific concentration or ratio, then you have to verify that the concentration is correct. Depending on your operation, this could be anywhere from once a shift to once a month.

- Actual Usage and Inventory Control (Process inks are bought on consignment and some chemicals are bought in such small quantities, does this need to be logged as well)

The standard states " The facility has a written Chemical Control Program that addresses all chemicals used in the facility" So the short answer is Yes.

- Can an Haz Com Program meet this requirement?

Not unless it addresses all of the bullet points in section 5.9.1.2

What I did was set up an Access database to list all chemicals in the facility. See attachment.

5.12 Glass, Brittle Plastics, and Ceramics Program

- The problem I am having is with conducting the inventory requirement and identifying all the glass, and Brittle Plastics in the facility. On past inspections the forklift lights were a problem, but I am having trouble distinguishing which are of the brittle variety, and which are not. Also, I am concerned about glass gauges, and controls that are on the machinery. The facility allows for no glass bottles into the facility and our building light system has guards to protect if there was ever a breakage. From an inside view there does not seem to be much of a risk with glass or brittle plastic affecting food safety at this facility.

I struggle with this as well. I have a master list of all glass and plastic in my facility. It's obviously impractical to audit everything on the list. I have broken out only those items that are above or around a product zone and placed them on a list that is inspected once a month.

Any help would be greatly appreciated.

HTH,

Marshall

On 5.12 Glass, Brittle Plastics, and Ceramics Program.

I'm a bit rusty on answering questions these days but here goes.

For me it's about:

1. Getting rid of, replacing or protecting items where practical to do so
2. Not allowing items to be brought in by employees, contractors, visitors etc.
3. Considering design of new equipment and machines and any changes to the building or process.

Once all of that is controlled auditing must be conducted on a basis of a risk assessment of each item considering:

1. Potential to contaminate product (proximity)
2. How easy and quickly it would be to noticed gone or broken by operators / management (quickly enough that contaminated product is not delivered or worse consumed)
3. Clear and effective breakage / loss reporting procedure
4. Availability of product inspection such as x-ray machine

It may be some items can be left off the audit inventory altogether, others may be audited annually, monthly, others may need to be checked daily or each shift. Items of high risk e.g. in and around a production line should really be part of a documented pre-shift or pre-order operator check, perhaps even with a double sign-off. The quality department cannot audit those items at a high enough frequency.

Regards,
Simon

5.12 Glass, Brittle Plastics, and Ceramics Program

- The problem I am having is with conducting the inventory requirement and identifying all the glass, and Brittle Plastics in the facility. On past inspections the forklift lights were a problem, but I am having trouble distinguishing which are of the brittle variety, and which are not. Also, I am concerned about glass gauges, and controls that are on the machinery. The facility allows for no glass bottles into the facility and our building light system has guards to protect if there was ever a breakage. From an inside view there does not seem to be much of a risk with glass or brittle plastic affecting food safety at this facility.

Just a note on "5.12 Glass, Brittle Plastics, and Ceramics Program"

Per the BRC, a Risk Assessment would be completed to determine the monitoring schedule. Some things never break while others have a history of breaking more often as well as how they break and proximity to the product to pose a hazard (does that forklift ever get near the raw product?) can be taken into consideration. Our food trade association is pressuring BRC to give more guidance on Risk Assessment, however, BRC have suggested it be modeled after HACCP's Hazard Analysis (Biological, Physical, Chemical) hazard risks.

Cheers,
-Cory

I've also just listed the glass or glass like objects as per different food section and let the production staff monitor it daily as part of daily checks,

there not always a risk of breakage but important to monitor it

Just a note on "5.12 Glass, Brittle Plastics, and Ceramics Program"

Per the BRC, a Risk Assessment would be completed to determine the monitoring schedule. Some things never break while others have a history of breaking more often as well as how they break and proximity to the product to pose a hazard (does that forklift ever get near the raw product?) can be taken into consideration. Our food trade association is pressuring BRC to give more guidance on Risk Assessment, however, BRC have suggested it be modeled after HACCP's Hazard Analysis (Biological, Physical, Chemical) hazard risks.

Cheers,
-Cory

Any update on this?