5 replies to this topic

[PollyKBD]

This may be a dumb question, but I have to ask. 

Does anyone have an unlocked chemical cabinet in a secure area? 

We are structuring our new facility and the question came up. The closet where our chemicals will be stored is a secure warehouse area. Only employees with a key card or delivery drivers with an escort may enter. Does the actual closet need a lock, too or is this considered secure?

Currently all employees have access to the key to our chemical closet. It remains locked because the cabinet, itself, isn't in the most secure area. 

 

[Fred73]

I have seen auditors that even if the cabinet is inside a secure area believe it need to be locked down. I think it will depend on the actual risk, how many employee have access to that area, and the security factors that the facility has. Usually the operations area is of employees only access with use of a card key/ID card but that still include many employees. I will definitely keep the chemical cabinet locked down or open only when the person in charge is working/taking the necessary chemicals.

[Ryan M.]

The answer is....it depends, and it is based on risk.  Really only you can assess the risk. 

• Who needs access to the chemicals? 
• Who doesn't need access? 
• How do you restrict those that do not need access from accessing the chemicals?

There are a lot of ways to address it.  In a former facility everyone needed access to the chemicals because they all used at least one of them to clean or maintain their areas.  Our facility was locked down (keycard access only and each person has unique ID for the card).  However, an SQF auditor did not think this was secure enough.  So...we had to lock down each individual drum with bung locks because we didn't really have an area we could isolate the chemicals.  In our next year audit, a different auditor, had no issue with a secure facility and personnel training on proper use of chemicals, he didn't see the need for bung locks.

 

At my current facility we have same type of setup, but very little security.  Doors are left open all the time and chemicals are easily accessed.  It has never been an issue during our SQF audit though....which I'm kind of surprised, but hey...we'll take it.

[SQFconsultant]

This may be a dumb question, but I have to ask. 

Does anyone have an unlocked chemical cabinet in a secure area? 

We are structuring our new facility and the question came up. The closet where our chemicals will be stored is a secure warehouse area. Only employees with a key card or delivery drivers with an escort may enter. Does the actual closet need a lock, too or is this considered secure?

Currently all employees have access to the key to our chemical closet. It remains locked because the cabinet, itself, isn't in the most secure area. 

LOCK IT UP!

 

This reminds me of two incidents that happened...

 

Years ago I inspected hotels as a QA Auditor for a franchise company, I was in compliance.  Visited a hotel in Andover, MA (USA) that was converting from a Holiday Inn with a central play area that included a big pool - about 100 rooms faced the pool in a square, no fencing surrounded the pool as the owners felt it was an enclosed area only accessed by hotel guests who had their rooms facing the pool - thus a "secured area."

 

Since my inspecion was a pre-opening audit and it was done from a risk compliance basis I told them that fencing per the franchise manual was mandatory - their of course was the standard yelling and sceamng as the owners did not want to delay opening, the cost of fencing, and blah blah blah...

 

I leave and somehow in error my report and comments that I made verbally to my company were not properly recorded.

 

The hotel opened without the fencing.

 

30 days after opening a busload of children from the a depressed area of NYC came in to stay for a "fun" getaway thru an agency.  a number of the rooms they were in faced the pool. 

 

Three children drowned on the day of arrival, all 3 boys of the same family.

 

#2

 

I visited a food company as a 3rd party Auditor some years back and during the opening meeting the owner came in and sat down to explain a recent recall.

 

He cried during the explanation - it was quite real.

 

Maintenance had placed a certain type of chemical in a non-secure chemical storage unit inside a secured area.

 

In error a production worker took the chemical out and it was in error used to clean a food contact surface that it was not intended for.

 

The chemical got into the food.

 

The food was eated by a child.

 

The child died.

 

...

 

Lock It up.

[majoy]

Your examples Glen are amazing, real live scenarios and scary ones too.

 

Not even for the sake of compliance but what really makes sense and what is needed to do.

 

You cannot avoid idiot people or employees, so make your process idiot proof. I remember the term the Japanese use poka yoke for this.

[Ryan M.]

Those are good examples of real life incidents.  What they tell me is that not necessarily a lack of security, but lack of training of personnel.  You can lock up anything, secure it, and what have you, but it still isn't 100%.  Nothing really is...but in my experience I have found proper training of all personnel with chemical handling, chemical safety, and proper usage is a much better guarantee than locking things up.

 

There are lots of instances where securing chemicals makes complete sense and they should be secured.  However, do not forget the need for proper training in the usage / handling of the chemicals and training on what to do if they are incorrectly used.  This former part is the real key that many people forget during training.

 

We had an instance at my current facility where latex based caulking was used to seal around a cover over a packaging hopper.  Latex does not hold up well to moisture, heat, and chemical.  After cleaning the packaging hopper with lots of water, chemical, and some heat (hot water) the caulking starting to melt off and fall into the hopper.  The operator on the line saw it and stopped the line immediately.  We lost about 2.5 pallets of product due to it, but the operator knew what to do in this event because of the training he had received.  And yes, the caulking is kept in a locked flammable cabinet inside the locked maintenance shop.