9 replies to this topic

[Xoinks]

Hello all -

 

Just looking for thoughts.  Our compressed air isn't great right now (very new business, owner is awesome but learning the ropes of food safety/maintenance etc.) , and we won't have time to get the filtration, etc. on the main system fixed before the audit.  Filter that's on the main line has been replaced recently.   It's on the list of things to be addressed.

 

The good news is - we don't use the compressed air for anything other than pre-cleaning (which is documented) prior to full sanitation.  So anytime we use it on a food contact surface, it's then washed with a detergent (actually foamed and sanitized, verified with ATP).  Plus we are a low risk bakery product for further processing.  Our primary use for it is to run our machines (belts), with no chance of contact with food/food contact surfaces during production.

 

I made sure to document and train that we wash down after using for a pre-clean,- in your opinion, is this sufficient to meet the standard?

 

Or is it best to shoehorn in a POU filter? 

 

Thank you!

[Charles.C]

Hello all -

 

Just looking for thoughts.  Our compressed air isn't great right now (very new business, owner is awesome but learning the ropes of food safety/maintenance etc.) , and we won't have time to get the filtration, etc. on the main system fixed before the audit.  Filter that's on the main line has been replaced recently.   It's on the list of things to be addressed.

 

The good news is - we don't use the compressed air for anything other than pre-cleaning (which is documented) prior to full sanitation.  So anytime we use it on a food contact surface, it's then washed with a detergent (actually foamed and sanitized, verified with ATP).  Plus we are a low risk bakery product for further processing.  Our primary use for it is to run our machines (belts), with no chance of contact with food/food contact surfaces during production.

 

I made sure to document and train that we wash down after using for a pre-clean,- in your opinion, is this sufficient to meet the standard?

 

Or is it best to shoehorn in a POU filter? 

 

Thank you!

I deduce you are not implementing any kind of analysis of the air quality.

^^ (red) - So, based on various earlier SQF threads, most likely not.

Edited by Charles.C, 29 August 2023 - 03:20 PM.
added

[Xoinks]

Thank you Charles!  Back to the drawing board, then.  

[SQFconsultant]

Not having an air quality test is going to be a hotpot in the audit process - the filter is needed, but if you can not show a test and stop for same this will be an issue.

 

Fortunately you have enough time to get a test done.

[SQFconsultant]

Nothing like a bad auto correct for spelling.

[Scotty_SQF]

From experience, it is possible to get by without testing.  You have to prove that no compressed air is being used in the process and touching either food or food contact surfaces.  Risk assess and then type out based on the risk assessment why you are not testing the compressed air.  First year we tried this, the auditor walked the line asked some questions and agreed that we were not using compressed air.  From what you wrote I'd also suggest having something documented on unintentional use of the compressed air after cleaning and what your facility would do if this occurred.

[kingstudruler1]

If you can't get the filter installed or testing in place prior to the audit, I recommend the following.

 

1.  Have a risk assessment stating that everything compressed air touches receives a full sanitation. 

2.  Enter the lack of filter and air testing into your non - conformity log or internal audit, etc.   Its far better for you to acknowledge a possible nonconformance ahead of an audit.  

     a.   there are third party companies that will test compresses air.   There is at least one that is a sponsor of the site.   Alternatively, there are some items that you can use like the camtu or petrifilm for microorganisms if you have a micro lab.   and filter paper for oil and water.   

     b.   Have a completion date assigned in non-conformity log.  evidence purchase, quote for installation, etc. for the point of use filters.  supplies ordered or third-party agreement for testing.   

 

 

Because you are doing a full wash, there really isn't much risk.   However, rules are rules and you never know how an auditor will choose to apply them.   

[jfrey123]

I worked in a facility that used compressed air for machine operation only (reject gates, pneumatic lifts, etc), and because we didn't use air on the actual product or cleaning, we didn't filter at point of use or test the air.  It always drew the auditor's attention, but fundamentally didn't affect food safety so we were able to bypass that requirement.  Which was good, because the running joke among production staff was that our air hoses could fight fires due to the moisture build up in the lines.

 

Since you are using the air for cleaning a food contact surface, you'll need to implement point of use filters or sufficient filters above to prevent contamination.  That is my opinion based on SQF code's hard declaration that compressed air must be maintained and regularly monitored.  It's great that you clean and sanitize after using the air, but that step alone won't be enough to let them skip out of the hard requirement.

 

11.5.5 Air and Other Gases

11.5.5.1 Compressed air or other gases (e.g., nitrogen or carbon dioxide) that contact food or food contact surfaces shall be clean and present no risk to food safety.

11.5.5.2 Compressed air systems and systems used to store or dispense other gases that come into contact with food or food contact surfaces shall be maintained and regularly monitored for quality and applicable food safety hazards. The frequency of analysis shall be risk-based and at a minimum annually.

 

The other option I see is to evaluate whether you need to use compressed air to perform that pre-clean at all.  If you can write into your sanitation SOP that compressed air is never to be used on food contact surfaces, and that it's only used for tools or non-contact devices, you can bypass the requirements outlined in 11.5.5.  That was what we did at that former plant of mine, and production staff was trained that air is a risk that we aren't controlling, so when interviewed by auditors they knew to say air was never used for dry cleaning.

[Xoinks]

Thank you everyone for your valuable insight here!  I love these forums for this, thank you - I geek out over food safety, and I want to assure our resources are going towards  legitimate risks and of course adhering to the certification code we are voluntarily building towards.

 

Great thoughts from everyone.  I talked to our owner, and we are going to do some last minute PoU filters and I'll get them some air testing done on them.  I think we have a chance that we can risk assess out of it, I have something written up on it - but after some points here we are going to aim to not take the chance (especially with the point of accidental use)

 

I won't ask about compressed air micro standards - I've done some searches and found lots of great data in the forums already, including from some who replied here.   (Thanks for all of the work!)

 

First audit is always nerve wracking, I've been through the standard about 10x and just hoping I didn't overlook a hazard.  

[Xoinks]

Which was good, because the running joke among production staff was that our air hoses could fight fires due to the moisture build up in the lines.

 

 

   Just made my coworker look over when I snort-laughed.  Thanks for that!