36 replies to this topic

[nichollaf]

Hi Everyone,

 

We have a glass and brittle plastic program, but we currently do not have a register and a customer is now requiring for us to have one. I can't argue because I know it is a good idea, but I have some questions as to how involved I am supposed to get with this register. Do I include absolutely everything in the processing area (wall clocks, fire alarms, brittle wall signs, etc)? Also, I know they aren't "brittle" per say but what about the UHMW nobs all over the processing equipment? I guess I am having a difficult time determining what plastic to include and what it not of concern. Thank you!

 

-Nichol

[JPO]

AIB SEZ...

 

"WHAT ARE BRITTLE PLASTICS? Brittle plastics are plastics
made from acrylic resins. Acrylic is considered brittle since it
breaks into pieces when subjected to blows beyond its impact
resistance. These materials are marketed under brand names
such as Plexiglass,® Lucite,® Exolite® and Acrylite.® Polycarbonate
plastics marketed under brand names such as Lexan,®
Tuffak,® Zelux,® Cyrolon® and Cyrofl ex® are not considered
to be brittle since they have high-impact resistance."

 

UHMW is NOT a brittle plastic.

 

the above definition is not a be-all of the "brittle plastic" world,  (and some people have the phrase "brittle plastic, glass, and ceramic) but the idea is if you drop it or strike it and it breaks into sharp pieces, it's a brittle plastic. 

 

if it merely dents (like UHMW)  or is punctured with the material being displaced moving to the side, it's not a brittle (stuff here).  The goal is to avoid sharp bits ending in the finished goods.

[mzenas]

Do I include absolutely everything in the processing area (wall clocks, fire alarms, brittle wall signs, etc)?

 

Yes.  Anything that is glass or brittle plastic.

[Ryan M.]

Unfortunately, it is a never ending list these days.  I suggest you look at the risk level associated with the item.  For example, brittle plastic in a storage area that is nowhere near ingredients or products would be low risk even if it did break/shatter.

However, brittle plastic near or above open ingredients or products would be a high risk.  

 

After you define the risk then you can assign a frequency of inspection.  For our process, we really have only medium to low risk since we have only 2 points where ingredients (raw materials) are exposed.  In these areas, the brittle plastic  is not near the exposed materials.  For medium risk we inspect/audit once a month and the low risk is once every three months.

 

You also need to look at historical plastic/glass breakage.  If you have a relatively high frequency of brittle plastic or glass breakage you will need to increase the frequency of your inspections/audits.

[redfox]

Hello,

 

Any plastics that area breakable or has tendency to break you can consider it as brittle plastic. That includes wall clock, voltmeter, ampere gauges, dial thermometers and etc.

We done the monitoring daily. Very tedious and it seems over-kill but necessary during audits.

 

regards,

redfox

[mgourley]

What JPO sez AIB sez is correct.

 

If you are worried about clocks, gauges, etc. I would suggest a low cost test.

Use one of the clocks that are on your wall, hit it with a hammer, drop it from height. If it does not shatter, it's NOT brittle plastic.

 

Hit a gauge...if the above is true, leave it off the list.

 

Certainly any plastic that is directly above or immediately adjacent to a product zone should be inspected, even if it passes the "shatter" test. However, that really limits those items that need to be on a "list".

It is ironic, in that probably 15 years ago, AIB standards basically stated that any glass, brittle plastic or ceramic needed to be on a list and inspected. The fact that they did not, at the time, provide guidance as to what was "brittle plastic", forced many of us to have a list a mile long that was never adequately inspected.

 

If it's a risk to the product, document and inspect it. If it's not, don't.

 

Marshall

[redfox]

Hello Marshall,

 

In our case we demonstrated by showing the video to the auditor that we a using polycarbonate shatter-proof plastic, hammered it and it did break but still we are required to include it in our monitoring list.

 

We still end up doing a monitoring list with that shatter-proof polycarbonate plastic on it.

 

regards,

redfox

[Charles.C]

Hello Marshall,

 

In our case we demonstrated by showing the video to the auditor that we a using polycarbonate shatter-proof plastic, hammered it and it did break but still we are required to include it in our monitoring list.

 

We still end up doing a monitoring list with that shatter-proof polycarbonate plastic on it.

 

regards,

redfox

 

Hi redfox,

 

Does one Auditing Company have a monoply at yr location ? Just curious.

[redfox]

Hello Charles,

 

First I will correct my phrase: It should be "hammered and it did not break".

 

No, the CB is not coming locally. They're from different Asian country and an accredited CB to audit GFSI scheme. Since our mind set during audit that we should not argue to an auditor to avoid any conflict with them. 

 

So, we end up including on the list of Glass and Brittle Plastic Monitoring.

 

regards,

redfox

[Charles.C]

Hi redfox,

 

I deduce you are saying that successive auditors have consistent, probably incorrect, viewpoints. That is worrisome.

[Scampi]

All of our shatter proof light fixtures are inspected daily....as the bulbs inside are not. ALL other plastic are monitored monthly, and I mean ALL of them. That includes all of the electrical conduit, piping in the freezers, wall clocks, hose reels, and the list goes on and on

[pooled]

Also, items in areas close to processing areas should be checked frequently (RA). So mirrors in washrooms, paper towel dispensers, vending machines, plug covers, etc.

