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How were you able to satisfy module 11, Lighting and light fittings 11.1.3

Started by , Oct 10 2022 02:59 PM
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Was wondering what documentation is needed to satisfy this requirement for module 11. Any examples would be greatly appreciated.

Thank you

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We just have it written in our policy that the light is appropriate for the task.  Light fixtures are maintained and are shatterproof. 
That satisfied our SQF auditor a couple weeks ago.

We don't have anything documented per se on this.  Just have documentation showing our bulbs are shatterproof.  Other than that the auditor will just look at you lights and as long as they are compliant, that will satisfy this.

you can also think about adding them to your glass and brittle plastic inspection-----even though they are neither of those things.........perhaps you only inspect them quarterly-----then you can demonstrate they are performing as expected

For 11.1.3.1, I think in the past I included mentioning sufficient light brightness in our sanitary design documents.  Essentially you just want any work area bright enough for employees to see what they're doing (for processing and sanitation).  If you've got a doubt as to whether an auditor thinks a spot in your processing area is too dark, get some lights added.

 

11.1.3.2 is simple with shatterproof lenses, or protective tubes on fluorescent bulbs.  You can get actual bulbs that are shatterproof, but I didn't like that option due to added costs, plus having an auditor tell me he would request to be manlifted up to the fixture to verify the bulb was what I told him it was.  Worth noting that even if the bulbs are covered with a shatterproof tube, there's often a clear cover on the fixture that must be shatterproof too.  I couldn't get documentation on some old dated fixtures, so I covered the flat panels in a clear contact plastic with a sticker imbedded under it to prove it was there.  And yes, my auditor made me lift him up so he could verify the plastic film was on the glass.

 

11.1.3.3 for storage areas, we just maintained a policy that product was never to be opened or sampled in our storage areas.  In conjunction with the broken glass cleanup procedures, it was always found sufficient.  We were never required to do any of the shatterproofing in storage areas thanks to these policies.

Just recently had SQF audit and received an NC for 11.1.3.1 . The auditor was looking for objective evidence that our lighting met 'local or regulatory standards'. He thought one area was 'too dark' and we had no equipment to test it.  We use OSHA guidance for lighting requirements but received NC for not having objective evidence light met that requirements so it really depends on your auditor and what they see. Super easy to correct at our facility but I suggest having your team invest in light meter and ensuring you have an objective way to test to compliance.

Was wondering what documentation is needed to satisfy this requirement for module 11. Any examples would be greatly appreciated.

Thank you

 

Hi 2xmahi,

 

For Light fixtures, as with most GMPS, I document company standards (that as a minimum meet those of the SQF Food Safety Code Section 11.1.3) and ensure compliance with these standards. You should ensure that all departments are aware of company standards, including your maintenance department. The light fixtures should be checked during internal audits/inspections.

 

In addition, light fixtures should be on a glass/brittle material register and checked at a frequency based on risk.

 

Also, note SQF Previous Implementation Guidance:

 

Adequate light intensity is required for processing operations, cleaning and inspection tasks. However, the design and construction of lighting can pose a risk to product due to breakage or dust accumulation.

Lighting shall provide minimum lux (foot candle) intensity as prescribed by applicable legislation or in their absence, meet good manufacturing best practices appropriate to the commodity being processed. In general, processing and food handling areas are illuminated to a minimum intensity of 200 lux (18.58 ft.c.). Inspection areas require higher illumination; 500 lux (46.45 ft.c.) is generally recommended.

 

Kind regards,

 

Tony

We have them on our monthly glass and plastic audit and and they are also included in the brittle material section on our pre/mid op inspections.

Semi annually we check the light intensity in the plant with our luminometer to ensure that the lighting meets or exceeds the requirements.


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