Non-food grade production as part of Food Grade plant

Good morning, all!

We are getting ready for our next SQF recertification audit and we have a bit of a quandry.

We have our main production facility that is completely food grade - that is not a problem. 

Our question comes into play where we are using a section of our distribution center to produce non-food grade products.  This section is closed off from the distribution center.  

We produce food flavorings and extracts, as well as smoke juice for the e-cigarette industry and some other non-food grade products for the spirit (liquor) industry.

Is there anything that we need to do to ensure that this area is not an issue during our SQF re-audit?  We have procedures in place, and are going to place sinage in the area stating it's non-food grade only.  

I have heard of some plants only certifying a room or portion of their plant - I just need to now if there is more info out there on this subject?  Or does anyone have any experience with this? 

Any input would be greatly appreciated.

Lynn

That is what I am trying to find out - how do we designate that area as a non-SQF area without it being an issue during our audit?  Is there something we need to do, as far as posting sinage or designation?  There ARE some food-grade ingredients in the flavors - they are added in the production facility - but also, non-food grade, which is added in the section of the distribution center.  The final product is considered non-food grade.  

Have a designated storage area that is away from food grade storage,  you may need separate ventilation, signs are good... sinks for employees to wash their hands when entering and exiting if they are exiting into a food grade area.  I would look at maybe color coded equipment (cleaning etc) for the non-food grade area...

Does your hazard analysis talk about this area at all and what hazards may have been introduced to your system by having it? 

Those are my surface thoughts on the situation.

(btw you can send me any e-liquid components you have for taste testing lol.  I have a vaporizer :shades: )

Hmmm...good point.  Everything that is finished is stored in the area it's made in until it's ready to ship.  Ventilation - that would be tricky since our audit is next week.  And, food grade and non-food grade are shipped and received from the same distribution center, so not sure if there is a designated "food grade" area that would come into play in that building?  The distribution center and the production building do not have the same GMP rules, either.

There is nothing made in that area that is food grade - everything food grade is made in a different building and then shipped down the street to the distribution center to the non-food grade area.  So, cleaning of the equpiment and equipment used is designated to non-food grade use only.  No chance of cross contamination as far as that goes.

No, it's not in our hazard analysis because it's not in the same plant as food grade.

(btw....we have over 250 new flavors going into production next week, lol.  we may need some testing)

And in a rare spasm of generosity, *I* would be willing to sample your spirit selection…

HA!  We have had many volunteer for that one.  We had a red velvet vodka come through recently that was very nice.....

 

 

 

(btw....we have over 250 new flavors going into production next week, lol.  we may need some testing)

Well I am a Quality Manager who has had to test pasta sauce as a quality technician for flavoring and a I was a quality coordinator that had to taste test yogurt flavors.... I won't even charge you :roflmao:

:off_topic:      :oops2:

I would suggest setting up a food grade / non food-grade storage area.  Also do not store non-food grade materials over food grade materials.  If there are allergens involved keep them segregated properly.  If you are using PG in your vape materials you want anything with PG probably segregated together seeing as some people are sensitive to PG (Propylene Glycol)... I'm not sure how important that might be but it shows you thought about it...

Well I am a Quality Manager who has had to test pasta sauce as a quality technician for flavoring and a I was a quality coordinator that had to taste test yogurt flavors.... I won't even charge you

 
HA!  There ya go - we do a little of everything....baking, tobacco, fish bait, veterinary, dietary, beverages, spirits, you name it basically.  The worst ones to taste test are the butters.....and egg (I like eggs, but one of our egg flavors makes me nauseous).    
 

I would suggest setting up a food grade / non food-grade storage area.  Also do not store non-food grade materials over food grade materials.  If there are allergens involved keep them segregated properly.  If you are using PG in your vape materials you want anything with PG probably segregated together seeing as some people are sensitive to PG (Propylene Glycol)... I'm not sure how important that might be but it shows you thought about it...

 
That we already have - all the non-food grade is in one room.  It's only moved to shipping when ready to go on the truck.  All the non-food ingredients are also in this room, in locked cages.  We have a solid allergen program (delegated to bottom shelf only, and like over like only).  We do use PG, but it's used in our food-grade ingredients also, so PG is actually in bulk tanks outside.  Most of the bases are glycerine.  Sounds like we may have had the same train of thought - label as non-food grade production and keep everything used for non food grade in that area.

And in a rare spasm of generosity, *I* would be willing to sample your spirit selection…

 ooohhhh me tooo!!

 
HA!  There ya go - we do a little of everything....baking, tobacco, fish bait, veterinary, dietary, beverages, spirits, you name it basically.  The worst ones to taste test are the butters.....and egg (I like eggs, but one of our egg flavors makes me nauseous).   

Used to do sauces....the jerk sauces really did me in.  Ruined my ability to taste well the rest of the day. 

HA!  We have had many volunteer for that one.  We had a red velvet vodka come through recently that was very nice.....

oooohhhh....pick me, pick me!

"That is what I am trying to find out - how do we designate that area as a non-SQF area without it being an issue during our audit?  Is there something we need to do, as far as posting sinage or designation? "

Per the 7.2 code update that goes into effect in July, if you want to exempt a part of your facility from the SQF audit, you must now submit a formal written request to your certification body.

We are a candy company & bakery, but in our downstairs portion of our facility we also have a separate area that is for ice cream production. We do not include the ice cream production under our SQF umbrella. Previously, we simply explained this to the auditor once he/she was on site (it's never been listed on our scope), but this year I had to submit a formal request to have the area exempted. It was approved without issue...just took the formality of submitting the request...

"That is what I am trying to find out - how do we designate that area as a non-SQF area without it being an issue during our audit?  Is there something we need to do, as far as posting sinage or designation? "

 

Per the 7.2 code update that goes into effect in July, if you want to exempt a part of your facility from the SQF audit, you must now submit a formal written request to your certification body.

 

We are a candy company & bakery, but in our downstairs portion of our facility we also have a separate area that is for ice cream production. We do not include the ice cream production under our SQF umbrella. Previously, we simply explained this to the auditor once he/she was on site (it's never been listed on our scope), but this year I had to submit a formal request to have the area exempted. It was approved without issue...just took the formality of submitting the request...

So, we should be ok with our audit that starts tomorrow, since the new code doesn't go into effect until July?  We have the area designated as non-food grade.  We aren't doing production over there right now - it's only a small portion of our business right now, but will become a larger one next year.

I would certainly think so. You sound confident in your approach, so you should be fine with the auditor! As long as you maintain similar controls (pest control comes to mind) I'd think it will be a non-issue as it was for us. I think that provided the exempted area adds no Risk to your food production, you're good.

I would certainly think so. You sound confident in your approach, so you should be fine with the auditor! As long as you maintain similar controls (pest control comes to mind) I'd think it will be a non-issue as it was for us. I think that provided the exempted area adds no Risk to your food production, you're good.

Fabulous!  Yes, we have everything else in place - this is the only different thing we have this year, and honestly, we didn't give it a whole lot of thought because up until a few weeks ago, we were not producing in that area, hence the concern at the last minute.