19 replies to this topic

[AJL]

Hi!

Upcoming BRC audit here and starting to get a little stressed about the chemical control. 

What we had was a whole lot of cleaning chemicals stored in a chemical cage, fine, no worries. ! That was locked. 

So then we also had a cupboard (not locked) where we store a whole lot of lubricants. 

The lubricants had been a mix of 'approved for coming into contact with food' and then some which should not come into contact. 

We also tend to have 3 containers of cleaning chemicals to the side in an adjacent room to production (opened) which we use just when cleaning. 

So in the last internal audit we were asked how the operators could tell the difference between the approved lubricants and the non approved. (for food contact). 

 

All the food contact lubricants were then left downstairs (unlocked cupboard) and the others moved to a different storage location (unlocked). 

 

Can you see anything wrong with the current situation? I am trying also trying to write an SOP that outlines how we deal with chemicals, which reflects the new requirements of ver. 9. :)

Thanks!

[Miss Frankie]

We had food grade and non-food grade in the same cabinet, but clearly marked.  Food grade on the upper shelf, non-food grade on lower shelves.

Multiple auditors, including our very picky consultant had no issues with that.

[AJL]

Ok that it isn't locked?

[Miss Frankie]

Ok that it isn't locked?

 Our chemicals were in the maintenance shop, which was locked but the cabinet itself was not locked.

 

Cleaning chemicals were accessed by drop lines/hoses all around the plant. The main source of chemicals were locked, but anyone could use the hoses for cleaning.

[jfrey123]

Lock on the maintenance shop itself is sufficient, as the goal is to make sure non-maintenance employees cannot access the chemicals.

 

Primarily dealing with SQF, it is a requirement that all hazardous chemicals be locked (11.6.4.2 ii).  It goes towards food defense, as well as making sure only trained employees are accessing the chemicals when needed.

 

So long as the different types of chemicals are stored in designated areas, they can be adjacent or in the same room for the sake of space savings.  You'll want physical separation at best, different locks on different cabinets can be helpful to prove you're maintaining access control.  And it would be wise to add checking the chemical inventories are in the correct spots in your monthly audits.

[AJL]

Ok, the food grade lubricants don't need to be locked away right? They technically aren't hazardous.
The other lubricants could possibly be hazardous?
Or am I looking at this in the wrong way.

[Charles.C]

(a) Ok, the food grade lubricants don't need to be locked away right? They technically aren't hazardous.
The other lubricants could possibly be hazardous?
Or am I looking at this in the wrong way.

 

Hi AJL,

 

(a) Wrong and possibly wrong.

 

BRC8 (not yet viewed BRC9)

4.9.1.1 Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include, at a minimum:
•  an approved list of chemicals for purchase
•  availability of material safety data sheets and specifications
•  confirmation of suitability for use in a food-processing environment
•  avoidance of strongly scented products
•  the labelling and/or identification of containers of chemicals at all times
•  a designated storage area with restricted access to authorised personnel
•  use by trained personnel only.

## (My addition) - Apply Safety Regulations (eg avoid storing sacks of Sodium Metabisulphite in proximity to Calcium Hypochlorite (= Boom !))

 

 Non-food Chemicals -  Canadian Definition -  Non-food chemicals such as water-treatment chemicals, boiler-treatment chemicals, chemicals for cleaning and sanitizing are suitable for use. "Suitable" presumably relates to the specific chemical/application,eg - 

https://inspection.c...6/1528209219187

 

The BRC8 Guidelines have a lot on this topic.

IMEX BRC expected Physical Partitioning in lockable/controlled rooms between (a) Food Ingredients / Process/Environment Non-Food Chemicals and (b) Engineering-related Non-food chemicals.

Some Chemicals necessitate individual Storage locations for Health/Safety Reasons, eg strong Oxidising/Reducing agents in proximity = Boom !.

[Marloes]

Also don't forget that ''Food Grade'' does not mean that it is edible!

Food grade usually refers to ok for incidental food contact. 

 

You also want to lock up your chemicals to prevent tampering (e.g. food defense).

