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Labeling secondary containers with lot numbers and expiration dates


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#1 regina.huffman

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Posted 07 April 2017 - 03:03 PM

Please help me out.  While auditing, I noticed several alcohol spray bottles  (secondary containers) used in the production rooms that were only labeled "Alcohol" and not with the lot code and expiration date of the primary container from which the bottles were filled.  When I raised the issue, I was asked where in the SQF code does it state we have to label secondary containers with the lot code and expiration date.  I stated that the code states we will adhere to all regulatory requirements (OSHA, EPA, USDA, etc.) and that the code does not explicitly state, "Label all secondary containers with lot code and expiration date".  Can someone give me direction as to what guidance document the requirement for secondary container labeling with lot code and expiration dating is located so I put this puppy to rest.

 

Thanks,



#2 Scampi

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Posted 07 April 2017 - 05:16 PM

The MSDS (now SDS) should be replicated on smaller containers-----we get our sanitation chemical in drums and pump it into smaller containers for the dosatron---the small containers are clearly labelled with an SDS---it is my understanding that this is an international system--alcohol is a chemical after all that could be harmful if ingested so from a straight up H&S view it should be labelled regardless of what food safety scheme your following 

 

 

Alternatively---a sign out sheet could be used for recording when the alcohol is decanted and from what lot it was taken


Because we always have is never an appropriate response!


#3 regina.huffman

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Posted 07 April 2017 - 07:10 PM

I have fought this battle before, but the powers higher than me want a black and white statement from a CFR, Code or something stating you have to put a lot code on it.  I mean, you have to have the HAZCOM labels filled out and the chemical labeled as to what it is, how hard would it be to put expiry on it also. In my past life I worked in the pharmaceutical industry and I am told I am too "Pharma" in my thinking. 

 

I love the idea of the sign out sheet.



#4 Charles.C

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Posted 08 April 2017 - 06:19 AM

Hi Regina,

 

Expiry date ?

 

https://www.reddit.c...bky&sh=755d5cf0

http://www.firstaid....rs_Expiry_Date/

 

I suspect yr search for a "statement" will be in vain but I wish you luck and await yr conclusion with interest.


Kind Regards,

 

Charles.C


#5 regina.huffman

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Posted 10 April 2017 - 03:23 PM

Thanks, I will put up anything I find. 



#6 mec862

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Posted 10 April 2017 - 05:00 PM

Hi Regina,

 

This would be an OSHA requirement from a safety perspective. I can't  think of a regulation from a food safety perspective. Although, it is extremely important.



#7 regina.huffman

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Posted 10 April 2017 - 07:41 PM

That is what I told the higher ups.  They stated that we use out primary supply up before the expiration date, so it should not be a problem.  That is why I was searching.  It is not like I am asking for the entire SDS placed on the secondary container.



#8 Michelle Grace Astorga

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Posted 11 April 2017 - 12:39 AM

It is a safety requirement, you may also want to check OSHA






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