Jump to content

  • Quick Navigation
Photo

No fencing around outdoor tanks - need creative solution

Share this

  • You cannot start a new topic
  • Please log in to reply
14 replies to this topic

NorCalNate

    Grade - MIFSQN

  • IFSQN Member
  • 69 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 24 February 2022 - 08:56 PM

Unique/difficult problem needing creative solution:

 

We have an outdoor tank "farm" (a group of tanks) which currently do not have a fence around them, which is an obvious SQF Food Defense issue. While there is no fencing around the tanks, the tanks do have locks on all openings, so we are able to secure the tanks when the facility is closed.

 

The quote we received to fence the tank area was significantly out of our budget though the quote for cameras was acceptable, so we are now in a position where we need to come up with a creative solution in order to confirm compliance with our SQF auditor.

 

Note: These tanks are only used 3-4 months (consecutive) out of the year

 

Creative solutions appreciated! Below I put two ideas I had as well:

 

 

1. Install security cameras, continue utilizing the locks on the tanks and come up with a more robust system where we document when tanks are locked and unlocked, that tank openings are visually inspected for evidence of tampering prior to use, etc... Then we would need to complete a risk assessment.

Downside: Not sure if this would be enough for the SQF auditor

 

2. Install temporary chain link fencing around the tank area along with security cameras, and continue utilizing the locks on all tanks when the facility is closed, including documenting when tanks are locked and unlocked each day and having a visual inspection prior to opening each tank.

Downside: The fencing will only be 6' high, though we likely would be able to secure it to the concrete so it stays in place. Not a perfect solution, but better than nothing?

 

Thanks



SQFconsultant

    SQFconsultant

  • IFSQN Fellow
  • 4,629 posts
  • 1135 thanks
1,125
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:Just when I thought I was out - They pulled me back in!!!

Posted 24 February 2022 - 09:36 PM

Need full 24/7 barrier, a 6 foot fense will not do it. Need full enclosurw, if I can reach thru, go over and enter from top that is not secure.

Why not a block wall sytem with padlocked door - block even with construction costs is cheaper than fencing. Either way a top enclosure is needed too.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

 

 

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 

774.563.7048


NorCalNate

    Grade - MIFSQN

  • IFSQN Member
  • 69 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 24 February 2022 - 10:33 PM

Need full 24/7 barrier, a 6 foot fense will not do it. Need full enclosurw, if I can reach thru, go over and enter from top that is not secure.

Why not a block wall sytem with padlocked door - block even with construction costs is cheaper than fencing. Either way a top enclosure is needed too.

 

Would adding an electric element to the fence as a deterrent suffice?

 

If we can show that the tanks are always locked when not in use and that access to the inside of the tanks is impossible without cutting a lock, implement a system where we log when tanks are locked and unlocked, perform visual inspections (looking for evidence of tampering) and confirm lock#s are correct, that wouldn't be enough to show compliance?

 

Is there any leeway given in the SQF requirements which would allow us to come up with an alternate solution when the standard is not financially viable? It's very frustrating to think that a well thought out and verified alternative would be immediately dismissed. 

 

That being said your comment is greatly appreciated. Just wish there was some intermediate. 



Scotty_SQF

    Grade - SIFSQN

  • IFSQN Senior
  • 366 posts
  • 87 thanks
139
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:hiking, gravel biking, exploring the great outdoors

Posted 02 March 2022 - 01:43 PM

What is in the tanks?  Food ingredient?  I worked at a place where we had silos that sent flour into our building.  We did not have a fence.  We had locks on the silo doors as well as security cameras to monitor the area.  We also did at least a weekly documented inspection of the area, as well as inspected the are before receiving more product. Never had a food defense issue with auditor on this set-up.

 

I also believe there is some leeway in regards to cost.  As you say, get creative.  One audit they had found multiple spots in a floor that concerned them. It was not viable for us to fix the entire floor as that would be a huge cost to the facility and would hinder us financially from customer standpoint.  We were able to risk assess the floor and create a 3 phase project.  Floor in that were the worst and higher risk were completed one year, followed by the next phase the following year and so on.  We also monitored the areas and anything real deep was cleaned out and fixed with a temporary concrete patch that would hold up until that floor area was able to be worked on.  Hope that gives you an idea.



