Glass Audit Registry Magnitude

Good Morning. I'm new to SQF packaging this year coming from 7 years experience in BRC for food industry. The organization I joined has a very extensive glass audit registry that covers the entire manufacturing facility and not just open product areas. A couple years ago BRC made note of the exhaustive lists and said that only areas that were over open product or in line and posed a risk for physical contamination needed to be on a registry.

I spoke with my SQF auditor this year and it appears that SQF is still expecting exhaustive lists that cover the entire manufacturing environment. I'm thinking I can perform a risk assessment and shrink my registry down. Has anyone else done this or have any insight into this?

Thanks,
Mark 

my registry is also very extensive and covers the entire plant, I have not done a rick assessment because as you noted the auditors are looking for extensive lists. 

my list ONLY covers areas where product or packaging would be impacted

I do not list washrooms/lunchrooms/offices etc

Basic GMP's should be enforced that would cover any issue that may arise

So glass/brittle should be monitored in warehouse/coolers/production areas (or where ever broken things could cause a problem)

My SQF auditor was fine with my list

Auditors should be following the auditing guidance (as quoted below)

If the risk assessment is acceptable to shrink down your list please respond back here to let us know. During our last SQF audit the exhaustive list was still required. Anything to make the list even remotely smaller would be nice.

Why are we (the ones paying the bills for these audits) not demanding that auditors follow the guidance???????????

GFSI only work when they are applied equally to all?  The guidance does not state exhaustive list AND is published by SQFI

The more time we (as the food safety specialists) spend on ridiculous items that add no value to the safety of our productions, the less time we and our monitors have to spend on items that DO produce safer food................

This is something I've also wondered. If your risk assessment effectively proves contamination can't/won't occur and it is substantially backed by facts/past results then there isn't much in section 13.7.2 of the code the auditor could use to refute. Of course, all auditors are different, but if auditing to the code I feel it would be a difficult contest. Unfortunately, there is still risk in getting away from the exhaustive list!

You are correct that the BRC requirement is less than the SQF.  I have been challenged by auditors at sites that did not have their storage areas included in their registry list.  I have never been challenged to include areas such as bathrooms and offices.  Just the production and storage areas keeping in mid equipment that moves through these areas such as fork trucks with glass screens or mirrors.  Even though you may be required to have an exhaustive list you can decide the audit frequency so as part of your risk assessment you can decide to only audit certain areas as few as once per year.  The only area that has a specific audit requirement in the standard is the 13.7.2.6 Glass  instrument dial covers on manufacturing equipment, equipment covers, and MIG thermometers shall be inspected at the start of each shift to confirm they have not been damaged.

Will it work, if we did risk analysis for the whole area initially, based on the assessment identify areas (high, medium, low and not significant) and implement a control measure - daily/weekly for high risk, monthly for low risk. The risk analysis can be updated with new changes and reviewed every year. 

That really depends on your certification type.  Are you BRC or SQF?

Will it work, if we did risk analysis for the whole area initially, based on the assessment identify areas (high, medium, low and not significant) and implement a control measure - daily/weekly for high risk, monthly for low risk. The risk analysis can be updated with new changes and reviewed every year. 

That really depends on your certification type.  Are you BRC or SQF?

BRC

That will be absolutely fine for BRC and is pretty much their expectation - as per clause 4.9.3.2 for both Issue 7 and Issue 8:
"These procedures shall include.... recorded checks of the condition of items, carried out at a specified frequency that is based on the level of risk to the product"

We use this exact same approach, with weekly inspection in processing areas and monthly elsewhere.

I agree as long as you have a good risk assessment for BRC you should be fine.

Leave it extensive.