6 replies to this topic

[Parkz58]

Greetings everyone,

 

I'm in a new role at a new food and beverage facility, and we have an upcoming customer audit that is being facilitated by AIB auditors.

 

We've noted a few places in our plant where we have motors, gear boxes, and similar parts/pieces that are:

 

- NOT in/on/directly over food contact surfaces

- starting to corrode, rust, and/or the paint is starting to slough away and/or peel

 

We have them on our radar, and intend to deal with them...but with limited time, resources and manpower, we're simply not going to be able to handle them all prior to the audit.

 

We're looking at writing an Executive Letter to have on file, stating that we have awareness of these issues, and that we have a 3-step approach to these things:

1. Ideally, and whenever possible and economically feasible, parts will be replaced with stainless steel parts.
2. When replacement is not feasible, corrosion and/or rust are to be controlled by scraping or brushing as appropriate and effective to maintain food safety.  Painting may or may not be utilized as a corrosion inhibitor, depending upon the situation.
3. To ensure paint condition, corrosion and/or rust are noted and addressed in a timely manner, Berner shall utilize the pre-op inspection to check for rust or paint that needs removal.   If such conditions are found, the issue(s) shall be escalated to Maintenance so that a work order may be issued.  If no adverse conditions are found at pre-op inspection, this confirms that the equipment is not at risk of being a foreign material at the time of inspection.

Is this going to be sufficient enough to satiate the auditor?

 

If not, what do you all recommend?

 

Beyond the audit itself, what recommendations do you have for long-term treatment of such items...or is it literally going to require replacing everything with stainless steel?  Painting seems to be a sore subject here...they've obviously struggled with finding the right kind of paint, or the right application, and instead have seen poor paint performance and longevity (as I've seen in other food plants, too).

 

Great to be back on IFSQN after quite a long hiatus (previous position afforded me nearly no time for it)...hoping to be a regular, active participant again!

 

Parkz

[SQFconsultant]

Great to see you again!

 

I like everything except for #1.

 

I'd be putting some doable dates in there because whenever ain't gonna cut it with most Auditors.

[Lynx42]

As long as it's on a work order and you have documentation of it, it shouldn't be a finding unless it's a actively a risk to food.

 

We had a similar issue and knew an unannounced AIB audit was coming, so we emailed for a quote, and was able to provide another email showing we were waiting for parts and it saved us a major finding.  She bypassed some other stuff, I think she assumed it was part of the work order, so we got lucky there and made sure to get another quote so it could all get fixed before our next audit.

[ChristinaK]

I would either change or eliminate #1 from the list. Maybe add it last, stating that if 2 & 3 cannot prevent the rust issue from recurring, that the food safety team (which should include someone from maintenance) will meet to determine if there is a better material available, such as stainless steel, or if a unique solution is needed (example: some kind of barrier or cover to prevent rust or flaking paint from migration).

 

Also, to build on what Lynx said, you may want to include a statement that any rust/corrosion that poses a risk to food safety will be immediately remedied, with how the effected equipment will be covered and/or isolated to prevent possible contamination. 

 

Is rust/corrosion/flaking remediation included in your maintenance policy/program? If not, you may want to do so.

[Botanist333]

We received a minor non-conformance for some peeling paint on the underside of a staircase. It wasn't in a production area but was in a position where ambient temperature non-exposed ingredients were stored beneath. We removed the ingredients, sanded and repainted. Our daily operational inspection was revised to include "Ingredients and finished goods are properly stored and protected with no risk of contamination from peeling paint when stored near or below painted surfaces." This was accepted by the SQF non-conformance reviewer.

[GMO]

I'm sure I'm too late but unless we're talking 100s of items here, I'd have got the loose stuff scraped off before the visit.  Then put a plan in place for monitoring and replacement.  

But a manager who shall remain nameless... ok, it was me, once repainted a piece of equipment in silver hammerite rather than white.  It didn't half hide the flaking paint till we had the chance to fix it. 

[GMO]

We received a minor non-conformance for some peeling paint on the underside of a staircase. It wasn't in a production area but was in a position where ambient temperature non-exposed ingredients were stored beneath. We removed the ingredients, sanded and repainted. Our daily operational inspection was revised to include "Ingredients and finished goods are properly stored and protected with no risk of contamination from peeling paint when stored near or below painted surfaces." This was accepted by the SQF non-conformance reviewer.

 

Just for info, storing combustible items under stairwells is a known health and safety fire risk.  Why they're not always blocked off I have no idea.  Not sure if your items are flammable or combustible but if they are, I'd move them anyway.  I'd never thought about it till I started to pick up some EHS responsibility and training.