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Food Contact Chemical Supporting Documents

Supporting documents for chem

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bnue

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Posted 20 July 2021 - 04:39 PM

Hi all, I was in a very unfortunate situation during a supplier audit recently where in front of me the maintenance manager argued with the quality manager over the documents he had collected as part of his risk assessment for the food contact chemicals they had. The documents collected included statements on organic, FDA approval, Non GMO, allergens, TDS, & SDS for each food contact chemical which the maintenance manager was strictly against and called it a waste of time and overkill. He asked me for exact clauses within GFSI that asks for these and I was unable to provide him any details other than stating its best practice and part of risk assessments. Clearly the food safety culture at that place needed work. Can anyone confirm if there is any supporting document that alludes to the need of these docs? Thanks much 



Scampi

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Posted 20 July 2021 - 05:11 PM

So, it's not just the GFSI you need to meet requirements on

 

Are you FDA or USDA and will get you what you need

 

Section 11.2.5.2

Detergents and sanitizers shall be suitable for use in a food manufacturing environment, labeled according to regulatory requirements, and purchased in accordance with applicable legislation. The organization shall ensure:
i. The site maintains a list of chemicals approved for use;
ii. An inventory of all purchased and used chemicals is maintained;
iii. Detergents and sanitizers are stored as outlined in element 11.6.4;
iv. Safety Data Sheets (SDS) are provided for all detergents and sanitizers purchased; and
v. Only trained staff handle sanitizers and detergents.


Edited by Scampi, 20 July 2021 - 05:12 PM.

Please stop referring to me as Sir/sirs


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kingstudruler1

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Posted 20 July 2021 - 05:12 PM

Hi All,

 

I was in a very unfortunate situation during a supplier audit recently where in front of me the maintenance manager argued with the quality manager over the documents he had collected as part of his risk assessment for the food contact chemicals they had. The documents collected included statements on organic, FDA approval, Non GMO, allergens, TDS, & SDS for each food contact chemical   which the maintenance manager was strictly against and called it a waste of time and overkill. He asked me for exact clauses within GFSI that asks for these and I was unable to provide him any details other than stating its best practice and part of risk assessments. Clearly the food safety culture at that place needed work. 

 

Can anyone confirm if there is any supporting document that alludes to the need of these docs? Thanks much 

 

 Some of if may be overkill.   but why not have it.  some of it if required.   the GFSI clause would be different depending on the standard used.  I have used BRC as it is a little clearer.  

 

Organic - depending on your operation this may be important as they could jeopardize organic status.  some no rinse sanitizers are not organic acceptable.

  BRC 5.4.4 /5.4.5

Non Gmo -   same as organic.    there may be issues where you could  jeopardize Non gmo status.     BRC 5.4.4 /5.4.5

allergen-  Some people dust baking racks with flour.   or use food oils as lubes.   for the most part, food grade chemical lubes/greases  don't contain allergens.   BRC 4.7.5

TDS - you are required to have a spc sheet.  BRC 4.9.1.1

SDS - you are required to have a sds.  BRC 4.9.1.1.  Also osha law. 

 

hope this helps.    



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Scampi

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Posted 20 July 2021 - 05:16 PM


Please stop referring to me as Sir/sirs


bnue

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Posted 20 July 2021 - 07:37 PM

Thank you Scampi. I personally have had auditors open the maintenance cabinet and ask for non GMO or allergen statement for any random food contact oil or grease. Just sad that I wasn't more helpful when required

 

 Some of if may be overkill.   but why not have it.  some of it if required.   the GFSI clause would be different depending on the standard used.  I have used BRC as it is a little clearer.  

 

Organic - depending on your operation this may be important as they could jeopardize organic status.  some no rinse sanitizers are not organic acceptable.

  BRC 5.4.4 /5.4.5

Non Gmo -   same as organic.    there may be issues where you could  jeopardize Non gmo status.     BRC 5.4.4 /5.4.5

allergen-  Some people dust baking racks with flour.   or use food oils as lubes.   for the most part, food grade chemical lubes/greases  don't contain allergens.   BRC 4.7.5

TDS - you are required to have a spc sheet.  BRC 4.9.1.1

SDS - you are required to have a sds.  BRC 4.9.1.1.  Also osha law. 

 

hope this helps.    

 

Thank you K! This is very helpful.

.



Charles.C

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Posted 20 July 2021 - 10:59 PM

Hi All,

 

I was in a very unfortunate situation during a supplier audit recently where in front of me the maintenance manager argued with the quality manager over the documents he had collected as part of his risk assessment for the food contact chemicals they had. The documents collected included statements on organic, FDA approval, Non GMO, allergens, TDS, & SDS for each food contact chemical   which the maintenance manager was strictly against and called it a waste of time and overkill. He asked me for exact clauses within GFSI that asks for these and I was unable to provide him any details other than stating its best practice and part of risk assessments. Clearly the food safety culture at that place needed work. 

 

Can anyone confirm if there is any supporting document that alludes to the need of these docs? Thanks much

 

Hi bnue,

 

A relevant answer probably depends on the specific purpose/context/scope of  the so-called "Supplier Audit".

 

Generically, IMHO, FS requirements are often inherently ambiguous (eg "risk assessment", "Approved Supplier")  so that an auditor could presumably choose to "nitpick"  to any personally inclined  extent. Or not of course.

 

I have never encountered the terminology "Maintenance Manager (MM)" but I deduce the proffered Encyclopedia of QA documentation somehow, negatively, "reflected" on MM's  own territorial responsibilities ?

 

Getting OT but IMO, each successive year demands that designers of FS Standards (inc.GFSI ?) justify their existence by unearthing a few new "nuggets" above and beyond the heretofore established auditorial expectations. In some cases there may be a valid justification for such enlargements but I suspect a few are basically flim-flam.


Kind Regards,

 

Charles.C


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Posted 21 July 2021 - 02:14 PM

here's the FDA code
 
https://www.accessda...h.cfm?fr=110.35


I notice that you referenced 21 CFR 110. Please note that part 110 has been replaced by 21 CFR 117.
https://www.accessda...21:2.0.1.1.16.2





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