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Risk assessment of paint on exterior of master carton

Paint Engineer Chemical contamination Very low risk Low risk Incident

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johnmcip

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Posted 15 March 2021 - 03:40 AM

I work in a very low risk produce repack facility. The engineers painted a conveyor belt, put it in place, and cleared it for use. To be fair, you needed the fingernail test to see that it wasn’t fully cured at the time they cleared it for use. Now the obvious result is that the paint smeared off the conveyor onto the exterior of the master carton. Granted there’s three barriers to the actual food products, but the severity of this situation should go without explaining. Any ideas on expressing what comes as second nature to us to a knuckle dragging engineer? Yes everything’s on hold, yada yada. I guess after that I should get advice on avoiding this in the future.



Scampi

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Posted 15 March 2021 - 11:59 AM

The only way to avoid this in the future is to A) fully understand how long the paint takes to fully cure and B) schedule that line accordingly

 

 

Why not just repack into new master cartons and move on?


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Posted 15 March 2021 - 05:17 PM

why does the process of engineering clearing things for use not include review by QUALITY ASSURANCE as a part of the process/


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johnmcip

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Posted 15 March 2021 - 05:21 PM

why does the process of engineering clearing things for use not include review by QUALITY ASSURANCE as a part of the process/

 

While this would be nice, we run a very tight ship over here. Many hats. No QA

I'm really just looking for ways to explain the severity of this type of situation to monkeys.



Scampi

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Posted 15 March 2021 - 06:38 PM

HAHAHA

 

Best of luck. If they really are monkeys, they won't understand. If you're trying to explain a food safety risk to engineers, the absolutely will never understand

 

It took me 6 months, and countless combos of rework for an engineer to finally admit that the conveyor used for trimming meat were NOT cut resistant (BTW QA was not involved in procurement) 

 

Tell the monkeys they cannot make decisions without 3 senior manager types giving the go ahead because next time, the product will be a write off


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johnmcip

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Posted 15 March 2021 - 06:59 PM

HAHAHA

 

Best of luck. If they really are monkeys, they won't understand. If you're trying to explain a food safety risk to engineers, the absolutely will never understand

 

It took me 6 months, and countless combos of rework for an engineer to finally admit that the conveyor used for trimming meat were NOT cut resistant (BTW QA was not involved in procurement) 

 

Tell the monkeys they cannot make decisions without 3 senior manager types giving the go ahead because next time, the product will be a write off

 

That seems to be the only solution, even though it will give them accuses to slough off all responsibility since "we never got authorization (and never asked)".

 

My all time favorite post on this forums is from Shea Quay regarding commissioning of equipment:

Posted 12 April 2012 - 08:36 AM

As you have used the word "engineer" in your question it would be impossible for anyone to answer that query. Engineers think differently to most of the rest of us. This is mostly because their hearts have been replaced with rocks which pump a viscous, oily-like substance around their veins. Your engineer will guarentee that that your "new" equipment will never really be ready and will break down frequently. And don't even get me started on NPD. I hope this helps in coming to grasp with this issue.
However if you insist on trying to do your job properly, ensure all lubricants used are food grade, do up a risk analysis that shows you have considered all possible physical, chemical, microbiological and intrinsic hazards related to the machine (is it mobile / hard to clean / does it have hidden corners where product might lodge, are refrigeration gas pipes running through it etc etc). If it's your job, do the same for health and safety. Remove your engineer's cigarette butts and empty coke cans from inside the machine, clean down, swab internally (if available) and externally. Run a trial. Send trial product for microbiological testing. Add machinery to glass and hard plastics register. Do up a cleaning schedule. Validate cleaning schedule. Write up a factory procedure. Train staff how to use machinery. Add machine to regular maintenance schedule. Not a whole heap you can really do after that I reckon.
And before all you engineers on the site start jumping up and down shouting and dragging those knuckles of yours along the ground - my sister is an engineer, so I know what I'm talking about.

 

 



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Posted 15 March 2021 - 07:23 PM

lol. My partner is a millwright---very similar situation (he has a hard time thinking outside his box)

 

At least if you have a written procedure (that they sign off on) then, when something happens again, the loss of revenue can get billed to their department, not yours and with any luck, annual bonuses are tied to that number!

 

There's more than one way to skin that cat

 

In my example, I copied the VP of ops every time I found blue plastic when I asked (again) if it was cut resistant, but didn't get traction until out sister facility starting rejecting our finished goods. But I was vindicated by my emails when, as usual, they tried to blame the QA department for the foreign material


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johnmcip

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Posted 15 March 2021 - 07:36 PM

Unfortunately I work in a small business with a vastly different structure than you implied.