NorCalNate

    Grade - MIFSQN

  • IFSQN Member
  • 69 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 23 March 2022 - 07:06 PM

What is in the tanks?  Food ingredient?  I worked at a place where we had silos that sent flour into our building.  We did not have a fence.  We had locks on the silo doors as well as security cameras to monitor the area.  We also did at least a weekly documented inspection of the area, as well as inspected the are before receiving more product. Never had a food defense issue with auditor on this set-up.

 

I also believe there is some leeway in regards to cost.  As you say, get creative.  One audit they had found multiple spots in a floor that concerned them. It was not viable for us to fix the entire floor as that would be a huge cost to the facility and would hinder us financially from customer standpoint.  We were able to risk assess the floor and create a 3 phase project.  Floor in that were the worst and higher risk were completed one year, followed by the next phase the following year and so on.  We also monitored the areas and anything real deep was cleaned out and fixed with a temporary concrete patch that would hold up until that floor area was able to be worked on.  Hope that gives you an idea.

Meant to thank you for the response, this is great to hear. We got a more reasonable quote, though it's still very high. If Management doesn't approve, I'm going to recommend a similar system as you proposed. 



Rick Reyes

    Grade - AIFSQN

  • IFSQN Associate
  • 37 posts
  • 11 thanks
19
Good

  • United States
    United States

Posted 23 March 2022 - 07:31 PM

NorCalNate, the use of cameras is absolutely appropriate for this function, the only issue is that the review of the footage must be scheduled so that it provides for appropriate detection of a threat. If you have a set review of the video footage for once a month at the end of the month but you use all the contents of the tanks four times during that time period then this is definitely not an appropriate review period for this process. The idea is to be able to detect any threats prior to any negative effects on your processes of products. The other issue with the use of cameras is that unless they are constantly being reviewed by a security team in real time then you must document the review of the camera footage, who reviewed the footage and when in a written document.



NorCalNate

    Grade - MIFSQN

  • IFSQN Member
  • 69 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 23 March 2022 - 07:57 PM

NorCalNate, the use of cameras is absolutely appropriate for this function, the only issue is that the review of the footage must be scheduled so that it provides for appropriate detection of a threat. If you have a set review of the video footage for once a month at the end of the month but you use all the contents of the tanks four times during that time period then this is definitely not an appropriate review period for this process. The idea is to be able to detect any threats prior to any negative effects on your processes of products. The other issue with the use of cameras is that unless they are constantly being reviewed by a security team in real time then you must document the review of the camera footage, who reviewed the footage and when in a written document.

 

Yes, I agree with your assessment. There is one other factor I'd appreciate your opinion on:

 

There is equipment in this area which we use to sort and crush grapes (only use during harvest). Though there is a possibility we could enclose the outside tank area (my initial post), there is no possible way to fence this area. That being said, I did confirm when in use this area is sanitized each morning (and swabbed).

 

With this new information, even if we enclose the tank area, I'm guessing we would have to implement a camera-review system for the equipment in this area since it's food contact? If that's the case, then I'd propose the following:

 

1. When any equipment in this area is being utilized (tanks or grape sorters/crushers), Management must review the previous day and evening's motion captures before any production can begin (I'd need to create a log/form), OR at a frequency which ensures none of the tank contents be transferred to our cellar area before footage is reviewed

2. Tanks required for use must undergo an inspection (confirm each opening was locked, confirm correct lock# for each valve, and look for any signs of tampering)

3. All outside tanks with juice must be locked by the end of the day (every opening), lock#s must be recorded and verified the next morning

 

Thoughts greatly appreciated!



kingstudruler1

    Grade - PIFSQN

  • IFSQN Principal
  • 825 posts
  • 284 thanks
242
Excellent

  • United States
    United States

Posted 24 March 2022 - 06:37 AM

Why do we feel like a good lock and / or seal program is inadequate and a fence is still needed?

