11.7.5.3 Use of temporary fasteners
11.7.5.3 The use of temporary fasteners such as string, wire or tape to fix or hold equipment shall not be
permitted.
We have a horizontal mixer that tilts only one way. We use plastic sheeting on the frame under the bowl and the floor on the side that the mixer tilts to. Currently the plastic is being attached to the frame & floor using duct tape. This is not anywhere near a food contact area and is there for ease of clean up (clean up everything, tear up the plastic & tape, scrub, mop and reapply).
What I'm wondering is that the code states "to fix or hold equipment", IMO plastic sheeting would not be 'equipment'. Would you appeal this non-conformance?
In my experience, tape is frowned on because it can trap dirt, insects and be a source of cross contamination. (Although if this isn't near food or a food contact area, contamination is less of an issue)
If there is an easy repair, I would not waste an appeal on it. Since the standard lists tape specifically, I would think it needs to go.
Setanta
I'm in the same boat my friend. In my process (food packaging) we apply adhesives using a messy open system and tape down plastic film and cardboard for easy cleanup. Like your situation these materials are disposable and not "equipment". We even initial and date them to show that they are not too old.
I've got my first SQF audit in May and we're struggling to figure out a replacement for these materials. Gap auditor says they need to go or we'll get a finding.
Hopefully someone with more experience can chime in.
Dear Pizza & Sandwich,
The intent for this requirement is to discourage tape-maintenance.
If all your machinery is maintained in good condition and you use the tape to fix sheets on the floor, wit the intent to ease cleaning, which are removed daily, I will not make a NC for that. Unless, there is another food safety or safety (staff) hazard related.
Dear zac 2944,
I understand that in your case the carton and tape is used to "close" an open system. I would see this as a temporary fix, because it is probably possible to make a permanent solution, e.g. a lid on the open system. Therefore I would score this with a NC.
Please note, I am not a SQF auditor and do not know the standard. I am speaking out of general GMPs.
If temporary repairs are a source of contamination for the product this is not the clause to raise the finding. This clause is related to maintenance practices where the use of tape and temporary fasteners is a common practice that must be eliminated not because is a potential of contamination, is just because is not the right way to fix it. Tape, cords, cardboard, etc is an informal fix.
As you can see from the responses, much of the decision depends on how the auditor views the local situation, surrounding area, general work practices and exposed product proximity.
I am an ISO22000 auditor and in your situation, (having not seen the location), I would typically encourage the manufacturer to look for ways to eliminate the practice of using tape and plastic. The level of 'insistence' depends on the situation. Could be from an observation through to major. Just depends.
Recommendation, get some brains together and work out how to cost effectively eliminate it.
cheers
If temporary repairs are a source of contamination for the product this is not the clause to raise the finding. This clause is related to maintenance practices where the use of tape and temporary fasteners is a common practice that must be eliminated not because is a potential of contamination, is just because is not the right way to fix it. Tape, cords, cardboard, etc is an informal fix.
IMO tape maintenance = temporary repairs, but you are probably right that it is not.
In my previous post I ment tape maintenance.
I understand the no string, wire and tape. What is the status for the use of zipties?
what is the status for the use of zip ties for temporary repair ? is it acceptable ???
I understand the no string, wire and tape. What is the status for the use of zipties?
what is the status for the use of zip ties for temporary repair ? is it acceptable ???
Thread is 2 years old. Maybe will be some delay in answering.
OK, Thank you Charles