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Nonconformity: Air is filtered with specified filters, but as the initial air quality is unknown, the air quality is uncertain - how to solve?

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Anf

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Posted 16 March 2020 - 01:08 PM

Hi,

 

We got a non-conformity on our FSSC audit this year. According to the auditor air quality is a focus area now.

 

Nonconformity: Air is filtered with specified filters, but as the initial air quality is unknown, the air quality is uncertain.

 

An overview over filters used for air in contact with product is included in our PRP document, but we hadn't included information about air used (quality before filters).

 

Can anyone share how they has solved this?

 

Thank you in advance.

 



Ryan M.

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Posted 16 March 2020 - 02:06 PM

I would think as long as you are managing /maintaining the filters and you conduct air quality testing you should be fine.  If you have the means perhaps do some testing of the air quality without filters, such as taking a sample of the supply air, or even outside air quality.



Charles.C

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Posted 16 March 2020 - 02:22 PM

Product ?

Specific NC ?

Related Clause ?

Compressed Air(?) used for ?

 

Air "Quality" is a rather wide Topic eg -

 

https://www.ifsqn.co...ent/#entry81054


Kind Regards,

 

Charles.C


Anf

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Posted 16 March 2020 - 02:34 PM

Product ? Spraydried fishmeal

 

Specific NC ? Requirement Air in direct contact with product shall be of known quality.

Nonconformity Air is filtered with specified filters, but as the initial air quality is unknown, the air quality is uncertain.
 

Related Clause ? FSSC 22000 V5 - ISO TS 22002-1:2009 (Food)  6.4

 

Compressed Air ? No

 

Information from the auditor during the closing meeting was that we have control over the air in the product (correct filter class, maintenance etc.), but we did not knew the quality of the air before it is filtered (incoming air from outside).

 

I am struggeling with seeing the real risk missed here. We use the correct type of filters, and there are measuring devices on the filter which indicate when it is time to change. And how can the quality be uncertain when a filter of correct type is used? 

 

What am I missing here?  :helpplease:



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Posted 16 March 2020 - 02:54 PM

"Nonconformity: Air is filtered with specified filters, but as the initial air quality is unknown, the air quality is uncertain."

 

You really need to challenge this NC.

 

One could say this about any facility they walk into.

 

This is like a real estate appraiser saying the structure of the building is uncertain because he/she doesn't have X-ray eyes and can't see the cracks in the steel beams in the wall.


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Glenn Oster

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Anf

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Posted 16 March 2020 - 03:00 PM

"Nonconformity: Air is filtered with specified filters, but as the initial air quality is unknown, the air quality is uncertain."

 

You really need to challenge this NC. Will do. Glad to see that it was not just something I missed. Thank you!

 

One could say this about any facility they walk into.

 

This is like a real estate appraiser saying the structure of the building is uncertain because he/she doesn't have X-ray eyes and can't see the cracks in the steel beams in the wall.

 

 



Charles.C

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Posted 16 March 2020 - 03:09 PM

Information from the auditor during the closing meeting was that we have control over the air in the product (correct filter class, maintenance etc.), but we did not knew the quality of the air before it is filtered (incoming air from outside).

 

I am struggeling with seeing the real risk missed here. We use the correct type of filters, and there are measuring devices on the filter which indicate when it is time to change. And how can the quality be uncertain when a filter of correct type is used? 

 

What am I missing here?  :helpplease:

 

Hi Anf,

 

Thks info.

 

The auditor comment does seem odd. I can only think there was either (a) a misunderstanding/typo(?) and the comment referred to output quality and/or (b) the "initial" referred to filtered air from one section being passed on into another production area of perhaps increased "sensitivity" (?).

 

Assuming the comment refers to "quality" of  filtered air, various safety/quality answers are offered (of increasing complexity) within the excel sheet  and files  in the linked post in post3 above (eg see excel sheets 1-5).


Kind Regards,

 

Charles.C


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Posted 16 March 2020 - 09:57 PM

If your filters remove 99.9% of all "stuff" that is great if you have a clean air supply. Say for example if your incoming air has 10lbs of "bad stuff" and your filters remove 99.9% then you have nice air. But if your incoming air has 10,000lbs of "bad stuff" then even if your filters remove 99.9% you will still have a lot of "bad stuff" in your air. The only way around this would be to test your air after filtering. There are companies that loan you test kits so you collect the samples.



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Charles.C

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Posted 16 March 2020 - 10:15 PM

If your filters remove 99.9% of all "stuff" that is great if you have a clean air supply. Say for example if your incoming air has 10lbs of "bad stuff" and your filters remove 99.9% then you have nice air. But if your incoming air has 10,000lbs of "bad stuff" then even if your filters remove 99.9% you will still have a lot of "bad stuff" in your air. The only way around this would be to test your air after filtering. There are companies that loan you test kits so you collect the samples.

 

Some monitoring requirement is indeed self-evident.

 

@ Anf- so is yr external air visibly poor ?, eg black ?

 

TBH I'm surprised the auditor's comment was not queried at the closing meeting..


Kind Regards,

 

Charles.C


Anf

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Posted 17 March 2020 - 06:15 AM

Charles, you are of course right. I should have commented on this during the closing meeting. I asked, but not the right questions. And my head was probably spinning a little after 2 days with audit. 

 

The plant is situated in a small place without other industry, and the air quality is "green" according to environmental surveillance. 

 

Thank you to everybody who took the time to comment on my question. I really appreciate it!



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Posted 17 March 2020 - 10:46 AM

The BRC have published a guide 'Understanding Air Quality Requirements and Air Filter Specifications in Food Production available on the BRC Participate Website which talks about outdoor air quality. Might be worth a read



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patti.garcia

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Posted 06 November 2020 - 04:10 PM

We had the same finding a while back. The idea is if you have really dirty supply air you may have the right filters or you may not be changing them with the right frequency.

 

We now do two things (annually) 

1. As part of our EM program we put out the micro plates to understand micro issues in our ambient air

2. We used an air sampling pump that collects dust and pollens from the air so we could test for particulates.





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