8 replies to this topic

[Pizza&Sandwich]

Are all oils in food processing areas supposed to be food grade?

Are all maintenance chemicals (including paint for exterior poles, drain maintenance, etc.) supposed to be included in having an MSDS and label even if the area is kept separate from all food production area chemicals?

 

 

[Setanta]

Yes to both.

[mapry2]

If there is no direct food contact and you use only in the maintenance area, you are not required to have food grade. You can support your argument with the risk analysis of the maintenance procedures.

 

Hope this helps.

[Chris @ Safefood 360°]

Are all oils in food processing areas supposed to be food grade?

Are all maintenance chemicals (including paint for exterior poles, drain maintenance, etc.) supposed to be included in having an MSDS and label even if the area is kept separate from all food production area chemicals?

 

Hi Lacey,

 

Aside from the standard requirements (depending upon the standard you are certified against), as you are in the US you might also consider the OSHA Hazard Communication Standard which requires MSDS and labeling of primary and secondary chemical containers:  https://www.osha.gov...TIVES&p_id=1551

 

Regarding food standards, BRC states:

 

BRC 4.9.1

Processes shall be in place to manage the use, storage and handling of non-food chemicals
to prevent chemical contamination. These shall include as a minimum:
●● an approved list of chemicals for purchase
●● availability of material safety data sheets and specifications
●● confirmation of suitability for use in a food processing environment
●● avoidance of strongly scented products
●● the labelling and/or identification of containers of chemicals at all times
●● segregated and secure storage with restricted access to authorised personnel
●● use by trained personnel only

 

Do you have questions regarding a specific standard?

 

-Chris

[Simon]

Are all oils in food processing areas supposed to be food grade?

Are all maintenance chemicals (including paint for exterior poles, drain maintenance, etc.) supposed to be included in having an MSDS and label even if the area is kept separate from all food production area chemicals?

 

It is good practice to have an inventory of all chemicals on site and then risk assess them e.g. where used, by whom, what for, how often, potential for direct or indirect contact with food or food contact surfaces.  This can be done on a spreadsheet.  Once you have this overview you can easily see which need to be food grade e.g. likelihood of contact.  Once you are in control of the current state make sure you close the gate on new chemicals by having a new substance approval procedure...which is a requisition form that must be submitted to "quality department" along with MSDS before purchase for review / approval.  If approved include on inventory.

[Charles.C]

Dear All,

 

I suppose it must be Best Practice to have MSDS documentation for all chemicals in use in food manufacturing / packaging facilities. I suspect some establishments / Engineers may not be aware of this.

IMEX, the obtainance of such sheets is not always straightforward, particularly where indirect purchasing routes are involved. And sometimes even where direct.

 

Interestingly, SQF (7.1 Code) seems to have a slightly different approach to BRC6  food.

 

I noted that BRC (4.9) specify  “Raw material handling, preparation, processing, packing and storage areas” but also state “Appropriate facilities and procedures shall be in place to control the risk of chemical or physical contamination of product”. Presumably external Engineering Stores/Chemicals would be negligible risk and therefore (audit) excludable. ?

 

SQF, AFAI could see, only requires MSDS sheets to be available for detergents, sanitizers, and chemicals related to pest / vermin management programs. Perhaps it assumes that any other non-food compatible chemicals will be stored such that “no” risk of cross-contamination is present. This is presumably Best Practice also but IMEX may be wishful thinking due to the squirrel syndrome.

 

BRC seem to have overlooked the potential of (externally introduced) chemicals within their pest control program unless they may be included within the somewhat dubious para.  4.9.1.2.

 

It is possible that I have missed a paragraph(s) somewhere. I also didn't check to see if SQF have elaborated the requirements further in their Guidance materials. Corrections are welcome

 

Rgds / Charles.C

[Empirestate]

Yes, even your pallet jack and forklift needs food grade grease.

[Marshenko]

Dear All,

 

I suppose it must be Best Practice to have MSDS documentation for all chemicals in use in food manufacturing / packaging facilities. I suspect some establishments / Engineers may not be aware of this.