[AJL]

Thanks Marloes.
How far does it go?
We have for example a washing machine with washing powder ... (By staff facilities) and also some (household) cleaning chemicals in the cantine/changing areas.
Thoughts? Does the whole lot need locking up?

[jfrey123]

That washing powder and those household chemicals in the changing area shouldn't be stored in the open.  There should be a lockable storage area for them, even if it is in the same room, to ensure untrained (or even disgruntled) employees cannot access them.  They'll also want it demonstrated that sanitation chemicals aren't out near active production, locking everything up ensures that.

 

Say a sanitation employee runs out of the cleanser they use for equipment cleaning, but they can't find their supervisor to open the cleaning chemical storage for them.  So they wander over and grab the washing powder, mix it up in their bucket.  They think soap is soap, they just want to do their job, but now you've got food grade contact washed with unapproved detergents.  These scenarios are the type of thing an auditor will challenge you with when they find chemicals unsecured.

 

I think the only exception I've never been called out on is dish soap in a office breakroom.  This breakroom was only used by office staff, not production employees, and was pretty far removed from the production area and the auditor didn't care there was a bottle of Dawn under the sink.  But in my production breakrooms, I've always called for employee dish soap to be kept in a mounted dispenser to make sure an employee can't walk off with it and carry it into production.

 

 

Edit to add:  Remembered another exception I was granted:  An auditor gave me a break once finding a bottle of Jack Daniels in the owner's office, which had a sink designated as the employee's dishwashing sink.  This was a very small operation, one full time employee and a bunch of owners running the business from those offices.  And...well... they were good ol' boys and it took me quite awhile to explain why I didn't think adding whiskey to our approved chemical list was something our auditor would want to see.  

Edited by jfrey123, 15 September 2022 - 08:32 PM.

[AJL]

It does seem rather extreme.
I understand all of the points, I really do.
I'm wondering if there is a difference to how this is audited in Europe vs. america for example because I have been to certified sites here that have for example a lab which is not locked, and leads out to production, and a huge chemical supply cupboard (not locked).
Interesting the idea about a manual dispenser for dish soap.
I can see that we need to possibly improve in some areas.
Should be noted that we are a small team and therefore food defence looking at internal threats is just the most strange and uncomfortable thing.
The team is awesome.

[Charles.C]

Also don't forget that ''Food Grade'' does not mean that it is edible!

Food grade usually refers to ok for incidental food contact. 

 

You also want to lock up your chemicals to prevent tampering (e.g. food defense).

Hi Marloes,

 

The topic of the meaning of  "Food Grade" is complicated. In many cases "Food-safe" is probably a more useful interpretation for non-food items.

 

FDA offers -

 

Food grade means that the material is either safe for human consumption or it is okay to come into direct contact with food products.

https://www.ifsqn.co...ns/#entry185047
("okay" is obviously subjective)

 

Various Industries/Standards have borrowed/interpreted "food grade" for their own contexts, eg via subjective terms like "incidental contact"

[AJL]

Thanks everyone, we have been going through it all today and doing a bit of a clean up 👍
Trying to work out how to make it practical and compliant

Edited by AJL, 16 September 2022 - 12:58 PM.

[Charles.C]

It does seem rather extreme.
I understand all of the points, I really do.
I'm wondering if there is a difference to how this is audited in Europe vs. america for example because I have been to certified sites here that have for example a lab which is not locked, and leads out to production, and a huge chemical supply cupboard (not locked).
Interesting the idea about a manual dispenser for dish soap.
I can see that we need to possibly improve in some areas.
Should be noted that we are a small team and therefore food defence looking at internal threats is just the most strange and uncomfortable thing.
The team is awesome.

 

 

Thanks everyone, we have been going through it all today and doing a bit of a clean up
Trying to work out how to make it practical and compliant

Hi AJL,

 

Auditing can be a tough job IMO since IMEX, large amounts of subjectivity are required across many activities  I also daresay that like in most Work Functions there are varying levels of Auditor "Competence/Strictness" which may generate inconsistences. A Global phenomenon IMO.

