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Requirments for Receiving Bulk Water as Ingredient

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springsangel

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Posted 31 December 2019 - 12:20 PM

Hello all!  Hoping you can point me in a directions.  We had our SQF audit and she didn't write this as a CAR but we got a "fix it for next time", because we called the supplier and they were able to provide them. 

 

Short version - we bottle spring water.  Our source ran dry for a few weeks, and we used our back up source.  It comes in via a water tanker, that we put into our silo. 

 

When we check it in ( not providing every tiny detail here)   we check the TDS, PH and Ozone level.    Once we know it is inside parameters, we put it in the Silo.  From there is will get all of our normal checks Micro etc as it moves through the system. 

 

She said we have to have a cleaning ticket for the tanker -  otherwise how do we know they didn't carry milk, or something with nuts in it.  This made perfect sense to me, but the Quality People are digging in saying it is not an FDA requirement and won't include it. 

 

Before everyone starts commenting about authority and top level support - I get all of that, but I haven't successfully found where the FDA requires it,  except under FMSA - which seems clear enough to me, but they argue, its a water tanker, labelled potable water only. 

 

" Transportation operations: The measures taken during transportation to ensure food safety, such as adequate temperature controls, preventing contamination of ready to eat food from touching raw food, protection of food from contamination by non-food items in the same load or previous load, and protection of food from cross-contact, i.e., the unintentional incorporation of a food allergen." 

 

 



SQFconsultant

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Posted 31 December 2019 - 12:55 PM

You actually need one of two things --- a signed declaration from the operator of the tanker line that the tanker is dedicated for water only or two you need clean out certifications/tickets.

 

Tell your Quality people to expect a major finding if they don't want to comply.

 

They were lucky this time.


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Glenn Oster.

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http://www.GlennOster.com

 


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Ryan M.

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Posted 08 January 2020 - 01:30 AM

Wow...interesting response from your supplier on that.  It sounds like the tanker is used for potable water only?  Is the tanker labeled that way?  Get a guarantee from your supplier on this with their signature.  If they can provide that, one of your quality checks at receiving should be verification of tanker for potable water only, such as the tanker is labeled as such.

 

Not sure if this came up, but what about seals / locks on open / accessible ports including transfer hoses?



Hoosiersmoker

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Posted 08 January 2020 - 01:33 PM

Also, to my knowledge, Opportunity for Improvement was eliminated and replaced with a Yes or No only. OIs were considered consulting and disallowed. Correct me if I'm wrong but I do recall reading that in my studies.





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