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SQF 9. Module 11. Risk Analysis Query


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Tresa

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Posted 30 May 2021 - 10:25 PM

Hi everyone, can anyone helps on how to conduct the risk analysis for these clause requirements for food manufacturing? 11.1.2.5 Ducting, conduit, and pipes that convey ingredients, products, or services, such as steam or water, shall be designed and constructed to prevent the contamination of food, ingredients, and food contact surfaces and allow ease of cleaning. A risk analysis shall be conducted to ensure food contamination risks are mitigated. 11.1.2.6 Pipes carrying sanitary waste or wastewater that are located directly over product lines or storage areas shall be designed and constructed to prevent the contamination of food, materials, ingredients, and food contact surfaces and shall allow ease of cleaning. A risk analysis shall be conducted to ensure food contamination risks are mitigated.



Charles.C

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Posted 31 May 2021 - 12:19 AM

 

Hi everyone,

 

can anyone helps on how to conduct the risk analysis for these clause requirements for food manufacturing?

 

11.1.2.5 Ducting, conduit, and pipes that convey ingredients, products, or services, such as steam or water, shall be designed and constructed to prevent the contamination of food, ingredients, and food contact surfaces and allow ease of cleaning.
A risk analysis shall be conducted to ensure food contamination risks are mitigated.
 
11.1.2.6 Pipes carrying sanitary waste or wastewater that are located directly over product lines or storage areas shall be designed and constructed to prevent the contamination of food, materials, ingredients, and food contact surfaces and shall allow ease of cleaning.
A risk analysis shall be conducted to ensure food contamination risks are mitigated.

 

 

Hi Tresa,

 

This is SQF becoming a PITA as they borrow  a nuisance feature pioneered by BRC which IMO is a superfluous request as individually featured..

 

if you do a search SQF now has approximately 5-10  clauses of equivalent  style (ie RA of GMP items).

 

I assume that an appropriately implemented GMP program will assure that all these repetitive clauses will actually pose a Low Risk.

 

IMO the semi-generic pdfs in Posts 1, 2  of this thread will handle all these abstractions by introducing the word "frequency" as illustrated -

 

https://www.ifsqn.co...nts/#entry58503

(the suitability is further discussed in Posts 3 et seq)


Kind Regards,

 

Charles.C


SQFconsultant

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Posted 31 May 2021 - 02:33 AM

First of all, is any of that present in your facility?


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Tresa

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Posted 31 May 2021 - 07:21 PM

First of all, is any of that present in your facility?

Yes, The pipes carrying the sanitary water are present above an equipment. The pipes are designed to allow ease of cleaning and constructed to prevent the contamination of the product and the food contact surfaces resulting in product safety, but not sure how to complete a risk analysis.



Tresa

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Posted 31 May 2021 - 07:34 PM

First of all, is any of that present in your facility?

OR, The flexible conduits are washed/ cleaned to prevent any cross-contamination in the production. The cleaning is done according to the frequency.



Mulan1010

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Posted 12 June 2021 - 06:53 PM

Hi Tresa - I can not say if it is right or wrong as we have not been audited on it yet but for...

   11.1.2.5 we basically listed out the ducting, conduit and piping used through out our facility.  We then stated the materials that they were made of.  Fortunately most of it is Stainless Steel although we do have some PVC and Flex Hosing.  For the PVC and Flex Hosing we have their specifications on file stating they are food grade and made that statement in our risk assessment.   We then stated that all the items are inspected on a regular basis and if become loose, damaged or compromised in a way that could affect product safety then they are repaired, cleaned and/or replaced.  For the piping or hoses that carry product from one area to another during production we break them apart nightly and clean so they are addressed daily on pre-op inspections.  For the ducting, conduit, water, steam and compressed air piping we have work orders for them to be inspected periodically and our staff is to be on the look out as well.  We do have documentation where issues with such items have been addressed, as needed.  We also run periodic micro tests on our water, compressed air, equipment surfaces and environment and used that as support that the procedures we have in place are being verified and based on the results the materials used and procedures in place are effective in protecting and maintaining the safety of our products.

  11.1.2.6 - We made a statement that none of our pipes carrying sanitary waste or wastewater are located above, they all run along or under the floor in our facility and we have procedures in place should there be a clogged drain or the drain backs up.  We are fortunate to only have a one level facility for our production areas so this one was not an issue for us. 



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Tresa

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Posted 14 June 2021 - 11:35 AM

Hi Tresa - I can not say if it is right or wrong as we have not been audited on it yet but for...

   11.1.2.5 we basically listed out the ducting, conduit and piping used through out our facility.  We then stated the materials that they were made of.  Fortunately most of it is Stainless Steel although we do have some PVC and Flex Hosing.  For the PVC and Flex Hosing we have their specifications on file stating they are food grade and made that statement in our risk assessment.   We then stated that all the items are inspected on a regular basis and if become loose, damaged or compromised in a way that could affect product safety then they are repaired, cleaned and/or replaced.  For the piping or hoses that carry product from one area to another during production we break them apart nightly and clean so they are addressed daily on pre-op inspections.  For the ducting, conduit, water, steam and compressed air piping we have work orders for them to be inspected periodically and our staff is to be on the look out as well.  We do have documentation where issues with such items have been addressed, as needed.  We also run periodic micro tests on our water, compressed air, equipment surfaces and environment and used that as support that the procedures we have in place are being verified and based on the results the materials used and procedures in place are effective in protecting and maintaining the safety of our products.

  11.1.2.6 - We made a statement that none of our pipes carrying sanitary waste or wastewater are located above, they all run along or under the floor in our facility and we have procedures in place should there be a clogged drain or the drain backs up.  We are fortunate to only have a one level facility for our production areas so this one was not an issue for us. 

Hi Mulan, Thank you for your input. are you able to share your RA?



PennyQAManger

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Posted 14 June 2021 - 10:00 PM

Risk Description:

Date:

Scope:

Assessment:

Control Step:






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