 

Regarding geographic differences you are likely (partially) correct in respect to Regulations, Standards and Auditing. Two well-defined examples  are (a) USA's sensitivity towards Listeria which has (not unreasonably) been dictated by specific Local incidents plus (b) SQF's abrupt revision of their Standard's content regarding HACCP Validation and their Audit Guidelines particularly due non-Uniform Auditee experiences.

 

I also get the impression that conversion of old, previously non-food production facilities for food use is more common in USA. This kind of approach may force building compromises which eventually become significant for auditors

 

.

[AJL]

Thanks Charles, I suspect that there is a little more focus on food defence in the USA... Which would lead to increased focus on chemical control for this reason.Lock everything!

This focus area (chemical) we have had this week was anyway a good opportunity to go through all the cupboards and rid of us of any chemicals that weren't really necessary. 😉
Also a good chance to have a discussion with the Factory manager about interpretation of the standard and the reasons behind the various expectations.
We have put all the non-food grade lubricants in the maintenance workshop, which although is not locked- then we will describe this as restricted to authorised staff.
Otherwise all stores are locked. The only place we have cleaning chemicals unlocked is a room next to the production where we have chemicalS we use for CIP- not locked. This is just 2-3 containers that are open during cleaning.
We have been through 2 internal audits with this system, while one auditor commented, the other bad absolutely no issue.
If I read the standard again
-access restricted to authorised personnel -
Well here I would argue that all staff are 'authorized' to access them as they are all trained in cleaning procedures.
It would be impractical to lock these, as they are used frequently and it would really just be something to please an auditor than a reality.
The whole thing as well with food defence and chemical sabotage - of course I recognize that it happens but it just seems so far fetched, to even consider this when we have such a small dedicated team.

Long term I guess the system will be automated which will remove this issue.

I guess it will always be a work in progress 😉
Continuous improvement.

Edited by AJL, 16 September 2022 - 06:43 PM.

[Charles.C]

Thanks Charles, I suspect that there is a little more focus on food defence in the USA... Which would lead to increased focus on chemical control for this reason.Lock everything!

This focus area (chemical) we have had this week was anyway a good opportunity to go through all the cupboards and rid of us of any chemicals that weren't really necessary.
Also a good chance to have a discussion with the Factory manager about interpretation of the standard and the reasons behind the various expectations.
We have put all the non-food grade lubricants in the maintenance workshop, which although is not locked- then we will describe this as restricted to authorised staff.
Otherwise all stores are locked. The only place we have cleaning chemicals unlocked is a room next to the production where we have chemicalS we use for CIP- not locked. This is just 2-3 containers that are open during cleaning.
We have been through 2 internal audits with this system, while one auditor commented, the other bad absolutely no issue.
If I read the standard again
-access restricted to authorised personnel -
Well here I would argue that all staff are 'authorized' to access them as they are all trained in cleaning procedures.
It would be impractical to lock these, as they are used frequently and it would really just be something to please an auditor than a reality.
The whole thing as well with food defence and chemical sabotage - of course I recognize that it happens but it just seems so far fetched, to even consider this when we have such a small dedicated team.

Long term I guess the system will be automated which will remove this issue.

I guess it will always be a work in progress
Continuous improvement.

Hi AJL,

 

^^^ (red) IMEX this may not work. An auditor may interpret "authorised" as requiring a specific , full-time, "storekeeper" which we anyway chose to do for safety/insurance reasons. Plus there is also a question of (a) documenting inputs/outputs and (b) human errors which IMEX are not readily controllable on a random basis. (Worst mishap was confusion over similarly coloured food coloring solution and detergent mixture !)

 

My experience with separating lubricants is similar to yours except non-locking rapidly guaranteed unidentified "borrowing". Furthermore locking minimises the likelihood of inadvertent (or advertent !) contamination.

 

PS - I have one reservation over yr lubricant storage. "Food Grade" designations (eg see quote below) can be confusing and sometimes controversial (eg meaning of "incidental contact"). I suggest it is preferable to avoid comments by separating all Engineering-oriented Chemicals from Process-Related items. The former can be additionally sub-divided via, for example, H1 and non-H1 designated materials.
 

