How to Control Knives and Cutting Instruments Under SQF

SQF code:

11.7.3.8 Knives and cutting instruments used in processing and packaging operations shall be controlled, kept clean, and well maintained. Snap-off blades shall not be used in manufacturing or storage areas.

Any ideas on how I can 'control, keep clean, and keep maintained' without a captive knife program? Breakaway blades are banned; I'm covered there. Risk of a blade entering product for the 2 seconds between fill and capping would be low. Any blade stuck into an already sealed bottle is going to immediately leak.

Risk aside, code says what it says, and I want to meet the code. Has anyone successfully met the code with training, inspections of personal knives, etc.?

The SQF certified plant that I previously worked in had a knife check in and check out log.  By signing a knife in or out, the person was documenting that it had been inspected and cleaned.  Employees were also supposed to remove the blades from the knives and dispose of them in the sharps containers provided.  About the time I left hat company, they were switching to a fixed blade knife with a wearable sheath because the knives were set down in inappropriate locations including the pockets of personal clothing.  

Yeah, that's a captive knife program. It's a sure-fire way to meet the code when it's followed. I'm just kind of wondering if there are other ways. My gut says no, but that's why I ask people smarter than myself.

what if the supervisor signed them out/in?  The # in and out (that is the same) might suffice 

Hi Tim,

My questions would be why do you have knives in that area? and do you really need them?

Kind regards,

Tony 

Agree with Tony here.  If a captive knife programme is too much because the risk is low, why do you need them?  Are there alternatives?  

One option though is to literally chain them to the equipment (depending on risk etc on cleanability) but then you still need the ability and records of check they're intact.

Unfortunately in more than one location, I've had suspected malicious contamination into machinery / apparent low risk processes for knives.  I would just go with the captive knife thing.  If you don't think that's something your team will control well, they won't control more ad hoc checks either I'm afraid.

Spent the last couple weeks watching the line and they get used often, especially at the palletizing step. I won't get too deep into the weeds, but there is a captive knife program 'in place.' It's basically what you suggested, Scampi. I found it doing last year's SQF section reviews (just passed my first year at this facility). Doing this year's section reviews I wrote myself a NC on the section review because we're falling short of the 'do what you say.'

Kicking butt and having them do what is already in place to do is going to probably be what I end up deciding, but I wanted to see if anyone had any approaches I hadn't heard of to meet this section of the code.

What about asking the team?  Set it as a challenge, what the requirements are and why, how would they do it in a way that is demonstrable?  

Also it's probably a longer term project but also have you challenged why they need to be used?  A lot of palletising operations are now 100% automated and I can't think of a site where they've needed one in that step.  Get health and safety involved too to see if there are alternatives that wouldn't need a knife?

No health and safety here. I know, it's weird. I was so sick of corporate red tape that I wanted to try a small place (I think technically it's considered 'medium') and see how it goes. It has its benefits over global corporate environments, but it also has unique challenges...

Anyway, my plan is to hit the FSC with this tomorrow at our monthly meeting and give them an opportunity to think it over a bit, maybe one of them will surprise me with a good idea. I'll give them the code and what's required, here's what we SAY we do, here's the last record of us doing it. Meeting the code is non-negotiable, but if we can come up with a better way, I'm all for it.

Risk aside, code says what it says, and I want to meet the code. Has anyone successfully met the code with training, inspections of personal knives, etc.?

Quoting this little bit real quick, personal knives would be a hard no from me in a facility.  Beyond being a sanitation hazard, not knowing what they do with the knife outside of working hours, it's an OSHA hazard where your company isn't providing a proper tool to perform a job.  The chance they injure themselves with their own knife and then turn it around into blaming your company is not 0%.

For box knives, the captive program is what I've done.  We had 10 of 'em at my first job, we numbered them all and had them checked in/out on our tool log like any other tool.  Blades had to be replaced when you turned it in, previous blade had to be viewed by a supervisor or above for damage, and the log made the employee initial that the tool had been cleaned and sanitized.  If one got damaged, worn out, lost, whatever, we'd mark it down on the log and replace it.

No health and safety here. I know, it's weird. I was so sick of corporate red tape that I wanted to try a small place (I think technically it's considered 'medium') and see how it goes. It has its benefits over global corporate environments, but it also has unique challenges...

Anyway, my plan is to hit the FSC with this tomorrow at our monthly meeting and give them an opportunity to think it over a bit, maybe one of them will surprise me with a good idea. I'll give them the code and what's required, here's what we SAY we do, here's the last record of us doing it. Meeting the code is non-negotiable, but if we can come up with a better way, I'm all for it.

If it works, that kind of engagement process can absolutely count towards your culture change plan as well.  Could be a win / win.