The crushing equipment, etc seems like a bigger issue.   

 

alcohol is not subject to IA laws.  However,  below is some good information and inexpensive training  on the subject.  - if you are unfamiliar with key activity types, mitigation strategy, etc. 

 

https://www.fda.gov/...113684/download

 

https://www.ifsh.iit...al-adulteration


eb2fee_785dceddab034fa1a30dd80c7e21f1d7~

    Twofishfs@gmail.com

 


Rick Reyes

    Grade - AIFSQN

  • IFSQN Associate
  • 37 posts
  • 11 thanks
19
Good

  • United States
    United States

Posted 24 March 2022 - 03:55 PM

Kingstudruler1, I am a food manufacturer so I am definitely  covered under the FSMA rules and all of it's requirements, my understanding of the rules is that FDA considers wineries as food manufacturers so making them subject to all FSMA rules that address Food Defense and Preventive Controls involved in those processes. Since wineries include at least two of the key activities types special measures are required to address the potential risks. Our facility is fully fenced and we still had to answer some difficult questions from the FDA auditor less than a month ago over our bulk storage tanks. The goal is to have a robust program that can stand up to all lines of questioning and ensures that the public safety is being addressed in a manner that is appropriate for the risks that were assessed. 



mgourley

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,403 posts
  • 997 thanks
274
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Plant City, FL
  • Interests:Cooking, golf, firearms, food safety and sanitation.

Posted 24 March 2022 - 08:19 PM

I'll defer to Glenn as the SQF expert, but I am curious.

What is the exact wording in the SQF clause that requires a complete enclosure?

 

Marshall



kingstudruler1

    Grade - PIFSQN

  • IFSQN Principal
  • 825 posts
  • 284 thanks
242
Excellent

  • United States
    United States

Posted 24 March 2022 - 09:46 PM

Kingstudruler1, I am a food manufacturer so I am definitely  covered under the FSMA rules and all of it's requirements, my understanding of the rules is that FDA considers wineries as food manufacturers so making them subject to all FSMA rules that address Food Defense and Preventive Controls involved in those processes. Since wineries include at least two of the key activities types special measures are required to address the potential risks. Our facility is fully fenced and we still had to answer some difficult questions from the FDA auditor less than a month ago over our bulk storage tanks. The goal is to have a robust program that can stand up to all lines of questioning and ensures that the public safety is being addressed in a manner that is appropriate for the risks that were assessed. 

 You are correct.   Everyone should follow food defense.  It is the right thing to do.   In their case, t is also required for SQF/GFSI.    

 

FSMA is required for alcohol beverage.   However, it is usually exempt from the IA rule as is animal food.     

 

I believe everyone should take the IA training if they are developing a food defense plan.  It is needed  to make the best decisions for their facility.  I would hate to see someone spend all of their resources on the most obvious KAT / area / process and ignore the rest.   Or apply a strategy based off of a suggestion from someone with no knowledge of the operation and in some cases knowledge of the applicable laws or requirements.       

 

 

E. Alcoholic Beverages
Contains Nonbinding Recommendations Draft-Not for Implementation
 
  17 
 
The IA rule requirements do not apply with respect to alcoholic beverages at a facility that meets the following two conditions: • Under the Federal Alcohol Administration Act (27 U.S.C. 201 et seq.) or chapter 51 of subtitle E of the Internal Revenue Code of 1986 (26 U.S.C. 5001 et seq.) the facility is required to obtain a permit from, register with, or obtain approval of a notice or application from the Secretary of the Treasury as a condition of doing business in the United States, or is a foreign facility of a type that would require such a permit, registration, or approval if it were a domestic facility; and  • Under section 415 of the FD&C Act the facility is required to register as a facility because it is engaged in manufacturing, processing, packing, or holding one or more alcoholic beverages.  (21 CFR 121.5(e)(1)).  Additionally, this exemption applies to food at these facilities that is not an alcoholic beverage, if such food is in prepackaged form that prevents any direct human contact with the food and constitutes not more than 5 percent of the overall sales of the facility, as determined by the Secretary of the Treasury.  (21 CFR 121.5(e)(2)).


