5 replies to this topic

[ShamrockGirl]

Good Day,  At our facility we produce bottle water and soda/pop.   Does labels and film overwrap have to be covered when stored?  It is not on a food contact surface.  I know it is a good to do but is this a SQF requirement. 

[GMO]

You've posted in BRCGS rather than SQF.  Are you SQF certified?  If you're a bottler, and BRCGS you'd also be certified to the food not the packaging standard. 

 

If you're BRCGS, no that doesn't need covering for food safety reasons but it's good practice.  Just check on the definition of "primary" packaging that they have in the standard though as it goes a long way beyond product contact.  That doesn't impact you here in my opinion but may in other areas of the standard like supplier approval, trace etc.

[jfrey123]

I'm not a bottler, but everywhere I've worked the labels are often either sitting on a shelf or a box which might be open or half closed.  Biggest thing is that labels are secured and controlled when not in use. 

 

I had fun auditing one of my sites in 2023: their label area was chain linked off in the warehouse with a gate using an electronic lock requiring a code, but inside the gated area was an exit button to release the lock on the gate.  I found a long stick and was able to trigger the exit button from the outside, took a selfie inside the gated area, and told the QA manager their labels were not fully controlled.

[GMO]

I'm not a bottler, but everywhere I've worked the labels are often either sitting on a shelf or a box which might be open or half closed.  Biggest thing is that labels are secured and controlled when not in use. 

 

I had fun auditing one of my sites in 2023: their label area was chain linked off in the warehouse with a gate using an electronic lock requiring a code, but inside the gated area was an exit button to release the lock on the gate.  I found a long stick and was able to trigger the exit button from the outside, took a selfie inside the gated area, and told the QA manager their labels were not fully controlled.

 

You know the "long stick" you "found" was totally there for that purpose?  In one factory I visited, the receptionist had left for the day.  I was waiting to get a card to access from the security who seemed to be nowhere.  I then watched a contractor walk in, take a ruler and fish out a visitor's card from the post box system which was used to return them.

 

I now ALWAYS look for what might be impromptu tools near security controls...

[jfrey123]

The "long stick" I "found" was a piece of a pallet that I broke off lol.  QA manager of that site got pretty peed off at me over it, but I told her it wasn't my fault that her warehouse staff hadn't noticed the broken pallet in their racks.  It didn't help that I was on-site for a week straight as part of a corporate FSQA team building event, and that I started off the week by auditing their building security unannounced:  I defeated their keypad lock on the front door by googling a list of the 10 most common 4-digit passcodes (second try, 2580), wandered unchallenged to where they put on smocks and hard hats, dressed in trainee clothing which should mean I'm not allowed to be unsupervised, then proceeded to walk the entire facility unchallenged for 45 minutes straight.  Literally stood by the QA station checking my fantasy football scores on my phone to see if they'd do anything.

 

Yeah...  I didn't make a lot of friends during that visit lol.

[GMO]

That is both hilarious and an obvious way not to make friends.  I would love though to do some "penetration tests" (yes, hilarious name) as I strongly suspect a high vis will get you into most places.