I'm trying to fully wrap my brain around this topic. We are a Wine Production and Bottling facility. Is a Glass and Brittle Plastic Registry an SQF Requirement? If so, in order to comply do we just need to note each item in our Production area and inspect periodically?
Is this something that a Risk Assessment might be able to take care of? From our perspective, we are not too concerned with this topic as all our product goes through multiple filtering stages including sterile filtered prior to bottling.
Another NC we got was that our facility windows aren't shatter proof. For us this is definitely not a Food Safety risk, so my thoughts are to address this NC in a Risk Assessment. Otherwise, we will not get Mgt approval to replace ALL our windows.
The glass and brittle plastics register is a requirement, however, the SQFI just did a free webinar on risk assessments and using them as exemptions to parts of the code. They did say that you had to provide any sort of exemptions up front to your certification body prior to them coming on site and scheduling a visit. I think that coupled with a glass and plastics breakage/clean-up procedure would be more than adequate. SQF Code Edition 9 Presentations - SQFI
If you were to go the route of the risk assessment, it would be best done as an appeal to your non-conformance, not as a corrective action.
Having the glass and plastics audit is a good way to keep up with maintenance and ensure that everything that breaks is cleaned/ repaired appropriately to not contaminate your product. If you can prove that the tiniest piece of glass would never get through your filter, or damage the filter, great! As for the windows, that could go into glass and brittle plastics policy and simply put in place a plan for what would be done if a window were to break and how you would check the safety of the environment/product. Then say how you would replace them with shatterproof. You don't need to do it all at once. It's a huge cost.