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13.3.8.2 Sanitary drainage - I have a combined sewer?


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#1 zac2944

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Posted 23 December 2013 - 04:37 PM

Happy Holidays folks,

I'm preparing for my first SQF Level 2 in a few months and need some help closing gaps.

 

13.3.8.2 says "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.". 

 

Problem is that my town utilizes a combined sewer system.  Therefore, at some point all my drains (floor, toilet, sinks) connect and leave the building. 

 

We have backflow preventers that are tested annually, but I don't think this will get me past this requirement.  Any ideas on how I can meet this requirement?  I can't tear up the floor and re-plumb >100,000sqft manufacturing plant.  There are many other food facilities in my town (Rochester, NY, USA) using the same combined sewer system (although they may not be SQF), so there must be a way around this.

 



#2 Simon

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Posted 29 December 2013 - 05:23 PM

You have posted this in the SQF packaging forum, can you tell us what products you manufacture and if/how you use water in your process.

 

Thanks.


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#3 Tony-C

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Posted 03 January 2014 - 04:33 AM

Happy Holidays folks,

I'm preparing for my first SQF Level 2 in a few months and need some help closing gaps.

 

13.3.8.2 says "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.". 

 

Problem is that my town utilizes a combined sewer system.  Therefore, at some point all my drains (floor, toilet, sinks) connect and leave the building. 

 

We have backflow preventers that are tested annually, but I don't think this will get me past this requirement.  Any ideas on how I can meet this requirement?  I can't tear up the floor and re-plumb >100,000sqft manufacturing plant.  There are many other food facilities in my town (Rochester, NY, USA) using the same combined sewer system (although they may not be SQF), so there must be a way around this.

 

Hi Zac,

 

You should control the drainage within your facility and ensure 'sanitary drainage is kept separate from drainage from food production areas' and that there are no 'back ups'

13.3.8.2 also states procedures shall be documented and implemented to properly manage sewage back-ups in order to minimize the potential for contamination.

 

In a lot of facilities sewage will eventually combine into a main sewer. The most important thing is that sanitary sewage does not flow through drainage in product areas. Sanitary sewage and drainage from product areas if they combine at some stage should be well downstream of the product areas.

 

Regards,

 

Tony



#4 zac2944

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Posted 09 January 2014 - 08:33 PM

Thanks for the input guys.  I think I will be OK if the auditor understands the difference as you've explained it.  Sewage does not flow through my manufacturing area, but the pipes to connect at the main sewer pipe in the building that then discharges into city combined sewer. 

 

There is a risk of back up if there was an internal block at just the right spot. Should I create an SOP on how to respond to such an event?  My crew know (through other documented training) that if there is even potential contamination that material is to be controlled as nonconforming.  If there was a sewer backup that affected product or raw materials I'm confident they would take correct actions. 

 

I just hate to have a procedure for every possible (and unlikely) event.  Per customer request we just wrote a similar procedure for water ingress from a roof leak.  Now we could have sewer back up procedure.  What's next; the sky is falling?  For significant risks I could see this (ex: glass breakage), but I've never once in all the years had a sewage backup at our plant.



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#5 SQFconsultant

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Posted 30 January 2014 - 03:59 AM

Since you are going for SQF certification, why not write the the procedure to be followed directly into your BCP - it could even be your test/verification/training process for the annual requirement of the BCP.  Interestingly enough I saw the "most unlikely event" happen in a plant real time while doing an audit one day and it was a sewer back up from the main line.


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#6 tery

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Posted 12 November 2014 - 04:54 AM

Thanks for the input guys.  I think I will be OK if the auditor understands the difference as you've explained it.  Sewage does not flow through my manufacturing area, but the pipes to connect at the main sewer pipe in the building that then discharges into city combined sewer. 

 

There is a risk of back up if there was an internal block at just the right spot. Should I create an SOP on how to respond to such an event?  My crew know (through other documented training) that if there is even potential contamination that material is to be controlled as nonconforming.  If there was a sewer backup that affected product or raw materials I'm confident they would take correct actions. 

 

I just hate to have a procedure for every possible (and unlikely) event.  Per customer request we just wrote a similar procedure for water ingress from a roof leak.  Now we could have sewer back up procedure.  What's next; the sky is falling?  For significant risks I could see this (ex: glass breakage), but I've never once in all the years had a sewage backup at our plant.

Zac, we have similar non-conformance at our recent SQF audit. I was wondering was the sewer back up procedure acceptable and sufficient as a corrective action. Thank you



#7 zac2944

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Posted 12 November 2014 - 01:47 PM

You have posted this in the SQF packaging forum, can you tell us what products you manufacture and if/how you use water in your process.

 

Thanks.

Food and pharma flexible packaging.  We do not use much water, and it is not a direct raw material.  We use water with soap when we mop the floors or run our floor scrubber.  We add water to adjust viscosity of waterbased inks.  Hand washing. That's about it.

 

 

Zac, we have similar non-conformance at our recent SQF audit. I was wondering was the sewer back up procedure acceptable and sufficient as a corrective action. Thank you

 

My auditor didn't dig too deep on this one.  He reviewed our procedure which mentions how our drainage works, how test backflow preventers, and how we train employees to identify and respond to any water/flood/sewage backup issues.  After reviewing the procedure he ticked a few boxes and moved on.  I have backflow test records on file, and training records on file, and even blueprints showing the drainage plumbing, but we didn't get into those.



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