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Risk Assessment to show Water/Backflow Testing is not applicable

backflow preventer testing

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#1 cmthomson

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Posted 24 August 2020 - 03:20 PM

Hello, Our facility is SQF Certified for Food Contact packaging. This is our first year of operations and we convert paper products. I am reviewing the SQF code on backflow testing. Our facility does not use water in the manufacturing process. I'm not sure how to go about starting a risk assessment to show that this section of the code is not applicable or very low risk. Has anyone done a risk assessment that I could review in order to start mine?



#2 olenazh

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Posted 24 August 2020 - 03:40 PM

Simply describe your processes to demonstrate they don't involve water. Based on that, make a conclusion that corresponding section of SQF is not applicable



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#3 SQFconsultant

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Posted 24 August 2020 - 04:02 PM

Hello, Our facility is SQF Certified for Food Contact packaging. This is our first year of operations and we convert paper products. I am reviewing the SQF code on backflow testing. Our facility does not use water in the manufacturing process. I'm not sure how to go about starting a risk assessment to show that this section of the code is not applicable or very low risk. Has anyone done a risk assessment that I could review in order to start mine?

 

A. where in Module 15 does it show that a "test" is required?

B. I understand you are not using water in the manufacturing process - but do you use water for sanitation?


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Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
 
 
 

#4 cmthomson

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Posted 24 August 2020 - 04:10 PM

Hi Glen-We do not use water as part of the process to clean or sanitize our manufacturing equipment. I am referencing Module 13-section  our cleaning and sanitation 13.5.2 Water Quality.



#5 SQFconsultant

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Posted 24 August 2020 - 04:24 PM

Hi Glen-We do not use water as part of the process to clean or sanitize our manufacturing equipment. I am referencing Module 13-section  our cleaning and sanitation 13.5.2 Water Quality.

 

My oops, I meant 13 and not 15. 

 

This is what was written for a client in the packaging field...

 

13.5.2 - Facility does not use water for manufacturing nor for sanitation and thus the need to prevent back-flow is not applicable.

 

easy peasy.


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
 
 
 

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#6 Hoosiersmoker

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Posted 26 August 2020 - 01:29 PM

We are also a paperboard packaging manufacturer. What conversions do you undertake? Do you do any printing processes? If so, you likely use water in your process in some form or fashion. Does your local municipality not already require you to have backflow prevention? If you do already have backflow prevention in place, just copy the annual inspection certificate and insert it into your FSM (for ease of audit purposes) and you're in compliance. Our auditor spends 2 seconds on it, sees the cert and moves on. Quick and painless! :shades:



#7 McForman

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Posted 19 March 2021 - 02:25 PM

Okay, so I am not SQF but BRC and during my audit this year my auditor asked me to add backflow devices for next year because we added a new building that has a lunch room and a restroom that open up out into the loading dock area and at my main building lunchroom opens up to my bag storage room but again we don't use water for manufacturing nor for sanitation we dry clean. I have had my township water company say we don't need them because we are considered low hazard( I have an email) and I have had a plumber out here twice looking at me like I am crazing now saying we don't need it and to add one to our main building just because is going to be a lot of replumbing $$$ so what type of contaminated are we trying to keep out, because if a pipe busted and water made it to my other rooms they have floor drains and everything is on racks, and we word discarded anything that would be contaminated worst case. 

 

So, maybe I can get the plumber to sign risk assessment with me and added it to my email from water company? I always take my auditors advice to improve my program but I am not a plumber and the plumber thinks I am crazy lol HELP!!

My oops, I meant 13 and not 15. 

 

This is what was written for a client in the packaging field...

 

13.5.2 - Facility does not use water for manufacturing nor for sanitation and thus the need to prevent back-flow is not applicable.

 

easy peasy.



#8 Hoosiersmoker

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Posted 19 March 2021 - 03:10 PM

I would gather the info and send it to your CB's tech dept. and let them decide if you can gain exemption. Just for reasons of the health and safety of your employees you should install backflow prevention. Comparing the cost of a hospitalization for illness (or worse) due to unintentional introduction of toxins or other matter to the cost of installing the backflow valve, it's insurance and money well spent. We had our incoming 4" main dug up and raised through the floor to have one installed. One less thing we have to worry about and the inspection / test is about $150.00 / year.



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#9 luluGFSI

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Posted 27 July 2021 - 01:09 PM

Hello, Our facility is SQF Certified for Food Contact packaging. This is our first year of operations and we convert paper products. I am reviewing the SQF code on backflow testing. Our facility does not use water in the manufacturing process. I'm not sure how to go about starting a risk assessment to show that this section of the code is not applicable or very low risk. Has anyone done a risk assessment that I could review in order to start mine?

 

Hey there - do you happen to have a better insight on what needs to be done for food contact packaging manufacturers in regards to this now that your audit has passed? We have our audit coming up. We have backflow preventers and our mechanics check them via the PM schedule but we have not had the backflow tested by a certified third-party. Any insight here would be greatly appreciated!






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