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Clause 13.2.2.3, Roof drain pipes that cross over production equipment

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Best Answer , 03 March 2017 - 06:51 PM

Put something that would catch any drips and direct the water flow towards a low risk area or a drain. I have seen this in other production facilities. We have this in our coolers under the compressor to catch condensation or fluid leaks, the auditor was very pleased with it.


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tezza07

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Posted 01 March 2017 - 08:57 PM

We had an SQF gap assessment that had issue with overhead roof drain pipes that cross over some of our production equipment (we are a flexible food packaging manufacturer).

 

Clause 13.2.2.3 (re: waste trap system)

Comments: Overhead waste pipes run over where exposed packaging material are at the machines.

Recommendation: Recommend risk assessment and regular inspections until permanent action taken to cover pipes or exposed material.

 

This was listed as a critical non-conformance in the report. During the closing meeting it was mentioned and I thought this would be something we could address solely by regular inspections - these pipes have never leaked. Based on past precedence would it be safe to say the risk is low and that the permanent solution could be the regular inspections in and of themselves?

 

Have any of you on here ever had this come up in a gap assessment or an audit and, if so, how did you address it?

 

Thanks!



SQFconsultant

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Posted 02 March 2017 - 01:18 AM

If the pipes are in good condition and not leaking I might see a major finding; however by definition this is not a critical - look up the definition.

With that in mind we consulted with a food manufacturer that is housed in a building that used to be a brewery and had similar piping over (miles and miles of piping) over their packaged products in the warehouse and while many of the pipes were not in bad condition the recommedation was to seal up the ones that could not be removed, mark them ad to what they conveyed and it never came up on the audit.

I don't beleive the critical finding is justified by the SQF definition of a critical finding if what you say is correct.

Gotta know the definitions of findings when you go into your live cert on site audit so that if nessacery you can challenge a finding.

In the meantime if you can't re route the pipes you can have routine inspection of the pipes for condition, mark them as to what direction the flow is and name them. Document you pipe audits and risk analysis until you can cover, box in etc and that should satisfy the auditor.


Kind regards,
Glenn Oster

GOC GROUP | SQF & EESystem Operations Consultant

www.glennoster.com

tezza07

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Posted 03 March 2017 - 03:43 PM

Thanks for the info! I will make sure I'm prepared so I can challenge any questionable findings during our audit.

 

I'm not sure what you mean when you said that they "...seal up the ones that could not be removed..." - how did they seal them? If you know I would love that info as we could potentially use that as a solution to this issue.

 

It's a single pipe that is painted white and is in good condition - could use a fresh coat of paint. We are not able to box the pipe in, so we are hoping that a fresh coat of paint and labeling it as "roof drain" with flow direction, and with regular inspection, that it will be sufficient to address the non-conformance.



itreatpets

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Posted 03 March 2017 - 06:51 PM   Best Answer

Put something that would catch any drips and direct the water flow towards a low risk area or a drain. I have seen this in other production facilities. We have this in our coolers under the compressor to catch condensation or fluid leaks, the auditor was very pleased with it.



jcohen246

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Posted 06 March 2017 - 08:59 PM

As itreatpets mentioned, use drip pans. Be very careful with potentially flaking paint. If it flakes onto your product while an auditor is there, that would be a critical non-conformance.



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Posted 09 March 2017 - 05:51 PM

Put something that would catch any drips and direct the water flow towards a low risk area or a drain. I have seen this in other production facilities. We have this in our coolers under the compressor to catch condensation or fluid leaks, the auditor was very pleased with it.

 

This.  Your regular inspection would include the drip pans and the piping.



tezza07

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Posted 23 March 2017 - 01:16 PM

Put something that would catch any drips and direct the water flow towards a low risk area or a drain. I have seen this in other production facilities. We have this in our coolers under the compressor to catch condensation or fluid leaks, the auditor was very pleased with it.

 

Thanks for your input, I really appreciate it



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