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Sanitary Drain System - Are We in Trouble?


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#1 Urban Explorer

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Posted 05 December 2012 - 11:41 PM

Our facilities audit is in one month. During the desk audit, we discovered that some of our drains are not separated from the sanitary drains. They are trying to figure out a solution (via air traps or whatever you call them, I'm a food scientist not a plumber!), but I am fairly certain that will be a major or critical hit and fail us right away.

Anyone know for sure?

I'm so peed off this is a 2 year old building, this should not be an issue.



#2 Madam A. D-tor

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Posted 06 December 2012 - 08:04 AM

Dear Desiree,

I can understand that you are peed off!
If you believe this will lead to a critical non/conformity, you are actually saying that your products are at risk right now.
You should then take immediately action to your products.
Do not wait until an auditor tells you hat your products are at risk.


Kind Regards,

Madam A. D-tor

#3 Urban Explorer

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Posted 06 December 2012 - 10:12 AM

Our products are not at risk, the drains are connected in the warehouse area where we do not store food product. The USDA approved the building plan, so I'm blaming the government!

This is why I asked what kind of non-conformity people have observed in the past.



#4 Madam A. D-tor

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Posted 06 December 2012 - 10:54 AM

Dear Destinee,


I am not sure for SQF (not a SQF auditor myself) but for IFS, BRC, Dutch HACCP and ISO 22K the instructions to auditors are:
- critical is given when there is a real food safety risk observed. E.g. leakage from roof in the products.
- major is given when there is a potential safety risk observed or their is a significant failure to meet the standard requirement.

I do not know, if this is a specific requirement in the SQF (I suppose it is).

Auditors are in generally, just like yourself, no plumbers. If you can validate that the products are not at risk, make sure you convince the auditors.
Let the auditors see that you have observed this non-conformity in an internal audit and use it to gain a big plus on internal audits, corrective action and continue improvement.


Kind Regards,

Madam A. D-tor

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#5 KDuf

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Posted 06 December 2012 - 01:22 PM

Our facilities audit is in one month. During the desk audit, we discovered that some of our drains are not separated from the sanitary drains. They are trying to figure out a solution (via air traps or whatever you call them, I'm a food scientist not a plumber!), but I am fairly certain that will be a major or critical hit and fail us right away.

Anyone know for sure?


If you're after SQF, check out the following SQFI-provided checklist for ed. :

http://www.sqfi.com/...les-8-8-12.xlsx

It helps with all sorts of things (basically a checklist/gap analysis tool for the SQF code).

I searched for drains in the document and here's what I found.
One of the sections for drains for a food packaging manufacturer (obviously you'd have to search your specific module) is listed below:


SQF Clause:
13.3.8.2 Sanitary Facilities
Item:
Sanitary drainage shall not be connected to any other drains within the premises and shall be directed to a septic tank or a sewerage system. Procedure shall be documented and implemented to properly manage sewage back-ups in order to minimize the potential for contamination.
Secondary Response:
(m) Sanitary drainage is connected to drains within processing facility


The small '(m)' indicates that to have sanitary drainage connected to drains within the processing facility represents a minor nonconformance. I like Madam A. D-tor's advice, make lemons into lemonade! Document it and address it.

Best of luck,

KDuf

Edited by KDuf, 06 December 2012 - 01:28 PM.


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#6 Urban Explorer

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Posted 06 December 2012 - 04:49 PM

Thank you everyone for your replies.

Armed with this info, I hope we can figure out what to do. The fact that it is most likely a minor is a huge relief.






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