 

Food-grade or food-safe lubricant is the name given to any industrial lubricant that is considered safe for incidental contact with items that may be consumed by humans or animals, as long as it does not exceed a certain concentration

https://interflon.co...grade-lubricant

 

PPS - Offhand, IMEX, Chemicals are approx. stored/separated via (1) Edibility, (2) Food Grade/Food Safe (3) Engg.H1, (4) Engg.Non-H1, (5) "OTHER". "Other" can be, and IMEX often is, considerable due factors such as bulk, inflammability, toxicity, explodability, spoilability, Location of Usage.

Edited by Charles.C, 18 September 2022 - 07:39 AM.
added PS, PPS

[AJL]

Hi Charles, yes well technically we are up to:
A locked chemical Storage Cage for cleaning chemicals
H1: A locked cupboard in a packaging storage area, for 'incidental food contact'
H2: An unlocked (restricted) area for lubricants etc used for maintenance purposes, non food grade
A locked cupboard with ink solvents etc.
You are telling me we need another cupboard 🙈
The maintenance area is very separate to the production area. I am torn being wanting to do everything possible to ensure we don't get a NC, and leaving things how they are to see how the auditor assesses it.
We haven't had a BRC audit before, just an internal audit against all standards.
The only thing that was really named was that the lubricants were not clearly marked as food grade/non food grade.

[Charles.C]

Hi Charles, yes well technically we are up to:
A locked chemical Storage Cage for cleaning chemicals
H1: A locked cupboard in a packaging storage area, for 'incidental food contact'
H2: An unlocked (restricted) area for lubricants etc used for maintenance purposes, non food grade
A locked cupboard with ink solvents etc.
You are telling me we need another cupboard
The maintenance area is very separate to the production area. I am torn being wanting to do everything possible to ensure we don't get a NC, and leaving things how they are to see how the auditor assesses it.
We haven't had a BRC audit before, just an internal audit against all standards.
The only thing that was really named was that the lubricants were not clearly marked as food grade/non food grade.

Hi AJL,

 

i recommend you to invest in a trial BRC audit. It substantially opened our eyes as to what was likely forthcoming.

 

The intensity of the audit is logically also related to how BRC pre-assess the Risk Level of your Products/Process, etc, ie Audit Scope.

[AJL]

Thanks Charles, back in February we were assessed against all sections of the standard with a score of 79,9%. We were happy with it, considering we had started serious preparations in October the year before - re writing the HACCP plans, and building a quality system.

I have lost count of the amount of doument and forms and SOPs I have created - it is something like 130!

 

So we have had a 'mock' audit - 2 days of intensive questioning. None of our chemical storage was questioned to the same extent it was in out recent intern audit! But with intern audits there is also the opportunity to go in a little more detail right!

Appreciate all the good points you have come with. I am dreading and looking forward to the audit all at once

You can be sure I will be coming with more questions and conundrums this next month leading up to the audit. This forum has been a very helpful source of guidance. 

[Charles.C]

Thanks Charles, back in February we were assessed against all sections of the standard with a score of 79,9%. We were happy with it, considering we had started serious preparations in October the year before - re writing the HACCP plans, and building a quality system.

I have lost count of the amount of doument and forms and SOPs I have created - it is something like 130!

 

So we have had a 'mock' audit - 2 days of intensive questioning. None of our chemical storage was questioned to the same extent it was in out recent intern audit! But with intern audits there is also the opportunity to go in a little more detail right!

Appreciate all the good points you have come with. I am dreading and looking forward to the audit all at once

You can be sure I will be coming with more questions and conundrums this next month leading up to the audit. This forum has been a very helpful source of guidance. 

Hi AJL,

 

79.9% "sounds" encouraging but, as you know, with BRC it's ultimately also about Ma/Mi etc.

Don't forget that as a new, potentially long-term customer, you also have some initial leverage. This may equate to some "benefits of the doubt".

Good Luck !