16 replies to this topic

[2xmahi]

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

Thank you

[Miss Frankie]

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.

[Scotty_SQF]

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.

[Scampi]

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

[jfrey123]

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.

[lamyrick]

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.

[Tony-C]

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

[GreyeagleA]

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.

[Dustie0592]

Good Afternoon, how often is everyone performing lumen testing or light intensity? We do twice a year but I did not see anywhere that specified a frequency. 

[TimG]

I absolutely do not do lumen testing. This has been a bit of a sticking point for me in the past with a whole ONE customer auditor (and I'm still hot over it).

I do, however, have a line on our internal GMP inspections to verify light is adequate for jobs being performed in that area, and that no bulbs are inop. I have had an internal GMP auditor (manager) mark something like 'could use more light in this area', and we installed more light in that area. Same thing with bulbs, we note them on the monthly GMP audit, and we replace them if out. 

I've never had SQF (or AIB, or OSHA) tell me that I needed to test for lumens.

[MDaleDDF]

I'd ask the auditor to show me in the standard where it says I have to do lumen testing.   Until then, I'd pass on doing it.   There's plenty of work in the standards list, I'm not interested in adding to it.

However, I don't have customer audits like you guys are talking about, not that would care about that anyway.   I have let one customer in for a very limited audit in the last 20 years, and he just wanted to see paperwork mostly, light plant inspection.    Took an hour or two total.   

Who asks about lumens?   Costco or somebody like that?

[Scampi]

I test lux once/year

 

CFIA does have certain conditions where a lux level is prescribed

https://inspection.c...ntrols/lighting

[G M]

...

Who asks about lumens?   Costco or somebody like that?

 

None that I've seen.  They just use subjective "enough to get the job done" descriptions.  

 

This falls into the category of things I would deliberately avoid setting a value for, because if the programs contain a value the inspectors or auditors are going to want to see you recording verifications and validations for it.

[tadelong]

As with Scampi, I also do lux testing. It's probably the Canadian thing. The first time we had an electrician bring his equipment and sign off on the levels. I used a phone app after that. That was fine for a few years until our auditor came one year with an axe to grind. Found every dark corner in the place, and we ended up spending thousands installing new lights. I found it uncomfortably bright for a year until I got used to it.

Fun fact, the CFIA mentions egg grading stations specifically so I had very little wiggle room.

"540 lux (50.2 foot candles) in inspection areas such as the egg grading station"

[MDaleDDF]

Ah, Canada thing.   Yeah, we don't have that here.    YET!   Lol.

[Dustie0592]

Our NSF (SQF) Auditor asked in 2023. "Did you know that you are to ensure that your light intensity is sufficient in each area of your plant?, he said that is always an easy non-conformance that he could note." I responded that I had read the section but it does not state how or at what frequency to ensure that your light intensity shall comply with the regulations or industry standard. He explained it was up to the site to decide how to test and what frequency, but gave examples that other facilities that he had been in and how they satisfied the requirement.

 

Thank you all for the responses. Since that audit in 2023, we perform lumen testing in each area twice a year. I am really interested to learn about other facilities processes. Our Costco audit has not asked me about light intensity or lumen testing yet. 

 

11.1.3 Lighting and Light Fittings 11.1.3.1 Lighting in food processing and handling areas and at inspection stations shall be of appropriate intensity to enable the staff to carry out their tasks efficiently and effectively and shall comply with local light-intensity regulations or industry standards.

Edited by Dustie0592, 26 February 2025 - 04:00 PM.

[jfrey123]

Thank you all for the responses. Since that audit in 2023, we perform lumen testing in each area twice a year. I am really interested to learn about other facilities processes. Our Costco audit has not asked me about light intensity or lumen testing yet. 

 

11.1.3 Lighting and Light Fittings 11.1.3.1 Lighting in food processing and handling areas and at inspection stations shall be of appropriate intensity to enable the staff to carry out their tasks efficiently and effectively and shall comply with local light-intensity regulations or industry standards.

 

I'm US based on a corp team that oversees QA for 10 facilities.  Our SQF auditors in these buildings have been writing "Lighting throughout the facility was sufficient for processing and handling activities. Lights were shatterproof and/or shielded, and were designed to prevent breakage." so I feel like we're getting by with their subjective judgement at the moment.  Maybe we're getting off easy.  I'll add that the internal GMP checks for the facility call out making sure lights are functioning so that likely helps.

 

I could not see myself wanting to spring for the testing equipment, plus routine calibration of said equipment, to check for intensity/lumen checks on once/twice per year frequency.  If we were forced to, I'd opt for creating a one time in-house study that maps the location and wattage of the current lights, maps various points where lumens were checked for sufficiency with regulatory standards (probably reference US OSHA here), and then state in SOP that lights must be functioning when inspected to ensure sufficient light exists.  If you can prove that lighting is sufficient when all the lights are on and functioning, redoing the lumen test over and over seems overly redundant.