eb2fee_785dceddab034fa1a30dd80c7e21f1d7~

    Twofishfs@gmail.com

 


NorCalNate

    Grade - MIFSQN

  • IFSQN Member
  • 69 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 29 March 2022 - 02:49 PM

What is in the tanks?  Food ingredient?  I worked at a place where we had silos that sent flour into our building.  We did not have a fence.  We had locks on the silo doors as well as security cameras to monitor the area.  We also did at least a weekly documented inspection of the area, as well as inspected the are before receiving more product. Never had a food defense issue with auditor on this set-up.

 

I also believe there is some leeway in regards to cost.  As you say, get creative.  One audit they had found multiple spots in a floor that concerned them. It was not viable for us to fix the entire floor as that would be a huge cost to the facility and would hinder us financially from customer standpoint.  We were able to risk assess the floor and create a 3 phase project.  Floor in that were the worst and higher risk were completed one year, followed by the next phase the following year and so on.  We also monitored the areas and anything real deep was cleaned out and fixed with a temporary concrete patch that would hold up until that floor area was able to be worked on.  Hope that gives you an idea.

Did your facility pass your SQF audit with your outside silos not being fenced and you doing weekly inspections and having security footage?



NorCalNate

    Grade - MIFSQN

  • IFSQN Member
  • 69 posts
  • 2 thanks
0
Neutral

  • United States
    United States

Posted 29 March 2022 - 09:45 PM

Does anyone know the requirements for outside fence height for Food Defense? Would an 8' fence (chain link) with 1' of 3-strand barbed wire suffice?



mgourley

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,403 posts
  • 997 thanks
274
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Plant City, FL
  • Interests:Cooking, golf, firearms, food safety and sanitation.

Posted 29 March 2022 - 11:14 PM

Since you are regulated by the FDA, "Food Defense" is pretty much an obsolete term. 

(Hold the flame throwers while I explain)

 

Prior to the Intentional Adulteration Rule that is part of FSMA, the FDA did in fact have a "Food Defense Plan Builder" that facilities could use to create a Food Defense Plan. It asked things like was there fencing around the property, etc, but there never was (and still isn't a height requirement for fencing).

 

The Intentional Adulteration Rule addresses four "Key Activity Types" where years of study determined the most likely places where intentional adulteration could take place. One of them is bulk liquid storage.

 

If you have a bulk liquid storage tank that has hatches or other means of ingress, having those secured against intentional adulteration is one of the things you need to comply with the IA Rule.

There is no requirement for fence height, composition or anything else.

 

The issue that I see in this thread is that there is some SQF requirement for total enclosure of said tank.

What is the exact wording in the applicable clause of the SQF code that requires this?

 

I just can't see the SQF code being that specific.

 

Marshall



G M

    Grade - SIFSQN

  • IFSQN Senior
  • 483 posts
  • 94 thanks
131
Excellent

  • United States
    United States
  • Gender:Male

Posted 28 July 2022 - 09:24 PM

...

I just can't see the SQF code being that specific.

...

 

Very few parts of it are.  The most relevant section would seem to be:

 

 

2.7.1 Food Defense Plan (Mandatory) ...

v. The measures taken to ensure the secure receipt and storage of raw materials, ingredients, packaging, equipment, and hazardous chemicals to protect them from deliberate acts of sabotage or terrorist-like incidents;
vi. The measures implemented to ensure raw materials, ingredients, packaging (including labels), work-in-progress, process inputs, and finished products are held under secure storage and transportation conditions; and
vii. The methods implemented to record and control access to the premises by site personnel, contractors, and visitors.
 
 

The measures taken for a refer or tank truck would seem to be adequate for less mobile outdoor storage vessels too (locks, seals with serial numbers).  A lighted area with security cameras would fit most of the generic exterior security expectations.





Share this


0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users