Here is the guidance on that element for food manufacturing (there is no guidance available as yet for packaging). there is likely very little difference between the modules
11.3.10 Implementation Guidance
What does it mean?
Employees, contractors and visitors are not permitted to eat or drink in food handling areas (refer to 126.96.36.199). Designated lunch rooms must therefore be available for staff to take breaks and eat meals.
These areas must be physically separated from food handling areas. Without a door and walls how are they going to keep the lunchroom physically separate from the plant? and i would caution about just building a box........if there is a flat ceiling above it, it creates a place for dust and debris to gather contaminating your food contact packaigng
What do I have to do? The supplier may provide additional outdoor lunchroom facilities (e.g., picnic tables) where they do not pose a dust or pest hazard to the processing area of the site. Covered facilities and sealed paths are one way to address these hazards. Where hazards presented by such facilities are minimal, the supplier may employ alternative controls such as routine cleaning of tables and steps to minimize dust on non-sealed paths. Foot baths also provide another means to ensure that foot traffic does not bring dust or other contaminants into the processing area, if practical to do so. Each site shall be equipped with a ventilated and well-lit lunch/break room for employees. The room must be equipped with a sink serviced with hot and cold potable water, a refrigerator and a microwave. The area must be kept clean.
11.3.10 Auditing Guidance
This element will be audited as part of each site audit through observation and interviews with operational staff.
Evidence may include: Separate lunch facilities are provided; Lunch room facilities are adequate for the number of staff; Lunch facilities are separated from processing, product storage or handling areas; Lunch room facilities are properly ventilated; Lunch room facilities are well lit; Lunch room facilities include a sink with hot and cold running water; Lunch room facilities are clean and tidy; Proper heating or cooling facilities are provided in lunch facilities; Hand wash signage is available at the exit of the lunch facilities; Hand wash signage at the exit of lunch facilities is in appropriate languages.
I would email SQFI and ask them for packaging guidance........if management is saying the code isn't specific enough you're in for a bumpy ride