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Should ALL glass and plastic materials in an area be included in the register, even if they do not pose a direct threat to the product?

Started by , May 28 2020 12:21 PM

We include everything. Others may think that extreme. But I have found Auditors to sometimes (more than a few) have different views than we do on things. Thus, including everything covers that issue.

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Hello, quick question on glass and brittle plastic register. Should ALL glass and plastic materials in an area be included in the register, even if they do not pose a direct threat to the product (e.g., waste bins, security cameras, fire extinguishers, etc.)? Or only those that can affect food safety? Thanks

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I included all fixtures/utensils/equipment parts presenting potential risk to food safety, even measuring gauges in a pasteurization room and fly light in a maintenance room. That was a CFIA inspector's comment several years ago (before, I had only ceiling light fixtures, windows, etc.) However, neither CFIA inspector nor any auditor ever requested to include surveillance cameras. Question to you: do you have fire extinguishers made of brittle plastic? Interesting - I thought they should be made of metal only... 

We include everything. Others may think that extreme. But I have found Auditors to sometimes (more than a few) have different views than we do on things. Thus, including everything covers that issue.

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I included all fixtures/utensils/equipment parts presenting potential risk to food safety, even measuring gauges in a pasteurization room and fly light in a maintenance room. That was a CFIA inspector's comment several years ago (before, I had only ceiling light fixtures, windows, etc.) However, neither CFIA inspector nor any auditor ever requested to include surveillance cameras. Question to you: do you have fire extinguishers made of brittle plastic? Interesting - I thought they should be made of metal only... 

 

Hi Olenazh, thanks for your response. Our fire extinguishers are made of metal, but they have plastic on the handle and pressure gauge. This was something one of your auditors mentioned most people forget to include (as well as surveillance cameras, even through they are far from any exposed product/raw materials). 

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Hello, quick question on glass and brittle plastic register. Should ALL glass and plastic materials in an area be included in the register, even if they do not pose a direct threat to the product (e.g., waste bins, security cameras, fire extinguishers, etc.)? Or only those that can affect food safety? Thanks

So what does the Standard request ???

What I have done in the past is included everything in open product areas on the register, performed a risk assessment on each piece based on type of material, likelihood of breakage, and likelihood of product contamination in the event of breakage. I then established frequency of checks based off risk.  I would have some items that would get checked weekly/monthly, and other items that would only be checked quarterly or yearly. 

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So what does the Standard request ???

11.7.5.3 All glass objects or similar material in food handling/contact zones shall be listed in a glass register including details of their location.

11.7.5.5 Regular inspections of food handling/contact zones shall be conducted to ensure they are free of glass or other like material and to establish changes to the condition of the objects listed in the glass register.

11.7.5.6 Glass instrument dial covers on processing equipment and MIG thermometers shall be inspected at the start of each shift to confirm they have not been damaged. 

11.7.5.3 All glass objects or similar material in food handling/contact zones shall be listed in a glass register including details of their location.

11.7.5.5 Regular inspections of food handling/contact zones shall be conducted to ensure they are free of glass or other like material and to establish changes to the condition of the objects listed in the glass register.

11.7.5.6 Glass instrument dial covers on processing equipment and MIG thermometers shall be inspected at the start of each shift to confirm they have not been damaged. 

Thanks. From a glass POV seems reasonably explicit.

 

No mention of Plastic but after a quick look at the Guidance I also noticed -

 

 A glass register has been developed;
•  The glass register is complete, and covers all glass located at the site;
•  The glass register includes brittle plastic and other materials;
•  Glass inspections are conducted regularly including instrument dial covers and thermometers;

 

 

Seems to answer yr OP.  "other materials"  is presumably up to SQF. Take your pick. Perhaps it means other brittle materials.

 

A SQF afterthought perhaps.

We include everything. Even clocks hung up in the production area! It's stressful and time consuming but oh well. 

We include everything. Even clocks hung up in the production area! It's stressful and time consuming but oh well. 

Brittle Plastic- Faced Clocks ? Not so ridiculous.

 

But "everything" IMO simply defeats the point of the exercise.

 

For comparison here is BRC's leading Clause -

 

Glass or other brittle materials shall be excluded or protected against breakage in areas where open products are handled or there is a risk of product contamination.

 

Followed by -

 

Procedures for handling glass and other brittle materials (other than product packaging) shall be in place where open products are handled or there is a risk of product contamination. These procedures shall include, at a minimum:
•  a list of items detailing location, number, type and condition
•  recorded checks of the condition of items, carried out at a specified frequency that is based on the level of risk to the product
•  details on cleaning or replacing items to minimise the potential for product contamination.
etc

Brittle Plastic- Faced Clocks ? Not so ridiculous.

 

It was a facility I worked at and I was new so I questioned why those? They told me their previous auditor strongly advised them to do so. So I took that advice with me. 

As MsMars stated, do a risk assessment to determine which pieces are the hazards.  In my previous life I've differed the inspection frequency based on risk assessment...some items daily, some monthly, some quarterly depending on risk.

We also include everything. It's about 15 pages of items. The last 3 auditors looked at it and after they skimmed the first few pages moved on. The one thing we have done is made it a daily inspection for all items at the machines in direct proximity to product and a weekly or monthly an most others, all documented with checklists and verifications. Never had an issue

This may be over thinking, but I'm seeing a lot of "everything", and I've heard of people making registers for pens, calculators, clipboards, etc. Does anyone do this?

also the cordless phone and the smartphone if they are used ;-)


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