IMEX, the obtainance of such sheets is not always straightforward, particularly where indirect purchasing routes are involved. And sometimes even where direct.

 

Interestingly, SQF (7.1 Code) seems to have a slightly different approach to BRC6  food.

 

I noted that BRC (4.9) specify  “Raw material handling, preparation, processing, packing and storage areas” but also state “Appropriate facilities and procedures shall be in place to control the risk of chemical or physical contamination of product”. Presumably external Engineering Stores/Chemicals would be negligible risk and therefore (audit) excludable. ?

 

SQF, AFAI could see, only requires MSDS sheets to be available for detergents, sanitizers, and chemicals related to pest / vermin management programs. Perhaps it assumes that any other non-food compatible chemicals will be stored such that “no” risk of cross-contamination is present. This is presumably Best Practice also but IMEX may be wishful thinking due to the squirrel syndrome.

 

BRC seem to have overlooked the potential of (externally introduced) chemicals within their pest control program unless they may be included within the somewhat dubious para.  4.9.1.2.

 

It is possible that I have missed a paragraph(s) somewhere. I also didn't check to see if SQF have elaborated the requirements further in their Guidance materials. Corrections are welcome

 

Rgds / Charles.C

 

 

Charles,

 

You may want to take a look at 11.6.4 of the SQF code - why they stuck chemicals in this particular section of the code is beyond me, but it specifically requires "instructions for safe handling" ... which I've taken to mean MSDS sheets, though I suppose it could be interpreted differently.  I know my auditor has asked for MSDS sheets for chemicals which are not "detergents or sanitizers"

 

11.6.4 Storage of Hazardous Chemicals and Toxic Substances
11.6.4.1 Hazardous chemicals and toxic substances with the potential for food contamination shall be stored so as
not to present a hazard to staff, product, packaging, product handling equipment or areas in which the product is
handled, stored or transported.
11.6.4.2 Processing utensils and packaging shall not be stored in areas used to store hazardous chemicals and
toxic substances.
11.6.4.3 Daily supplies of chemical used for continuous sanitizing of water or as a processing aid, or for
emergency cleaning of food processing equipment or surfaces in food contact zones, may be stored within or in
close proximity to a processing area provided access to the chemical storage facility is restricted to authorized
personnel.
11.6.4.4 Pesticides, rodenticides, fumigants and insecticides shall be stored separate from sanitizers and
detergents. All chemicals shall be stored in their original containers.
11.6.4.5 Hazardous chemical and toxic substance storage facilities shall:
i. Be compliant with national and local legislation and designed such that there is no cross-­
contamination between chemicals;;
ii. Be adequately ventilated;;
iii. Be provided with appropriate signage indicating the area is a hazardous storage area;;
iv. Be secure and lockable to restrict access only to those personnel with formal training in the handling
and use of hazardous chemicals and toxic substances;;
v. Have instructions on the safe handling of hazardous chemicals and toxic substances readily accessible
to staff;;
vi. Be equipped with a detailed and up-­to-­date inventory of all chemicals contained in the storage
facility;;
vii. Have suitable first aid equipment and protective clothing available in close proximity to the storage
area;;
viii. In the event of a hazardous spill, be designed such that spillage and drainage from the area is
contained;; and
ix. Be equipped with spillage kits and cleaning equipment.

Edited by Marshenko, 15 January 2014 - 07:10 PM.

[Charles.C]

Dear Marshenko,

 

Yes, I think from memory that I only searched for MSDS or similars at that time since people usually  state  if they specifically  require such. IMEX, the instructions issued by the producers / suppliers are often more usage-intelligible than MSDS documents. I personally do not automatically seek them (MSDS) out for every chemical in sight unless obligated.

 

Regardless, it’s good to know that SQF have not forgotten "hazardous" chemicals. Thanks.

 

Regarding 11.6.4.3, IMEX of certain sanitiser/chemical combinations, SQF might well have added that a potential for explosive/inflammable reactions is a negative indicator for implementing proximate storage. 

 

Rgds / Charles.C