10 replies to this topic

[garlicbread420]

Hello folks,

I have a question that I have asked around, researched some but could not find any good ideas. 

 

So the problem is, we store some products that need 'refrigeration' and some that dont in our 'cooler' area. Now technically, as per Canadian regulations, the temperature must not go above 4 Deg C. But we cannot achieve this due to multiple number of reasons (repeated door opening, old building, management not ready to invest in the building as they are buying a new one). We have our BRC Audit in upcoming months and still not sure how to handle this.

Interestingly, we send our temperature records to our clients and they all seem to be okay with it (6.5 Deg C)- and have never complained or such. They wont say anything on record for obvious reasons. 

 

So, now, how do we explain all this to an auditor ? any ideas ? 

[Scampi]

ok---so it's great that your customers don't care--but that doesn't make it right (as you well know)

 

you need to perform shelf life testing to show that your 6.5 isn't affecting that

 

you need a documented statement re: the new facility

 

get management to spend the $$ on a high speed door install (they can take it with them to new place)

 

put data loggers in the middle of pallets to show what the product temp is (as the room could be cold enough to keep your product 4 or below

 

Include a statement in your storage procedure that some product(s) that do not require refrigeration may be stored in the cooler---but you MUST mark them some how

 

May i suggest that you don't store product in there that doesn't need to be---that should equal less door openings, no?

[olenazh]

Hi, welcome to the forum. So, your management is investing in BRC certification, but doesn't want to spend money on adding couple more ref units to the cooler, eh? I personally don't see how you could explain high temperatures in your refrigerating area to the auditor. We're also in an old building, and are buying a new one soon, and our cooler doors have been kept open quite often - however, it has nothing to do with keeping cooler temperatures under 4C. It's not only to comply with Canadian regulations, but simply to cover our rear end: in any case of threat to public health due to spoiled product, your company's loss would be not only its reputation, but much more money than they'd spend on the cooler improvement.

[Charles.C]

Hello folks,

I have a question that I have asked around, researched some but could not find any good ideas. 

 

So the problem is, we store some products that need 'refrigeration' and some that dont in our 'cooler' area. Now technically, as per Canadian regulations, the temperature must not go above 4 Deg C. But we cannot achieve this due to multiple number of reasons (repeated door opening, old building, management not ready to invest in the building as they are buying a new one). We have our BRC Audit in upcoming months and still not sure how to handle this.

Interestingly, we send our temperature records to our clients and they all seem to be okay with it (6.5 Deg C)- and have never complained or such. They wont say anything on record for obvious reasons. 

 

So, now, how do we explain all this to an auditor ? any ideas ? 

Hi gb,

 

I daresay nothing to explain since the cause will probably be self-evident to the auditor, Simply accept  at least one forthcoming NC. The incurred corrective actions /  RCA should at least be fairly straightforward.

 

Do the Canadian Regulations also stipulate the consequence of such a temp. deviation as far as the stored product is concerned ? (Note that yr temp. data would probably be perfectly acceptable in UK if this knowledge is of any "help").

[Scampi]

The law is clear----product temp not room temp

 

refrigerated, in respect of a food, means that it is kept at a temperature of 4°C or less, without being frozen. (réfrigéré)  https://gazette.gc.c...ors108-eng.html

 

you will recevie a non conformance from CFIA and a timeline to correct it when the perform this inspection

[garlicbread420]

Thank you everyone.

 

I know it will be a tough pill to swallow but the management has to spend some money on it to get it under 4 Deg C. I dont see any other way either. 

[sqflady]

Silly question but have you talked to maintenance?  Do they have a way to adjust the temperature down or is it at the lowest it can go?  What type of thermometer are you using?  The type with the little glass bottle of solution is more indicative of product temperatures since there is less variation with door openings.

[garlicbread420]

Silly question but have you talked to maintenance?  Do they have a way to adjust the temperature down or is it at the lowest it can go?  What type of thermometer are you using?  The type with the little glass bottle of solution is more indicative of product temperatures since there is less variation with door openings.

Not a silly question at all. I have tried with both water type and other sensor types. Both show similar temperatures.

Maintenance can set it to 'freezing' to cool it down but the building is not made to withstand that and it leads to ice formation near the condenser unit which ultimately melts on the floor and product when we adjust it to cooling later on. 

So yeah I have pretty much tried all permutations and combinations but the only thing that would fix is upgrade of condenser units - the ones we have are from the 60s. 

[garlicbread420]

The law is clear----product temp not room temp

 

refrigerated, in respect of a food, means that it is kept at a temperature of 4°C or less, without being frozen. (réfrigéré)  https://gazette.gc.c...ors108-eng.html

 

you will recevie a non conformance from CFIA and a timeline to correct it when the perform this inspection

Yeah, the laws are clear. It is funny that the clients do not care but somehow we will be in trouble for our BRC Audit. I know it is wrong but I have seen clients send ambient trucks to pick up the stuff we keep in our cooler. We share all records with our clients on a weekly where we write the actual cooler temperatures - around 5-6 Deg C and have never had a complaint. 

 

So I am still stuck when I tell the management to fix. They always say our clients dont care and they wont make any money from it (warehouses are all full - and we have to decline our clients for storage). So a tough spot for me right now. 

[Ryan M.]

Not only shelf life, but potential for food safety depending on the product.

[Charles.C]

Not only shelf life, but potential for food safety depending on the product.

Hi Ryan,

 

Seems unlikely inasmuch as, afaik, UK accept max 8degC.

 

I don't recall ever seeing a claim that US/Canadian Food is safer than that in UK in this context ?. A question of Validation I suppose.

 

But maybe coming soon.