Drinking Water in Food Plant in clear bottle poses a safety risk in my facility

So, basically, I don't agree with this rule. My establishment is a very very hot bakery. During the summer months, I like to let the staff drink gatorade, powerade, etc. to keep them from becoming dehydrated. Not to mention, a clear container poses a risk if it happens to break... Finding something clear, as opposed to a colored container, would be very difficult.

Is there any way I can bypass this rule? Can I supply the auditor with my 'risk analysis' and reasoning as to why I don't want to permit only water in clear containers?

11.4.1.2 Personnel working in or visiting food handling or processing operations shall ensure that: 

Drinking water is permissible only under conditions that prevent contamination or other food safety risks from occurring. Drinking water containers in production and storage areas shall be stored in clear, covered containers, and in designated areas away from raw materials, packaging, tools, or equipment storage

you cannot over rule the water only rule

A) you cannot then control allergens

B) it's a very slippery slope (next comes vodka and oj)

You can try, but I doubt you'll be successful 

If you want to offer gatorade etc. perhaps more frequent breaks where it's provided by the company in the lunchroom

off topic, but not: How does one pose an argument to SQF for some of their 'rules'? It seems like many rules are created by these third-party lab companies to force you to use their services.. aka trace analytics and compressed air testing.. oh capitalism

off topic, but not: How does one pose an argument to SQF for some of their 'rules'? It seems like many rules are created by these third-party lab companies to force you to use their services.. aka trace analytics and compressed air testing.. oh capitalism

Ive often wondered how much money was/is made on the SQF practitioner class.   I got around third party air testing.   

If you want to offer gatorade etc. perhaps more frequent breaks where it's provided by the company in the lunchroom

This is what we did at a plant that was not climate controlled and used steam for extracting essence. Mid-August it would be 120F in the production areas. Everyone had permission to go sit down and drink cold water  in the break room whenever they needed it as long as there were employees on the floor to monitor their station.  

on your off topic convo-----------i don't necessarily agree with them pushing 3rd party labs (I've done that testing way before GFSI)  but I agree 100% that it is essentially a racket

Recall/withdrawl rates have not changed since these schemes were started and aren't likely to any time soon

When shady companies hire inexperienced staff on purpose because they can push them around--bad decisions are made and the public bears the consequence and there is zero GFSI is capable of doing to change that

CFIA has added a 3rd party audit as part of their risk assessment model-------------who's auditing the auditors?  One of our locations is getting a new auditor this year----I'm supposed to believe that they have years of experience in every sector?  This particular auditor is certified for all categories---that isn't supposed to happen---neither is an auditor asking for records by name

Lastly, the retail industry started these schemes--------because they didn't want to lose money--------they get reimbursed for ALL withdrawl/recall returns they take so I'm confused where they think they are losing money

Walmart didn't get that big by losing money  (end rant)

on your off topic convo-----------i don't necessarily agree with them pushing 3rd party labs (I've done that testing way before GFSI)  but I agree 100% that it is essentially a racket

 

Recall/withdrawl rates have not changed since these schemes were started and aren't likely to any time soon

 

When shady companies hire inexperienced staff on purpose because they can push them around--bad decisions are made and the public bears the consequence and there is zero GFSI is capable of doing to change that

 

CFIA has added a 3rd party audit as part of their risk assessment model-------------who's auditing the auditors?  One of our locations is getting a new auditor this year----I'm supposed to believe that they have years of experience in every sector?  This particular auditor is certified for all categories---that isn't supposed to happen---neither is an auditor asking for records by name

 

Lastly, the retail industry started these schemes--------because they didn't want to lose money--------they get reimbursed for ALL withdrawl/recall returns they take so I'm confused where they think they are losing money

 

Walmart didn't get that big by losing money  (end rant)

These are the topics I would love to discuss. Where can we get a thread of rants going!? LOL 

I would love to hear the entire industry's honest view on these GFSI schemes and the like. We are the ones who implement them, so we should be the ones to control and change them.

So much to be said on these off topic conversations...lol.  Don't even get me started how different auditing bodies and auditors audit differently.  We had a great auditor this year that when we reviewed the findings from last year, stated that two of them we should not have got hit for as we were in compliance.  

I have questioned some of the rules as well if it was made to make us utilize some labs services...

The inclusion of water containers for production staff in SQF 9.0 was a welcome change.  We got stuck between a rock and a hard place in my old spice manufacturing plant.  Production area would get really and we couldn't allow water bottles (though we did encourage people to visit the break room to get water/drink as needed).  An employee brought an OSHA complaint against us, and OSHA demanded we allow employees to carry water bottles on production lines.  We cited the SQF Code we operate under as well as FDA GMP's prohibiting personal items in production areas; OSHA ignored our response and threatened penalties if we didn't comply, they claimed that the breakroom was too far for employees to have regular access to water in hot temperatures.  The fix for us at that time was to install a drinking fountain in the production area, adding it to our master sanitation schedule and the environmental monitoring program to keep SQF happy with the reality it had to be there.

I doubt you can get around the clear container requirement or the water only requirement for the reasons cited above by others.  If SQF only wants water in clear containers, you'll have a hard time getting around that if an auditor spots dark colored liquid in non-clear unlabeled containers.

So much to be said on these off topic conversations...lol.  Don't even get me started how different auditing bodies and auditors audit differently.  We had a great auditor this year that when we reviewed the findings from last year, stated that two of them we should not have got hit for as we were in compliance.  

 

I have questioned some of the rules as well if it was made to make us utilize some labs services...

I would also like to know what happened to "get GFSI certified and you won't get customer audits anymore." We still have multiple customer audits each year. Also, if I am GFSI certified why am I answering questions on a 6 page form all of which are evidenced by my certification?

I would also like to know what happened to "get GFSI certified and you won't get customer audits anymore." We still have multiple customer audits each year. Also, if I am GFSI certified why am I answering questions on a 6 page form all of which are evidenced by my certification?

EXACTLY!!!! I'm preparing for a customer audit right now. Does my GFSI certification mean nothing!???? That's the entire point of it!

Currently working on implementing company issued water bottles, in designated areas.  Our EHS department wants water in production areas during the warm months (and I don't fully disagree), we have a dry processing environment, over 95% completely enclosed process, 4 floors, with no A/C.  They requested coolers out in production but we have run into issues with the insulated coolers in the past.  (Even in outdoor area, the small drops that hit the floor then attract flies). 

So we found clear, non-breakable, hands-free water bottles with the company logo on them.

We plan to allow these in a few designated areas with water only.  Each employee will be issued one bottle every spring and can purchase a new one if they lose it.

The water bottles were not cheap (considering what it is), but if it improves employee working conditions it will be worth it.  

And on the 'off topic'....I would love to vent frustration over GFSI auditors and the amount of customer audits we still have to endure.

EXACTLY!!!! I'm preparing for a customer audit right now. Does my GFSI certification mean nothing!???? That's the entire point of it!

Necroing to agree with this whole-heartedly! I've even had a few auditors (both customers and GFSI) push back on my accepting GFSI certification from my suppliers in lieu of doing extensive questionnaires, site audits, etc. Ostensibly they're the ones who are most qualified to do a site audit; what purpose does my little self serve presuming to do the same?

Re: water breaks, also make sure you're keeping an eye on new heat guidelines. I think at least one state has new guidelines based off heat index that mandate breaks at a specified frequency, and eventually the feds will get their business figured out and do the same, albeit perhaps at the heat death of the universe.