My facility has a very old, stand-alone building that was turned into a freezer in the 1920s/1930s, which was not included in our scope at the time of our certification audit in 2013 (under 7.1) because it would hundreds of thousands of dollars to get all three levels of the building up to SQF standards.
During our certification audit (under 7.1), we never said that we were excluding a building from our scope of certification, we just never spoke of it at all. This was lucky for us because during our recertification audit a month ago, the auditor only asked if there were any changes to be noted and since there weren’t, nothing more was said about it and he moved on.
If we were to have to include that building in our scope, I imagine that I would be doing extensive risk analyses for every problem that we were NOT going to be able to solve (e.g., frost falling off coils on ceiling over product), which included documented evidence that those problems have never caused a food safety problem, as well as documented proof of everything we are doing to minimize the potential impact of these problems on the products we store in that building (e.g., twice daily inspections, daily cleaning). And then I would just wait and see...
I am very curious about how this all plays out! We are the only facility within our company that has this particular issue, so I'm not sure how others are handling it.
- erin -