12 replies to this topic

[Jvalentin]

HI All, 

We currently have our SQF Certification Level 2 and we handle Loose Leaf Tea.  We have 3 Clean Rooms , 2 of them are for Processing and one of them is for Inspecting products.  We use the Inspection room to inspect raw material at receiving.  We inspect for foreign material and compare for quality.  My question is do we need a separate 

inspection room or can I use one of my processing rooms to conduct my inspections?  I was not sure if the code required an inspection room separate than processing areas.

Thank you

[FSQA]

Jvalentin,

 

Generally, IMO you should prefer to keep you RM segregated from your finished/processed product.. If you are inspecting the raw material in the same room where your processing is conducted, it might be difficult to segregate both the products and control your hazards between pre and post processing.

[Brendan Triplett]

Jvalentin,

It appears, from your description, that you have 3 clean rooms and the only real thing that differentiates them (if your processes are the same) is the title that you give to them about whether they are used for inspection or processing. As long as you have a clear delineation in the steps that you take from one step to the next I think that it would be fine to use the same room. Your steps for processing would be the same regardless of the room that the product was inspected in. FSQA mentions something about raw products. Are you receiving more than one product? Are you reviewing how to inspect and process one material in the same room or are you looking to inspect different products and process them in rooms interchangeably? If you are bringing in a material, inspecting it and then processing it in the same room I do not see too much of an issue. Would love to hear if anyone has experience in this area however.

[SQFconsultant]

Many facilities have an "inspection area" for in process product without the need for separation.

However you mention that you check raw materials... I would keep things as they are to prevent the eventuality of crOSS contamination to in process.

[Tony-C]

Hi Jvalentin,

 

There seems to be some confusion here, are you processing or are you packing? If processing what is the process?

 

SQF requirements are straightforward and require:

11.2.6 Inspection/Quality Control Area

11.2.6.1 A suitable area shall be provided for the inspection of the product if required.

11.2.6.2 The inspection control area shall be provided with facilities that are suitable for examination and testing of the type of product being handled/processed. The inspection area shall:

 i. Have easy access to hand washing facilities;

ii. Have appropriate waste handling and removal; and

iii. Be kept clean to prevent product contamination.

 

Your current system seems fine with a separate room, why would you want to change it?

 

Kind regards,

 

Tony

[012117]

in case there are some confusion, understanding the risks from your process and product will help you resolve it. If you see some possible cross contamination in your process, then it may be separated. If none, it may be good as what is available currently.

[Brendan Triplett]

Jvalentin,

 

012117 makes a good point here.  I would not process and inspect any raw materials that contain allergens or have a high probability of cross contamination with pathogens.  There is just too much risk associated there.  SQF code is trying to ensure that you minimize that risk as much as possible.  I do not, however, see an issue with receiving tea leaves and sugar in these rooms as long as you have controls in place for spills and quarantining.  A challenge that you might face though is that if you quarantine product for adulteration or contaminates you may end up shutting a few rooms down if you are using them at the same time rather than just shutting down one room.  Does your company anticipate a marked increase in the speed of processing by using multiple rooms or are they just checking to see if the rooms can be changed from time to time?  Is your current system too slow or ineffective?

[Jvalentin]

HI All, 

Thank you for all your answers.  To elaborate a little.  I am in the middle of getting our Handler Organic Certification and I decided to dedicate one of our rooms for that use.  What we currently do is blend and repack loose leaf tea.  The extra room will be used for non-organic blends and repacking.  As for the inspection room what I would like to do is put our Tumbler in there to be used for Organic and Non-Organic blends.  What I am trying to avoid is the change over cleaning in between Organic and Non-Organic.  At least with tumbler separated in smaller room it will be easier to clean and manage.  Our Product is low risk and we receive all of our tea from approved suppliers.  All we do is mainly check the quality of the tea.   I am just trying to figure out how to juggle SQF and Organic Certification.  

Can I use the Inspection room and also have the Covered Tumbler inside there and just document the cleaning before and after either an inspection of product and or a Tea Blend. 

[Scampi]

I have 6 audits a year, two of which are Organic (farm and processing)

 

I have not duplicated paperwork where I don't need to for SQF and organic. Our process (like yours) remains the same regardless of what type we are processing.....we don't run both on the same day if we can help it and if not Organic first

We run low risk foods, so I switched sanitation chemicals this year to one that meets the biodegradability requirement for organic, but still does a great job

 

The only comment my organic auditor had was we had no specific organic handling training............so i modified another document and voila!  All compliant

[Jvalentin]

HI Scampi, 

So I am writing my OSP for my Organic Certification and it will tie into my SQF sanitation program.  I was trying to avoid the hassle of using the Clean Room for Organic and Non-Organic material but it is probably better that I write in my plan the changeover process.  May I ask what sanitation chemical do you use?  I use Eco-Lab and asked them what they have that and this was thier response.

 I was told we could use certain products as long as we are using a chlorine based sanitizer on the three compartment sink instead of the mulit quat sanitizer as the final part of the wash rinse and sanitize process.

 

What I propose doing would be to use the following

Pantastic ( Pot & Pan Soap ) and the Eco San ( sanitizer ) on the three compartment sink to wash/rinse/sanitize any wears

 

Any suggestions I am sure you encountered this.

[Scampi]

We use crystal simple green...........I've attached all the documentation they sent me

My organic auditor had not heard of this but was really impressed with the 100+% biodegradability in 28 days.  Boss likes it because now it's all we use and it's user friendly. Safe up to a 1:1 dilution (but here's hoping no one ever uses it like that)

 

Due to the nature of our process we are sanitizing with 12% acetic acid as our sanitizer 

Attached Files

•  TOX_SimpleGreenAPC-and-Crystal_TCLP_02-21-12.pdf   39.95KB   9 downloads
•  BIO_Crystal_OECD_302B_Inherent_Biodegradability_10-16-13.pdf   771.2KB   7 downloads
•  TOX_Crystal_Aquatic_Mysid-Shrimp-LC50_Trinidad_-US-EPA-600-4-90-027F_2-15-16-&-confirm.pdf   3.82MB   8 downloads
•  Crystal_confirmatory_BioResearch Lab Trinidad_OECD301D to 100%_28 days.pdf   409.07KB   5 downloads

[Scampi]

It was really hard to find anything I thought would do the job and be organic approved and this was the best I could find

 

No I didn't talk to ecolab or diversey, but I knew they wouldn't have what I needed

 

PAA is supposed to be approved for final sanitizing, but I would ask you CB directly before using (apparently not all are on board with it yet)

[gud2ya]

Is the inspection room part of the process or is it a receiving procedure? i suggest a separation from other processes especially if these are raw materials subject to acceptance or rejection. however, even if these are already accepted, there should be a separation in terms of space or a partition because different process steps involves different risks.