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SQF 9.6.6 Loading, Transport, and Unloading Practices

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TylerJones

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Posted 03 August 2022 - 02:38 PM

Hi all,

 

Back to pick your minds.

 

Background: Going for first SQF audit this year at this site. I have personnally done SQF / BRC for 10 years but have never came across this issue. We are a meat production facility receiving frozen raw meat and process to fully cooked cryovac RTE refrigerated packages. My concern right now is receiving:

 

9.6.6.4: Loading and unloading docks shall be designed to protect the product during loading and unloading. Loading practices shall be designed to minimize unnecessary exposure of the product to conditions detrimental to maintaining product and package integrity during loading and transport.

 

9.6.6.8 Unloading practices shall be designed to minimize unnecessary exposure of the product to conditions determental to maintaing product and package integrity.

 

Past facilities I have worked at have had a real dock that fits a 53' trailer with door seals, air curtians all the necessities for safely receiving and loading. Here all trucks park in the center of the road (we are in a neighborhood) I block all traffic with my forklift and unload frozen meat pallets and then open a roll-up door and place them in a tempering refrigerator. Same goes with all roll stock, spices and anything inbound. If its snowing we shovel a path, if its is raining we get soaked. All product is on pallets, has plastic coverings, wrapped with shrink wrap before removing from trailers. Is that sufficient to meet this clause? There is no way to back a trailer in to the parking lot or create some sort of dock, Has anybody had a situation like this or auditied a facilty that where there was no offical dock?

 

I have put plastic strips on all roll up doors. There arre ILTS inside by roll up doors and mouse traps on the left and right of all roll up doors. 

 

Thanks

 

 


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jfrey123

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Posted 03 August 2022 - 04:29 PM

I see pushback based on forklift sanitation, weather exposure on your sealed pallets, and the open rollup door itself.  I've had to deal with similar issues in the past, auditors generally hate seeing a forklift go into a parking lot, but I've worked for smaller companies and "things happen", to put it mildly.

 

  • Auditor isn't going to like seeing your forklift go outside and then reenter a raw material area.  You might be able to document a cleaning of the forklift (including wheels) as well as the floors traveled to overcome this, and back it up with good historical environmental swabbing, but in the end it's up to you to prove that receiving practice isn't bringing in contamination.
  • Rain water falling onto a product is going to be a concern.  You might get away with drying and removing/disposing of exposed shrink immediately as the product enters and before the pallet gets to the storage area.
  • Strip curtains alone generally do not meet the standard for pest/vermin proofing of an entry door.  I've had auditors accept an fast moving automatic rollup door combined with a really strong air curtain when the ILT's in the area showed no spikes in activity compared to other plant areas.


OrRedFood

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Posted 03 August 2022 - 07:36 PM

 

I see pushback based on forklift sanitation, weather exposure on your sealed pallets, and the open rollup door itself.  I've had to deal with similar issues in the past, auditors generally hate seeing a forklift go into a parking lot, but I've worked for smaller companies and "things happen", to put it mildly.

 

  • Auditor isn't going to like seeing your forklift go outside and then reenter a raw material area.  You might be able to document a cleaning of the forklift (including wheels) as well as the floors traveled to overcome this, and back it up with good historical environmental swabbing, but in the end it's up to you to prove that receiving practice isn't bringing in contamination.
  • Rain water falling onto a product is going to be a concern.  You might get away with drying and removing/disposing of exposed shrink immediately as the product enters and before the pallet gets to the storage area.
  • Strip curtains alone generally do not meet the standard for pest/vermin proofing of an entry door.  I've had auditors accept an fast moving automatic rollup door combined with a really strong air curtain when the ILT's in the area showed no spikes in activity compared to other plant areas.

 

I'm interested in the last line of your response - We have a shipping/receiving dock which has a metal roll up door and a brand new screen which is opened and closed using a motor.  We do not have the dock seal unit to enclose trucks that back in for shipping/receiving.  We are SQF certified, going on our third in person audit after the desk audit.  Somehow the auditor did not write up the lack of the enclosure on the dock door (this was prior to my working here). We have a new auditor this year, who will likely notice the issue. 

 

Has anyone else had any experience with not having the seal around the truck?  We do have a quote, but have not pulled the trigger on it due to the expense.  

 

Thanks!


Edited by OrRedFood, 03 August 2022 - 07:36 PM.


G M

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Posted 03 August 2022 - 08:22 PM

... There is no way to back a trailer in to the parking lot or create some sort of dock, Has anybody had a situation like this or auditied a facilty that where there was no offical dock?

 

...

 

Yes, I've seen it before.  One administrative location is actually covering two establishments as recognized by USDA, and the older facility is small and located in an older business district -- the building is over 100 years old, and has no loading dock.  The forklift drives out onto the street and pulls pallets out of trucks and drops them in the "warehouse" portion of the building.

 

Raw, RTE, seasoning, packaging all comes in that way in thoroughly wrapped pallets with dust covers.  Compared to how the larger facility operates, it seems very antiquated and sketchy, but the inspectors never raised an issue over it.



jfrey123

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Posted 03 August 2022 - 08:25 PM

I'm interested in the last line of your response - We have a shipping/receiving dock which has a metal roll up door and a brand new screen which is opened and closed using a motor. We do not have the dock seal unit to enclose trucks that back in for shipping/receiving. We are SQF certified, going on our third in person audit after the desk audit. Somehow the auditor did not write up the lack of the enclosure on the dock door (this was prior to my working here). We have a new auditor this year, who will likely notice the issue.


That door with air curtain was at a company I consulted with a few times. They had a need to bring material from one storage area inside the production building across a parking lot to their shipping warehouse via forklift up and down a ramp. This situation was justified as safe as production forklifts never entered this storage area, and the product was never permitted to be opened in any storage or shipping areas, combined with favorable pest and EMP results historically.

For a loading dock as you describe, door seals have been a hit in the past for us. Auditors will argue a truck parked and actively loaded/unloaded at that door must be sealed to the building due to the amount of time that elapses. I’ve had an auditor at another plant go so far as to ask for one of our company trailers to be backed to the door to simulate unloading, and dinged us when they saw light between the trailer and seal.


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TylerJones

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Posted 04 August 2022 - 02:59 PM

Thanks for your repsonses. I have multiple pallet jacks that I can strategically place around the facility so that outside stays outside and the ones inside are "cleaner' I think they are enough to color code, I have some other tricks up my sleeve but some hazard analysis and plastic wrapping will be documented in greater depth. We are indeed antiquated and sketchy but leaves only room to improve! Thanks for all the input.

 

Tyler 


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