Use of compressed air to fill a Flexible Intermediate Bulk Container before filling
We use compressed air to fill a Flexible Intermediate Bulk Container (FIBC) before we fill it with dry ingredients. The air is used to keep the FIBC upright during the filling process. The tip of the hose is used at the top of the FIBC and is removed before we begin the fill. Is it necessary to use a filter on the end of the air hose? I don't think of it as coming in contact with the ingredients (BRC 4.53), as the hose is only used to fill the IBC. Thoughts? Thank you.
I am a little unfamiliar with this process. For clarity, is the inside of the container a contact surface for the product? In other words, are you spraying compressed air onto a food-contact surface?
From 21 CFR 110.40(g)
Compressed air or other gases mechanically introduced into food or used to clean food-contact surfaces or equipment shall be treated in such a way that food is not contaminated with unlawful indirect food additives
My understanding is that compressed air used on food or food-contact surfaces must not be contaminated with debris, oil, etc. You could test your compressed air system to see if it's outputting clean air. If not, a filter may be necessary. A filter doesn't necessarily have to go at the end of the hose, it can be upstream (typically just after the air tank) as long as the hose line is clean. And of course, make sure the compressor is serviced with food-grade oils only.
Yes, the inside of the FIBC is direct food contact.
Thank you.
You definitely want a compressed air testing program in place and a verification for it on some time table based on risk. It might be annual, it might be every week. That will be your decision based on risk of air contamination.
Since the air is in contact with food contact surface your program needs to ensure and prove the food going in will not be at risk of contamination.
... Is it necessary to use a filter on the end of the air hose? ...
Not BRC here, but similar GFSI requirements in SQF.
A touches B touches C; SA=SC. The sanitation level of the compressed air needs to be adequate for contact with the product, because the interior of the container touches them both.
The filter doesn't necessarily need to be on the "end" of the hose, but it needs to be sanitary air coming out, and you'll want a sanitation/maintenance program to support it just like the water systems.