I'm assuming they are considering using a liquid filling line to fill chemicals?
I concur with contacting your CB - as anything run on an SQF line needs to be included under the scope (my understanding). I will plead a bit of ignorance if I'm incorrect and major product categories can be added to the line without them being notifed, but that's been my understanding. From the code:
5.1 Changing the Scope of Certification When a site wishes to add food sector categories or new products to their scope of certification, the site may request the increased scope of certification in writing with the certification body.
Where the scope change is a new process or a major change to an existing process, a new product line, or a significant change in personnel, raw materials, packing materials or ingredients, the certification body shall be advised in writing. Where the request is received within thirty (30) days prior to the re-certification audit window, the certification body may defer the scope extension to the next re-certification audit and shall advise the site. No new certificate shall be issued until after a successful re-certification audit.
But that all said - your hazard analysis needs to account for other products and hazards run on the line. So prior to moving forward, at minimum, a full FS Plan reassessment would need to be done. As I'm guessing your expertise is not chemicals, it'd be wise to bring in a technical expert as well to figure out how to assure there is no residual risk from running the chemicals when you switch back back and forth between disinfectants and food product. (Testing of rinse water at the end etc to check for chemical concentration, etc., switching out every gasket, etc.)
Situationally and pending the type of chemicals it MIGHT be feasible, however - even if it is, I really struggle to see it being a good idea. To do it safely would require a significant amount of work up front, probably far more than would be worthwhile to try to get in on the short term demand for sanitizers. This is all also all assuming there isn't something in the FDA code that strictly forbids running chemicals on the same line as food, i.e. not using food equipment for non-food items. Not to mention the additional requirements that chemical producers have, OSHA considerations, etc.
If the objective is not for sale but for use in the plant, then I'd pick an area away from any food, risk assess it, keep it off of equipment (or get dedicated equipment for it), and work within the FDA's guidelines for short term mixing of sanitizers in the plant. https://www.fda.gov/...136118/download
Edited by Xoinks, 03 April 2020 - 02:29 PM.