 

Here's a funny story though. We had an incline conveyor that took product upward and dumped on another cross conveyor. The walls on it weren't tall enough and occasionally product would fall off onto a support beam. Every time you walked by you would see product sitting on that beam. I mentioned this to our engineer and his suggestion was to "wrap a piece of UHMW plastic around the beam so that the product would fall to the ground instead of sitting there." How do you train people like that?



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Posted 16 March 2021 - 12:25 PM

that takes the cake!  The only way I can think of is to pull an Erin Brockovich, make him lunch and then tell him what's in it and where it came from!

 

 

Unfortunately it sounds like the only real option available to you is to never release the product. Put a note in your records stating that you did not authorize release and move in. In this scenario, because there is no food safety risk, you can safely get away with this stance


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Charles.C

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Posted 16 March 2021 - 01:50 PM

Use of the terminology "very low risk" in the OP was probably highly optimistic.


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johnmcip

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Posted 17 March 2021 - 03:39 AM

Use of the terminology "very low risk" in the OP was probably highly optimistic.


Aside from simple distribution, what would you consider the lowest of risk?


Charles.C

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Posted 17 March 2021 - 12:54 PM

Aside from simple distribution, what would you consider the lowest of risk?

 

Hi John,

 

My opinion reflected the seeming lack of Process Quality Control as implied by comments in previous Posts.

 

To (hopefully) enable an evaluation of overall risk assessment, please inform details of Product/Process/HACCP Plan.

 

 

.


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johnmcip

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Posted 17 March 2021 - 02:23 PM

Hi John,

 

My opinion reflected the seeming lack of Process Quality Control as implied by comments in previous Posts.

 

To (hopefully) enable an evaluation of overall risk assessment, please inform details of Product/Process/HACCP Plan.

 

 

.

 

That's not the point you were making. you were implying that my products and processes are not inherently "very low risk" as I stated. What would you consider to be the lowest risk product/process?



Charles.C

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Posted 17 March 2021 - 02:32 PM

That's not the point you were making. you were implying that my products and processes are not inherently "very low risk" as I stated. What would you consider to be the lowest risk product/process?

 

Hi John,

 

Please see 3rd line in Post 12. Thks.


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johnmcip

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Posted 17 March 2021 - 03:08 PM

Hi John,

 

Please see 3rd line in Post 12. Thks.

 

Yes, I saw that. You made the original accusation that I was exaggerating risk level, lying about our processes, or had a fundamental misunderstanding about risk levels. I really don't want to turn this into a flame war, but you made the accusation. I want to know what your idea of "very low risk" is, before I tell you what our processes are and you dispute my risk assessments out of principle.



Charles.C

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Posted 17 March 2021 - 03:31 PM

Yes, I saw that. You made the original accusation that I was exaggerating risk level, lying about our processes, or had a fundamental misunderstanding about risk levels. I really don't want to turn this into a flame war, but you made the accusation. I want to know what your idea of "very low risk" is, before I tell you what our processes are and you dispute my risk assessments out of principle.

 

Hi John,

 

This document may help to answer yr query but as you probably are aware there is no universal definition of "low risk food".

 

Attached File  Food Business Risk Classification,2018.pdf   632.84KB   2 downloads


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Charles.C


johnmcip

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Posted 17 March 2021 - 04:11 PM

Hi John,

 

This document may help to answer yr query but as you probably are aware there is no universal definition of "low risk food".

 

attachicon.gif Food Business Risk Classification,2018.pdf

 

Here shows that the FDA does in fact use the designation "very low risk" in reference to specific hazards (pg xii) https://www.fda.gov/...124721/download

 

You won't answer my question because on second thought you realized that some products and processes can be considered very low risk. For instance, repackaging of non-RTE produce, and repackaging of produce with enzymes known to kill Salmonella, E. Coli., and other types of bacterias and viruses.

BRC gives examples of "low risk" as raw meat, sugar, and flour. Even those have very specific hazards I can think of off the top of my head: meat may be mistreated by the consumer causing proliferation of the small amounts of bacteria from source, and flour and sugar are almost fluid which would allow physical contamination to go unnoticed, especially by small ground particles of machinery. non-RTE produce has none of those risks.







Also tagged with one or more of these keywords: Paint, Engineer, Chemical contamination, Very low risk, Low risk, Incident

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