Asset Letters of Conformance
Started by awilders, Jul 12 2011 01:18 PM
We had a recent BRC assessment consultation during our GMA-Safe audit. One item that struck me as overwhelming was the Letter of Conformance said to be required for all of our assets (1300+), and all of our spare parts.
Here is the example from the auditor. “At a plant, I asked if a pipe had food grade material in it, and it did. I pointed at the gasket between flanges and asked the company for a Letter of Conformance for the gasket in that pipe. Because they did not have that letter, they got a “non-conformance” (or whatever she called it, sorry for the loose use of wording)”. Essentially, she explained that we needed to have Letters of Conformance stating that the machinery has been built to food regulatory standards, or perform a risk assessment. These Letters or Risk Assessments are to be on file for materials and equipment (assets). We have very few documents like this.
So my question, how detailed or specific does this really need to be? Do I really need to inspect equipment we have been producing food in for 20+ years and write up these documents for every single machine and spare part?
Keeping in mind, this is for the food contact items.
It seems that I could be busy for months chasing documents down and performing risk assessments. Is there any basic statement that covers our commitment to ensuring our maintenance keeps all materials used within food safe regulations? This whole concept is overwhelming.
Here is the example from the auditor. “At a plant, I asked if a pipe had food grade material in it, and it did. I pointed at the gasket between flanges and asked the company for a Letter of Conformance for the gasket in that pipe. Because they did not have that letter, they got a “non-conformance” (or whatever she called it, sorry for the loose use of wording)”. Essentially, she explained that we needed to have Letters of Conformance stating that the machinery has been built to food regulatory standards, or perform a risk assessment. These Letters or Risk Assessments are to be on file for materials and equipment (assets). We have very few documents like this.
So my question, how detailed or specific does this really need to be? Do I really need to inspect equipment we have been producing food in for 20+ years and write up these documents for every single machine and spare part?
Keeping in mind, this is for the food contact items.
It seems that I could be busy for months chasing documents down and performing risk assessments. Is there any basic statement that covers our commitment to ensuring our maintenance keeps all materials used within food safe regulations? This whole concept is overwhelming.
Hi awilders,
In my personal opinion, the auditor asked for the certificate of conformance of the sampled food confact surface. Maybe you can ask your equipment suppliers to provide such kind of certificate.
By the way, during the audit, you can tell the auditor the material of equipments. If they have common sense they will know which can be used to contact with food and which not.
Only my five cent opinion,
Best regards,
Jason
In my personal opinion, the auditor asked for the certificate of conformance of the sampled food confact surface. Maybe you can ask your equipment suppliers to provide such kind of certificate.
By the way, during the audit, you can tell the auditor the material of equipments. If they have common sense they will know which can be used to contact with food and which not.
Only my five cent opinion,
Best regards,
Jason
Dear awilders:
At my company, we had maintenance contact those companies that had man'f equipment and had them supply letters of conformance/suitable for food contact. We also got letters from current & past suppliers of mat'ls - Stainless Steel, Delron, other product contact materials - and got similar letters of acceptability for food contact.. This should cover 85-90% of your equipment. Now you are down to a managable number of Risk Assessments. Use a resource like the AMS principles of sanitary design during your RAs. You can also use NSF's White List to identify chemicals & some materials approved for direct and incidental food contact.
Don't forget to write a very short program outlining what you will do for future equipment installations: letters from man'f, and inspection prior to use for in-house man'f equipment.
At my company, we had maintenance contact those companies that had man'f equipment and had them supply letters of conformance/suitable for food contact. We also got letters from current & past suppliers of mat'ls - Stainless Steel, Delron, other product contact materials - and got similar letters of acceptability for food contact.. This should cover 85-90% of your equipment. Now you are down to a managable number of Risk Assessments. Use a resource like the AMS principles of sanitary design during your RAs. You can also use NSF's White List to identify chemicals & some materials approved for direct and incidental food contact.
Don't forget to write a very short program outlining what you will do for future equipment installations: letters from man'f, and inspection prior to use for in-house man'f equipment.