3 replies to this topic

[NicoleChurchill]

Hi Everyone!
I need some help..
In the middle of our audit for BRCGS standard 8 and have run into a little problem.  We utilize card boxes for inedible.  These boxes are used in the raw section of our facility As the Master Outer case of product that is in a plastic bag with closure.  No risk of touching the corrugate.  
In the RTE, we utilize these same boxes (new, not reused, never been in the raw) for collection of inedible RTE waste (slicer waste- ie; small slices).  This waste once collected goes directly to our garbage compactor (including the box).  The cardboard boxes are never reused...they are disposed with the waste product.
Our BRCGS auditor is stating that this is not in compliance with section 54 of the SFCR.
Meaning, we are in a regulatory issue....
Can someone help in terms of guidance to prove that these boxes do not fall under the section 54 of the SFCR.
Thanks in Advance!

[kingstudruler1]

Ouch.   Im not canadian so this law confuses me.   There does not appear to be a definition of conveyance.  Is the box a conveyance or container?  Does it matter?  Which part of 54 do they have an isssue with (A,B, Or C)?    

 

if "B", and the box isn't labeled as waste, etc, I could see that being an issue for you.   

If "A"  could you make the that each individual  box is only used for trash?  

 

 

Other conveyances and equipment

54 Any conveyance or equipment in an establishment that is used to handle any contaminated materials, any waste or any other thing that is inedible must, unless that conveyance or equipment does not come into contact with those materials, waste or things,

• (a) be used only for that purpose;

• (b) be identified as being reserved for that purpose; and

• © meet the applicable requirements of section 53.

Edited by kingstudruler1, 15 March 2022 - 11:26 PM.

[Scampi]

You are in breach of the regulation

 

You cannot use ANY form of your packaging to handle waste-----you need to purchase containers that are designated AND identified for waste/inedible

 

BTW you may also want to check if you should be denaturing your inedible prior to disposal   OR   perhaps (if this is protein) you should be sending it to a rendering plant and not the compacter

 

A CFIA inspector would tell you the same re: section 54

 

Sub-section 66(2): Frequency and manner of removal and disposal

• You remove and dispose of contaminated materials and waste at a sufficient frequency and in a manner that prevents contamination of the food
  Examples:

  • You remove waste and contaminated materials at a set frequency, or more often if necessary so that they do not overflow
  • You remove contaminated materials and waste from the establishment using predetermined routes
    • You construct effluent or sewage lines such that they do not pass directly over or through production areas, unless you take measures to prevent risk of contamination of the food
    • You only allow designated employees to remove contaminated materials and waste. These employees wear appropriate clothing, such as overalls, gloves and boots, when removing the contaminated materials and waste
    • For fishing or harvesting vessels, you dispose of sewage in a manner that does not present a risk of contamination to the surrounding waters
  • For additional information refer to the guidance material on Preventing cross-contamination

he size and layout of your establishment is adequate and accommodates the activities conducted. For example:

• incoming materials (food, non-food, packaging) are received in an area separate from food processing areas
• you have separate facilities for:
  • the storage of waste and inedible products
  • cleaning and sanitizing equipment used for waste/inedible products
• 2.4 Waste and inedible/food disposal (section 66 of the SFCR)

  You handle and dispose of waste, such as garbage, discarded packaging, broken pallets, discarded construction materials, and inedible products or food waste in a manner that prevents the contamination of your food. For example:

  • the utensils and containers used to collect, hold and dispose of waste are identified
  • the frequency at which you remove the waste prevents its accumulation and the attraction of pests that may contaminate your food
  • the waste is stored and covered in a manner that prevents the release of objectionable odours
  • the equipment used to contain and store waste is leak proof
  • the drainage and sewage system can handle the volume and type of liquid waste created and prevents pooling
  • contaminated materials and waste are removed from the establishment by designated employees using predetermined routes
    • employees wear appropriate clothing when removing contaminated materials and waste.
    • The route followed prevents cross-contamination of your food by the waste.
  • inedible meat products are stored in an enclosed area dedicated to the handling of inedible products
  • specified risk material is collected, stored in a dedicated area within the inedible meat product area, and disposed of in accordance with the Health of Animals Regulations

[kingstudruler1]

 

You are in breach of the regulation

 

You cannot use ANY form of your packaging to handle waste-----you need to purchase containers that are designated AND identified for waste/inedible

 

BTW you may also want to check if you should be denaturing your inedible prior to disposal   OR   perhaps (if this is protein) you should be sending it to a rendering plant and not the compacter

 

A CFIA inspector would tell you the same re: section 54

 

Sub-section 66(2): Frequency and manner of removal and disposal

• You remove and dispose of contaminated materials and waste at a sufficient frequency and in a manner that prevents contamination of the food
  Examples:

  • You remove waste and contaminated materials at a set frequency, or more often if necessary so that they do not overflow
  • You remove contaminated materials and waste from the establishment using predetermined routes
    • You construct effluent or sewage lines such that they do not pass directly over or through production areas, unless you take measures to prevent risk of contamination of the food
    • You only allow designated employees to remove contaminated materials and waste. These employees wear appropriate clothing, such as overalls, gloves and boots, when removing the contaminated materials and waste
    • For fishing or harvesting vessels, you dispose of sewage in a manner that does not present a risk of contamination to the surrounding waters
  • For additional information refer to the guidance material on Preventing cross-contamination

he size and layout of your establishment is adequate and accommodates the activities conducted. For example:

• incoming materials (food, non-food, packaging) are received in an area separate from food processing areas
• you have separate facilities for:
  • the storage of waste and inedible products
  • cleaning and sanitizing equipment used for waste/inedible products
• 2.4 Waste and inedible/food disposal (section 66 of the SFCR)

  You handle and dispose of waste, such as garbage, discarded packaging, broken pallets, discarded construction materials, and inedible products or food waste in a manner that prevents the contamination of your food. For example:

  • the utensils and containers used to collect, hold and dispose of waste are identified
  • the frequency at which you remove the waste prevents its accumulation and the attraction of pests that may contaminate your food
  • the waste is stored and covered in a manner that prevents the release of objectionable odours
  • the equipment used to contain and store waste is leak proof
  • the drainage and sewage system can handle the volume and type of liquid waste created and prevents pooling
  • contaminated materials and waste are removed from the establishment by designated employees using predetermined routes
    • employees wear appropriate clothing when removing contaminated materials and waste.
    • The route followed prevents cross-contamination of your food by the waste.
  • inedible meat products are stored in an enclosed area dedicated to the handling of inedible products
  • specified risk material is collected, stored in a dedicated area within the inedible meat product area, and disposed of in accordance with the Health of Animals Regulations

 

 

I knew scampi would have the answer.