13 replies to this topic

[keeli]

Hello,

New here, but have read a lot of posts and comments about having a glass/brittle plastic/wood register.

I work at a flavor and extract company and we hold some of our products and chemicals in amber glass containers located in the production area.  They are all contained in one area as a zone where you can have glass.  Is it necessary to still have a register?

 

Right now, glass that is outside of this zone is visually inspected monthly during our internal auditing by both FSM/ SQF Specialist as well as production manager.   

Anything inside that zone is not inspected or documented.  Unless something breaks, we don't have any documentation of anything. 

 

I should also note here that we are certified through AIB and have never had a register and have never been sited for not having this.

 

Thanks in advance for any and all advice!

Edited by keeli, 28 February 2024 - 05:14 PM.

[jay2023]

I would have at least a record of checks on the containers, for example each time they are used or start and end of shift- backed up by risk assessment as they are one of the things that are likely to break

[jay2023]

Best option would be to exclude glass- could they be supplied in a different type of container like plastic?

[keeli]

jay2023-  Because they are chemicals it is best they are stored in glass as to not erode other material and cause issues to quality and food safety of the product(s) itself.  

 

We do a Preop inspection in the am and afternoon.  but only for those glass items that are not located in the approved glass zone.  so anything in the approved glass zone, it is visually checked as an overall... not as to each individual item.

Edited by keeli, 28 February 2024 - 06:49 PM.

[jfrey123]

Most of the time, I write SOP’s to do a monthly glass/bp check with daily pre-op forms capturing checks of anything close to production (equipment dials, buttons, etc).

Never had to track glass in a sense like this, but I think a log in this area of yours showing a daily start of the total number of bottles and ending count, with verification that none broke that day, should be sufficient. Lets you record when some bottles are taken out or added, as your inventory flows.

[Dorothy87]

Hi :) 

 

some options ; 

 

- add list of bottles to daily start up check (usually by the risk assessment glass should be checked daily - this can be challenged, for example how far they are located from food contact or how many incidents you had last year) 

- replace with amber / brown hard plastic bottles (best idea, then you can decrease risk from daily checks to monthly / quarterly) 

 

 

[keeli]

Hi Dorothy87,

So because our products are very strong and are really chemicals, putting into plastic might degrade the quality and potentially the food safety of the product/material.

 

Right now... glass is stationary in one location.  When production workers are compounding those glass jars come across into the main production floor to the compounders table in order to compound a flavor or extract.  We do visual checks in the AM and PM.  These are only documented as yes nothing is broken.  Not on an individual basis.  So where they stand.. risk is probably medium to low.  But when they are taken of the shelves they become high risk.

 

I think my main struggle is if, per SQF I need to have a registry or if it will lead to a non compliance.

 

Thanks for your ideas!  

Edited by keeli, 29 February 2024 - 08:55 PM.

[jfrey123]

You mentioned SQF specialist, but said you're certified under ARB, so not sure exactly which standard we should consider.  But from the SQF standpoint:

 

11.7.3.2 Containers, equipment, and other utensils made of glass, porcelain, ceramics, laboratory glassware, or other similar materials shall not be permitted in food processing /contact zones (except where the product is contained in packaging made from these materials, or measurement instruments with glass dial covers are used, or MIG thermometers are required under regulation). Where glass objects or similar material are required in food handling/contact zones, they shall be listed in a glass inventory, including details of their location and condition.

 

Based on that, I could suggest you label and number each glass container for a daily inspection.  Each one needs should be verified as intact and not broken, and a daily log checking them would be great in a SQF auditor's mind.  When one is cracked, you record it on the log and whatever glass breakage incident form you have, show it got replaced with a new one relabeled to the correct number after knowing there is no hazard from the breakage.

 

And honestly, this is one of those logs auditors love to see findings on:  say a glass broke in November 2023, and you show them a investigation that the glass was only cracked and didn't post a hazard, so you discarded it and placed a new jar to take it's place.  Auditors love internal findings that are well documented.  They hate reviewing records that show 0 problems through the whole year.  So while it'll be a pain to document glass checks for these inventoried bottles, if/when something happens, they'll love to see that you handled it thoroughly and it'll give them confidence your FM program is operating well.

