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Allergen Management

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#1 jdsummers6

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Posted 08 April 2019 - 01:09 PM

Hello gang,

 

Tried replying to an older thread and didn't get any hits back. Apologies for "doubling up". 

 

We are a paper converting company and deal with some food grade papers, and so we are pursuing SQF certification in fall of this year. Had a question regarding employees and lunch boxes that I hope we can get some assistance with. 

 

Our employee entrance currently is adjacent to the employee parking lot. From the moment you enter this door, you're in a production zone. When they enter the building in the morning, no machines are active. They carry their lunch boxes through a production area, then a warehouse area, then enter the break room where they place their lunch boxes and prepare for our morning staff meetings. My question is this: will a risk assessment that determines lunch boxes (no Walmart plastic bags, etc) with a zipper or Velcro enclosure only are approved suffice to allow these to pass through these zones? And what about employees that want to eat their lunch in their car and pass back through during production hours? 

 

Looking forward to your advice and wisdom.

 

Justin



#2 The Food Scientist

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Posted 08 April 2019 - 01:24 PM

 

Hello gang,

 

Tried replying to an older thread and didn't get any hits back. Apologies for "doubling up". 

 

We are a paper converting company and deal with some food grade papers, and so we are pursuing SQF certification in fall of this year. Had a question regarding employees and lunch boxes that I hope we can get some assistance with. 

 

Our employee entrance currently is adjacent to the employee parking lot. From the moment you enter this door, you're in a production zone. When they enter the building in the morning, no machines are active. They carry their lunch boxes through a production area, then a warehouse area, then enter the break room where they place their lunch boxes and prepare for our morning staff meetings. My question is this: will a risk assessment that determines lunch boxes (no Walmart plastic bags, etc) with a zipper or Velcro enclosure only are approved suffice to allow these to pass through these zones? And what about employees that want to eat their lunch in their car and pass back through during production hours? 

 

Looking forward to your advice and wisdom.zi

Justin

 

Hi Justin,

 

First, my suggestion for them eating in their car and passing through production area, is placing hand washing stations with signs indicating employees must wash hands before entering. (you can do some observations of employees to verify they are complying). Also assess they're outer garments on the way..

 

For the second part, yes perform a risk assessment to determine the level of protection of employee food (which lunch boxes to approve). Also depends on how close they are to the production zone when passing by, is it way too close to the machines? Do some sort of segregation like signs, tape, paint....etc. to prevent any cross contact. Don't forget to TRAIN TRAIN AND TRAIN everyone on this! Hope this helps!


Edited by The Food Scientist, 08 April 2019 - 01:25 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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#3 SQFPKevin

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Posted 08 April 2019 - 01:40 PM

Hi Justin,

 

That is a tough situation. I am also in the FG paper converting industry. Ill let you know how we solved a similar issue, hope it helps. 

 

First, as part of our employee training, we mandate all employees sign off acknowledging this GMP rule (checking this is being followed on our internal audits). 

 

Second, we put up a small foyer around the entrance as a physical barrier and have a designated GMP walkway on the perimeter of our plant to get into the lunch room. Its only about 60 feet. This walkway is Non-GMP. The walkway is also separated by a physical barrier, about waist high (this was done in sections due to the expense) and our auditor was completely fine with this.

 

We justified allergen control with our GMP's. 

 

We are a low-risk facility and had our audit last month, he had no issues.  



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#4 zanorias

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Posted 08 April 2019 - 01:49 PM

I can't speak on the SQF standard, though carrying any personal items through a production area concerns me due to contamination hazard; what if a peanut bar wrapper from an employee's lunch box falls into the production area whilst travelling though it, or even a piece of zip or something from the box itself? It's relatively simple to control industry standard equipment i.e. pens/clocks/rulers, though I fear staff lunchboxes and their content may present a less controlled risk.

 

For staff wishing to eat in their cars, can they not leave their lunch box in the car and choose temperature appropriate foods? Rather than taking it through a production area twice before using it.



#5 tezza07

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Posted 08 April 2019 - 01:59 PM

We are a paper converter specializing in food contact packaging products, and we've been through 2 SQF audits so far.

 

As long as you designate a walkway and document the risk assessment then it should be okay. Our walkway is a non-GMP area and is open to the production area (we have a rail to designate the walkway but no solid barrier like a wall). We do not allow employees to eat or drink on the walkway. I would also specify in your GMP Policy that they cannot carry open food or drink on the walkway as an added precaution.

 

As with eating lunch in their cars, this is no different than if they eat a meal at home and then come to work. you just have to ensure that you have proper procedures in place to mitigate allergen risk upon entering production areas.

 

Side note: I'm assuming after your meetings in the break room that employees just go straight to their designated production area? If you don't have a designated hand washing station at the point where they enter the production area to start work, I would suggest you look into having one installed as that will be an issue during your audit. 13.3.2.1 states that they shall be provided in appropriate areas, and 13.3.2.4 (i) states that they have to wash their hands on entering production areas.



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#6 SQFconsultant

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Posted 08 April 2019 - 03:41 PM

As they walk directly from the outside to the production area you will need to install hand washing stations right at the entrance.  I would restrict employees to only eating their meals in the lunchroom. As to bringing their meal boxes into the production area I would do exactly what Kevin mentioned and that is to establish a non-gmp pathway with a barrier that runs from the hand washing area to the lunchroom.  And heavily train on GMPs.


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
 

 

Serving the New Republic of the United States of America, Costa Rica, Panama & Caribbean Islands

 

 


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#7 Julie Y

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Posted 12 June 2019 - 10:57 PM

Agree with all the above. You will need to have a designated hand wash station for employees to wash their hands. We created a "non-GMP zone" area where it is taped off and have a taped "non-GMP walkway" for employees to bring their lunches to the lunch room. We also installed an additional hand wash station outside of the lunch room where we could easily monitor and ensure that employees were washing hands before going back to work. We train our employees to bring food in containers or bagged and in addition, we have them sign off on our GMP policy where it states the non-GMP zones and hand washing policy.







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