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jdsummers6

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Posted 26 July 2019 - 06:57 PM

Hello all,

 

Sorry if there's a previous thread out there regarding the specific questions I'm about to bring up. 

 

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.

 

2.) Do forklifts require sanitizing? 

 

3.) About how much time does your facility currently allow for completion of SSOP's? (I understand this will vary)

 

Thanks guys/gals, hope to spark some good conversations here. 

 

- Justin



Hank Major

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Posted 26 July 2019 - 07:38 PM

1.) You could do a swab study and see if either microbes or proteins show any increase after a day, week, or month of no sanitizing. Most food safety standards want no longer than monthly.

 

2.) My auditor said the forklift needed a wipedown monthly.

 

3.) I've never really had to deal with things taking too long, but I do note in my SSOPs that wet cleaning must be conducted after food production has ceased, and leave enough time to dry by morning.



Charles.C

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Posted 26 July 2019 - 08:45 PM

Hello all,

 

Sorry if there's a previous thread out there regarding the specific questions I'm about to bring up. 

 

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.

 

2.) Do forklifts require sanitizing? 

 

3.) About how much time does your facility currently allow for completion of SSOP's? (I understand this will vary)

 

Thanks guys/gals, hope to spark some good conversations here. 

 

- Justin

 

Hi Justin,

 

(1) The classic answer from a safety POV is that the frequency depends on doing a risk assessment which will involve things like nature of food contact, type of product, etc, etc

So need to know some details regarding Product/Process, eg a  Flowchart.


Kind Regards,

 

Charles.C


jdsummers6

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Posted 29 July 2019 - 01:36 PM

Hi Charles,

 

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.

 

2.) Do forklifts require sanitizing? 

 

3.) About how much time does your facility currently allow for completion of SSOP's? (I understand this will vary)



Charles.C

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Posted 29 July 2019 - 05:37 PM

Hi Charles,

 

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.

 

2.) Do forklifts require sanitizing? Maybe depends on the function.

 

3.) About how much time does your facility currently allow for completion of SSOP's? (I understand this will vary)

Not sure what "completion" refers to ?

 

Hi Justin,

 

I'm not in Packaging arena (no idea what "ROME" means) but I anticipate there are some typical cleaning/sanitiizing schedules for Packaging already posted on this forum if you don't mind a little searching.

 

"Low Risk" is IMEX operationally rather ambiguous from a cleaning POV.

 

I deduce this refers SQF clauses 13.2.11.X

 

The SQF Guidance requirements has (inter alia) -

 

(a) The frequency for cleaning and sanitizing different areas of the premises and all associated equipment including pre-operative cleaning and cleaning between breaks;

 

(b) Evaluation of cleaning.  Monitor the effectiveness of cleaning and keep records of all inspections implemented to verify the effectiveness of the cleaning program. This can include visual inspection after sanitation activity or prior to start-up; The results of the Environmental Monitoring (2.4.8) can also be used to validate the effectiveness of the cleaning and sanitation as well as the frequency between intervals.

 

For food the textbook answer to (1) is typically a minimum frequency of daily after work for fcs or more often for certain operations depending on the "details". Seems not dissimilar to (a) above.

But Post 2 suggests that Packaging is much more tolerant than food production.

 

The frequency is also related to (b) above for which I presume you will need some data.


Kind Regards,

 

Charles.C


jdsummers6

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Posted 29 July 2019 - 06:26 PM

Charles,

 

Thanks for the reply. ROME refers to "release of maintained equipment." We have a sanitizing procedure after any maintenance is performed before equipment / machinery is able to be brought back online.  It was only mentioned to assure everyone reading that we have measures in place for these situations, just needed clarification on frequencies of routine cleaning and sanitizing. 

 

You're right, this is concerning 13.2.11 - just wondering the current practices of any individuals in food packaging manufacturing to get a good starting point for frequencies. We are planning on taking culture swabs soon, but if most packaging manufacturers only sanitize rollers weekly, then that's where we were going to start.

 

Swab > clean > swab again ******** wait a week ******* swab > clean > swab again, then compare the results. 

 

As for the forklifts, I believe we will follow Hank Major's advice and do a monthly wipe down. 

 

When I used the word completion I was referring to average time facilities set aside from the beginning of their routine cleaning/sanitizing activities to the end of their routine cleaning/sanitizing activities. As in, if an SSOP has 10 steps, how long (on average) does it take to complete these steps?



Hoosiersmoker

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Posted 30 July 2019 - 06:26 PM

Hi Charles,

 

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.



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Charles.C

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Posted 30 July 2019 - 07:46 PM

 

Hi Charles,

 

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.

 

 

Hi Hoosiersmoker,

 

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 -

 

https://www.ifsqn.co...e-2#entry143700

 

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". :smile: ). 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.


Kind Regards,

 

Charles.C





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