We process food packaging products such as butcher paper, steak paper, and the like. The master rolls come from SQF (or equivalent) certified facilities and we rewind the rolls into smaller rolls, or cut it into sheets. For a simple flow:
Receive paper > store in warehouse > process the paper on a rewinder/sheeter > package the finished product.
The specific questions we are hoping for guidance on are listed above:
1.) What should the frequency be of sanitizing all product contact surfaces? We are generally a very low risk facility. We have written ROME procedures for maintained equipment. I'm asking for advice under normal operating circumstances. As a packaging manufacturer, we have determined that cleaning / sanitizing might be detrimental to the equipment or increase the risk of contaminants. Our Operators wipe contact surfaces with a clean cloth before each run, no other "sanitizing". If you have no food in your plant, the only likely source of pathogenic contamination is your employees and if they follow your GMPs that risk is nearly zero.
2.) Do forklifts require sanitizing? Do they come in direct contact with the raw or finished product? If you strip off outer packaging before you process the paper stock, the risk from the forklift is zero. We have ours on a monthly inspection and cleaning and has never been questioned at an audit.
3.) About how much time does your facility currently allow for completion of SSOP's? (I understand this will vary) We don't technically have any SSOPs, our cleaning is built in to the machine operation. A quick wipe usually takes 2 - 3 minutes. The facility cleaning however, takes considerably longer but helps maintain a contaminant free environment that keeps the machines clean.
Are you following SQF Edition 8 for Packaging Manufacture? Actual "Sanitation" other than bathrooms and break room tables, doesn't really need to happen at our plant.
Thks yr input indicating that yr SQF "cleaning SSOP" is minimal.
I recall that yr post is sort of an extension to a previous recent one -
It would seem that for EMP/Packaging SQF have currently (ie in 2019) done somewhat of a "flip-flop" over their expectations as compared to those in 2018. Maybe reality bit.
@ jdsummers - Based on above and assuming Post 7 is representative of the current SQF viewpoint you may be doing an "overthink" of requirements unless yr risk assessment demands a more extensive "Cleaning SSOP".
I suggest you read through the lengthy thread linked above which illustrates SQF's seeming oscillations on this topic in the period 2018-19.
Two generic answers to yr frequency query No.1 which have been previously discussed here for food are -
(i) initially implement an appropriately elevated version of the "standard" routine for cleaning which you anticipate will be convenient/effective. (Call it a "guesstimate". ). Then use data such as from a EMP program (eg APC/Y&M) to demonstrate micro. adequacy so that after a short period you can reduce yr program to the original target and show this is also micro. satisfactory. Specific risk assessment based excel presentations to (retrospectively) justify such a methodology exist on this Forum.
(ii) directly implement yr preferred target cleaning procedure then perform same steps as in (i)
Clearly HS's approach by-passes (i, ii) based on doing a "simple" risk assessment. This is seemingly where SQF have flip-flopped (read above linked thread). Up to you.