[Dorothy87]

Hi Dorothy87,

So because our products are very strong and are really chemicals, putting into plastic might degrade the quality and potentially the food safety of the product/material.

 

Right now... glass is stationary in one location.  When production workers are compounding those glass jars come across into the main production floor to the compounders table in order to compound a flavor or extract.  We do visual checks in the AM and PM.  These are only documented as yes nothing is broken.  Not on an individual basis.  So where they stand.. risk is probably medium to low.  But when they are taken of the shelves they become high risk.

 

I think my main struggle is if, per SQF I need to have a registry or if it will lead to a non compliance.

 

Thanks for your ideas!  

 

 

I would suggest - Daily start up checks, plus glass breakage procedure & register and staff training. I believe you will be fully covered. 

[keeli]

Thank you everyone!

I appreciate your help!

[keeli]

You mentioned SQF specialist, but said you're certified under ARB, so not sure exactly which standard we should consider.  But from the SQF standpoint:

 

11.7.3.2 Containers, equipment, and other utensils made of glass, porcelain, ceramics, laboratory glassware, or other similar materials shall not be permitted in food processing /contact zones (except where the product is contained in packaging made from these materials, or measurement instruments with glass dial covers are used, or MIG thermometers are required under regulation). Where glass objects or similar material are required in food handling/contact zones, they shall be listed in a glass inventory, including details of their location and condition.

 

Based on that, I could suggest you label and number each glass container for a daily inspection.  Each one needs should be verified as intact and not broken, and a daily log checking them would be great in a SQF auditor's mind.  When one is cracked, you record it on the log and whatever glass breakage incident form you have, show it got replaced with a new one relabeled to the correct number after knowing there is no hazard from the breakage.

 

And honestly, this is one of those logs auditors love to see findings on:  say a glass broke in November 2023, and you show them a investigation that the glass was only cracked and didn't post a hazard, so you discarded it and placed a new jar to take it's place.  Auditors love internal findings that are well documented.  They hate reviewing records that show 0 problems through the whole year.  So while it'll be a pain to document glass checks for these inventoried bottles, if/when something happens, they'll love to see that you handled it thoroughly and it'll give them confidence your FM program is operating well.

 

So.. after speaking with our production manager, we haven't had any reported broken glass in 2023 at all... So in this case, I would just have to validate that what we're already doing works?   Or it would still be best to still add the register and just validate that what we're doing works. 

[jfrey123]

So.. after speaking with our production manager, we haven't had any reported broken glass in 2023 at all... So in this case, I would just have to validate that what we're already doing works?   Or it would still be best to still add the register and just validate that what we're doing works. 

 

You could take a look at your company's prior AIB audits to see if the auditors have made notes regarding your current practices.  It was unclear to me earlier whether you were going for the SQF or AIB standard.  I'm not familiar with AIB, so can't say for sure whether those glasswares need to be on a register, but I think SQF would make you label them.  My experience in SQF would have me labeling all of those glasswares into their own register, with a log for daily inspections and a log for sanitation of each one as it occurs.

 

You can hold up your evidence that glass hasn't broken, but auditors are quick to point out lack of something happening doesn't mitigate the risk that it could happen.  If you code calls for glass to be registered, I'd establish a register.  But if your prior audits have been passed in this area with just a breakage report, I'd have a hard time justifying telling you a register needs to be created.

[keeli]

You could take a look at your company's prior AIB audits to see if the auditors have made notes regarding your current practices.  It was unclear to me earlier whether you were going for the SQF or AIB standard.  I'm not familiar with AIB, so can't say for sure whether those glasswares need to be on a register, but I think SQF would make you label them.  My experience in SQF would have me labeling all of those glasswares into their own register, with a log for daily inspections and a log for sanitation of each one as it occurs.

 

You can hold up your evidence that glass hasn't broken, but auditors are quick to point out lack of something happening doesn't mitigate the risk that it could happen.  If you code calls for glass to be registered, I'd establish a register.  But if your prior audits have been passed in this area with just a breakage report, I'd have a hard time justifying telling you a register needs to be created.

 

Always going for SQF, AIB is just our certification body vs FCID, etc.

Yea I think we are rethinking a few things! 

 

Thank you and everyone else for helping me through this!

[MOHAMMED ZAMEERUDDIN]

Register or record is a must.