Implementing Shatterproof covers
Hi, we are a relatively new company that manufactures Lettuce in our 2 acre green house. We currently have in place a Food Defense procedure to check lightbulbs 3 times a day for any damage, or faultiness.
My question is that based on SQF 18.1.2.10 we need to have shatterproof covers or something a kin to that. Do we need to purchase shatterproof covers (roughly 500 bulb covers at 17$ a pop) or can we mitigate that with a strategy of the 3 times check a day or something better?
We are trying to save money in the long run, but need to be compliant, so any help would be great.
This is actually a foreign material issue and not food defense
A food defense threat assessment shall be conducted to identify potential threats that can be caused by a deliberate act of sabotage or terrorist-like incident.
18.1.2.10
Lighting and light fixtures in product handling areas, inspection stations, ingredient/ input and packaging storage areas, and all areas where the product is exposed shall be: i. Of appropriate intensity to enable personnel to carry out tasks efficiently and effectively;
and ii. Shatterproof, manufactured with a shatterproof covering, or fitted with protective covers. Where fixtures cannot be recessed, including in warehouses, structures must be protected from accidental breakage, manufactured from cleanable materials, and addressed in the cleaning and sanitation program.
So you can perform a risk analysis and TRY that, but your risk analysis will need to be incredibly robust, AND your final step would need to show how you'll determine what product was affected AND that you will dispose of any product if there is ANY risk whatsoever
I really appreciate your quick response that pointed me in a better direction. Thank you.
You will not be able to get around the shatterproof requirement as I have not seen a successul argument/risk asessment for not installing shatterproof materials.
I agree with Scampi!
You could also perform checks as you mentioned and say it is a part of your glass and brittle plastics audit (at a frequency you are are comfortable putting on if a bulb shatters).
You may also want to consider making the change gradually and replace the bulbs with shatterproof as they burn out, that way it is not a huge upfront cost but more manageable over time.
Agree with Kara
As part of your process, you need to do the math on losing your crop (because you will have to bin alot) in the event of a bulb exploding (they have been known to do that) vs a slow and steady plan to replace them all
I'm with Glenn, shatterproof bulbs and be done with it.
what type of lights do you currently have?
A few things:
- "Lighting and light fixtures in product handling areas, inspection stations, ingredient/ input and packaging storage areas, and all areas where the product is exposed shall be:" That's as far as you need to go with that one. "Shall be" is a mandated item.
- Why not just pay for LED lighting once and be done with it? We've been converting our fixtures (over 450 fixtures with 4 lamps per) to 110V direct wire lamps. The price has come down considerably and they are now very affordable.
- McMaster Carr has a lamp shield for 48" T8 lamps for $4.81. That's what we have until the fixtures get upgraded to LED. (The most expensive is $15.22 for 96" T12 which are getting nearly impossible to find)
I'm with Glenn on this one too, eliminate the 3X a day inspections of the 500 bulbs and just check them every week or every month with your glass and brittle plastic inspections. It's a lot less procedurally too, and once the initial cost is past you it's a minute maintenance cost from there out.