Waste Containers

Looking for some advice on waste containers.  I joined my company about 6 months ago and recently uncovered an "interesting" practice regarding waste containers.  The company recycles empty packaging containers to capture waste and recyclables.  The boxes are labeled and only used once.  At the end of the shift, or whenever full, they get moved to the dumpster or recycle area.  I understand the good-intentions behind the practice - they are trying to reduce waste, etc.  However, the practice does not meet SQF Code requirements.  We are SQF certified, and I cannot understand how an auditor has not observed this practice over the years and not said anything. 

Understandably, operations and sanitation want to keep the practice as is.  I want to ensure we are in compliance with SQF code and regulatory requirements.  My issue is that boxes are not cleanable, nor are they designed for this purpose.  What happens when a box doesn't get labeled as waste (and we all know that it WILL happen)?    

Anyone encounter this type of issue?  Am I making a mountain out of a mole hill?

Hi, Jennifer;

No, not a mole hill by any stretch (per SQF code 11.4):
 

Obviously you're more than aware at this point that this is an extremely dangerous practice, more so since packaging is being used. Waste management is in my experience an area of inspection that will cost a certification for non compliance, or as the worst case scenario a regulatory shut-down.  It's a beast to manage unfortunately and will turn every last hair on the head grey. Management needs to tune this up post-haste. 

Best of luck!

While Slab is right, iI am curious about the product is and more about the environment.  Are we talking about large Gaylords?  I have seen other companies recycle Gaylords to hold plastics and cardboards in a dry environment that is not high risk and SQF was okay with that.    

Yes, we are a dry environment and the boxes, etc. are typically being used to hold recyclables.  Slab is definitely right - waste management is an area that cause major headaches.  In my short tenure, I have found that this one area that needs serious improvements. 

Thanks for confirming my initial thoughts!

I agree that this can be a very tricky situation.  However, if your facility feels like it must do this then your team can type up a risk assessment that supports why the containers are acceptable to use as waste containers.  Hopefully your company has a written program or procedures in place on the control of the containers and, if you have not already done so, include a review of this in the internal audits. It goes a long way to support your risk assessment if you have some type of micro testing to back up your procedures. 

There are a few things that we do not follow the SQF Code on and we have a risk assessment on each one supporting that what we are doing is acceptable.  So far this has been accepted by the SQF auditors and we have had 4 different auditors over the years.