[JohnWheat]

Hi redfox,

 

I deduce you are saying that successive auditors have consistent, probably incorrect, viewpoints. That is worrisome.

Was thinking the same thing....

[JohnWheat]

Arguably if you have items that pose a large risk requiring a lot of scrutiny/inspection then a replacement of type and /or material, therefore reducing or removing the risk.    

[Ryan M.]

Correct!  Every auditor/inspector has different ideas of "risk" as it pertains to your process unfortunately.  I have found customer audits/inspections are typically the most inconsistent.

 

I recently had a customer auditor tell me a piece of hard plastic that was below the actual filling of the product was a hazard and needed to be addressed.  Yes, the plastic had a crack in it, but it had not yet produced any types of splinters.  Moreover, the filling equipment is completely enclosed.  As such, even if the plastic had splintered a piece someone would have to pick it up from the ground, open the filler (stopping the fill process) and plop it into a container.  Mind you, the filler is smart enough to know what packages are open and exposed so it turns off the sealing elements thus not allowing the packages to seal.

 

Even after I argued as such the customer auditor was not sufficiently appeased and wrote it up anyway.  This is by far the most frustrating part about all audits/inspections; the inconsistencies in which they audit even to the same standard.  With different standards...forget about it, it is a crap shoot.  It is difficult to push back on customers right now because we are trying to expand our business as we just started up the facility.  

[SQFconsultant]

At our own processing plant we skipped the term brittle and just created a plastic register of ALL plastic and a glass register.  Completely eliminates a customer 1st or 2nd party audit and all 3rd party auditor definitions of what is brittle and what is not, etc.  It's just all plastic to us.

[Ryan M.]

At our own processing plant we skipped the term brittle and just created a plastic register of ALL plastic and a glass register.  Completely eliminates a customer 1st or 2nd party audit and all 3rd party auditor definitions of what is brittle and what is not, etc.  It's just all plastic to us.

 

I'm curious...how many items are on your list?  

 

I ask because if we did this in our facility it would take a week just to get through the list.  It is a waste of time and resources in my opinion.  This is why it is all about risk assessment.  I would rather spend 15 minutes to argue the point and show why we don't include a certain item or why we do include a certain item on the glass/hard plastic register than a week of my QA tech's time.

 

In my previous post I mentioned the customer audit, well they are coming back in a couple weeks for a follow-up audit and if that point comes up again I'm going to argue it.  We have some leeway this time since we have had the customer for 5 months and overall they are very happy with our performance, customer service, and quality.

[SQFconsultant]

Ryan,  at our processing plant for spices and related items we have about 155 items on the plastic register, 50 on glass and about 10 on wood.

 

We are the opposite on the opinion - it is not a waste of time nor resources to us - it is a waste of time and resources to argue.

[Ryan M.]

Ryan,  at our processing plant for spices and related items we have about 155 items on the plastic register, 50 on glass and about 10 on wood.

 

We are the opposite on the opinion - it is not a waste of time nor resources to us - it is a waste of time and resources to argue.

 

Ah ok, 215 items total I can see why it is easier to just do it than to conduct a risk assessment and show what is the actual risk and what is not.  Our register has 258 items as it is which is nowhere near everything in our processing/production areas.

 

I'm all for "best practices", but at the same time there has to be a balance with the cost of doing business.  Lots of factors involved such as size of company, process, facility, value of materials (ingredients, finished products), etc.  You can't be everything to everyone...this is something I've learned through experience.

[redfox]

Hello Ryan,

 

We do risk assessment as required by the standard but per area and type of fixture (ex: lighting fixture in warehouse) not for individual fixture. But we still do list of all brittle plastics and glasses individually and it's done before our operation. In my previous post I stated "tedious and over-kill" coz it really is but needed to avoid NC during audit.

 

regards,

redfox

[adriennemarie]

Hi Do you have a temple for glass registry? one of are auditor recommending us to have that one

[pHruit]

Hi Do you have a temple for glass registry? one of are auditor recommending us to have that one

This is going to depend entirely on your own site.
The document itself doesn't really need to be complex - a list of brittle items, a column to record whether or not they are intact, and a column to add any comments should be more than sufficient.

For some items it might be useful to have a supplementary map / photo guide to illustrate what and where the items actually are. It depends a bit on your site, but it can be a useful document to be able to train against and as an aide-memoire.

[Charles.C]

Hi Do you have a temple for glass registry? one of are auditor recommending us to have that one

 

See -

 

https://www.ifsqn.co...er/#entry151649

https://www.ifsqn.co...ter/#entry62686

https://www.ifsqn.co...ter/#entry62993

https://www.ifsqn.co...ter/#entry24985

https://www.ifsqn.co...te/#entry152712

[lorlandini]

At our plant, we created our register by identifying all the plastic and glass parts in the entire plant.  It is an extensive list.  We then did a risk assessment of the parts and made a register for daily, weekly, monthly and semi-annual inspections.  

 

Leo

[SafetyP]

Hello all, 

 

Just curious. Should "safety glasses" (PPE) and or "Prescription glasses" be added to the glass and brittle plastic registry? How do you mange control with 500 employees half of which are seasonal temps? 

 

Thank you in advance for your opinions.

Edited by SafetyP, 06 March 2020 - 07:50 PM.