6 replies to this topic

[Scotty_SQF]

Question/advice on cleaning:

 

We are a small operation with most of the operation being storage and distribution.  We do have a converting operations where we take a roll of film and slit down to a smaller roll.  Our facility is very clean especially compared to other sites that do the same thing that I have been to.  Currently we do utilize cleaning schedules and they are for general cleaning.  My question or seeking advice comes from a good majority of our tasks are set at a frequency of 'as required'.  This is due to a couple of factors: 1. not all of the equipment runs every day 2. there isn't much dust, debris, etc. build up due to our converting operation 3. due to the nature of the converting operation it doesn't allow for a great risk of contamination due to dust/debris and 4. we have had 0 complaints to anything related to dust, dirt, etc. contamination concerns from customers in over 10 years of operation.  Also, need to say that mircobiological risk is very low.

 

Having said this items are being cleaned and the schedules are initialed when cleaned and schedules are reviewed and signed off.

 

Will this be a problem with an auditor for our upcoming SQF initial audit to have items at a frequency of 'as required'?  What would be the best way to show justification on this?  I was thinking maybe an assessment of some sort or some sort of justification document outlining the above.  Or will the inspection of the facility, along with our records (daily check of cleanliness, facility audits, program audits) show this is justified and adequate.  Just want to keep the questioning on it down to a minimum and show that we have it all buttoned up.  Open to any opinions.  Thank you!

[jdpaul]

I would think if you supplemented the "as required" with documentation of visual inspection of the area to show that it wasn't in need of cleaning on x week, month, etc. you would be fine (but kind of depends on what the tasks are because a risk assessment might be valuable/important)

 

What are some of these as required tasks?

Edited by jdpaul, 04 February 2022 - 04:56 PM.

[Charles.C]

Hi Scotty,

 

Seems to be an extension of your earlier thread -

 

https://www.ifsqn.co...le/#entry180456

 

I don't quite understand how certification to S&D can include a converting process or is this excluded from the scope ?

 

Your previous thread notes that "risk" must be included (but afaik not "validation") so IMO "as required" seems challengeable. I predict you will need to adjust/amplify your SOP.

 

IM(food)EX (not SQF) the simplest classic response is to" intuitively" evaluate the areas involved in respect to contamination potentials and designate appropriately factored frequencies (ie including consideration of your own options). More analytical risk-based SOPs are available on this forum but I daresay are overkill for your situation.

[Miss Frankie]

Just  thought, but you could say something like:
"Conveyor A is cleaned after 10 hours of use" 

"Roller B is cleaned after 6 hours of use"

"Table C is cleaned after 20 hours of use"

 

You're stating the cleaning frequency.  
You will need to track hours, of course so you can prove you're cleaning after the appropriate number of hours.

[Charles.C]

Just  thought, but you could say something like:
"Conveyor A is cleaned after 10 hours of use" 

"Roller B is cleaned after 6 hours of use"

"Table C is cleaned after 20 hours of use"

 

You're stating the cleaning frequency.  
You will need to track hours, of course so you can prove you're cleaning after the appropriate number of hours.

 

A possible, auditorial, "Risk-intentioned" follow-up to above is why the difference ? Some possible reasons are given in Post 2 but "as required" seems inadequate to me as an acceptable general response.

Specific SQF clause unstated  but if a risk-based response is mentioned [?] a  possible generic-type, potentially all-in-one, approach for such activities is illustrated below -

 risk assessment for frequency.pdf   25.11KB   59 downloads

(this effectively incorporates info such as mentioned in last para. of Post 1 within a risk matrix context)

Edited by Charles.C, 14 July 2023 - 09:18 AM.
edited

[Scotty_SQF]

Got by on it on two audits, but the auditor this year made a good point in stating that even though the tasks that were listed as 'As Required' were very very low risk (emptying recycle cans, etc.) that we should have a defined frequency.  So I changed tasks to a defined frequency and wrote in these items will be inspected at this frequency to check for compliance and to perform task if not in compliance.  In order to show that it may be checked daily so that way operators are at least checking daily and then emptying when needed.  We are a very low risk food packaging facility, so it works for us.

[Charles.C]

Got by on it on two audits, but the auditor this year made a good point in stating that even though the tasks that were listed as 'As Required' were very very low risk (emptying recycle cans, etc.) that we should have a defined frequency.  So I changed tasks to a defined frequency and wrote in these items will be inspected at this frequency to check for compliance and to perform task if not in compliance.  In order to show that it may be checked daily so that way operators are at least checking daily and then emptying when needed.  We are a very low risk food packaging facility, so it works for us.

Hi Scotty,

 

Here is a fairly elegant Predictive document designed for BRC's "frequency based on risk" requirement which perhaps models your "semi-intuitive" situation. Includes 3 disparate examples, the last is perhaps nominally equivalent to various (all ?) of your cleaning activities.

 

 Cleaning RA1.pdf   320.41KB   77 downloads