7 replies to this topic

[PenguinPwner]

Hi all! First post on here. After reading essentially everything posted here, I have come with a question of my own. Forgive me if it's silly, I haven't been doing SQF or even QA for all that long!

 

We had an NC on our first SQF audit, and it was in regards to the chemical database. We didn't have one. Mind you, this had been something people were aware of, but for some reason people thought that I was going to be the one to alleviate that particular problem. I had brought it to their attention, multiple times. Anyhow, it was resolved, erroniously if I'm not mistaken, by having a chemical titration log put out on the production floor. This log tracks usage of chemicals for CIP/COP. However, for every other chemical we have here for QA, Janitorial staff, maintenance, etc., there is no database of on-site chemicals. Would the titration log alone be sufficient as a database? I am unsure and leaning towards no.

Furthermore, the new chemical approval SOP we have here is sourced from another plant that we have, and it requires the plant manager to approve every new chemical. I have not found anywhere that states that the plant manager is the sole person capable of doing so. Ours is a very nice person who is very much QA oriented, but English is not his first language and he is constantly busy as is. Who would be qualified to approve new chemicals? Is it only the plant manager that can do this?

 

 

Thanks, everyone! 

I hope these weren't dumb questions, lol.

[TimG]

11.2.5.2 Detergents and sanitizers shall be suitable for use in a food manufacturing environment, labeled according to regulatory requirements, and purchased in accordance with applicable legislation. The organization shall ensure: i. The site maintains a list of chemicals approved for use; ii. An inventory of all purchased and used chemicals is maintained;iii. Detergents and sanitizers are stored as outlined in element 11.6.4; iv. Safety Data Sheets (SDS) are provided for all detergents and sanitizers purchased; and v. Only trained staff handle sanitizers and detergents.

 

You've got to hit each of those points if you're SQF. Some things to note, they say you need a list, and you do an inventory and maintain it. They don't say how often you update that inventory. I have a list of stuff I inventory weekly, and some I inventory annually. It's compliant. 

Another thing an auditor will do is see a chemical, ask you to see it on your 'approved list', and then ask you to see the SDS. So make sure you can do that.

[SQFconsultant]

Would the titration log alone be sufficient as a database? I am unsure and leaning towards no.

 

................. Nope.

 

You need a full inventory list.

 

Ours is updated with usage and replacement and then checked each week.

 

Our QA Manager approves/dis-approves and verifies the list every week.

[G M]

For the approval process, and most things in SQF, it just needs to be a "trained and qualified" person; and it is up to you to define what trained and qualified means. 

 

As long as what your policy says makes a person trained and qualified is generally reasonable, and you do what your policy says, you'll be ok.  While borrowing a policy or program from a sister plant is a fair starting point, this is one of the reasons these plans are meant to be bespoke for each site, what works for them won't necessarily work for your facility.

[jfrey123]

What they said.  Master chemical list for the entire site, inventoried at an interval you determine to help track usage.  Those chemicals that need to be diluted before use must have a titration log or come out of a calibrated dispenser, but there are plenty of other chemicals that come ready-to-use so just tracking them by count is fine.

 

If all of your sanitation chemicals aren't coming from one supplier now, this is a good time to suggest a change.  Often you get a dedicated chemical rep who will come in once a month and run a chemical inventory for you while they're setting up your next order.  These inventory reports can be reviewed by your team and it meets the standard.  They also take repsonsibility for keeping for SDS book up to date, and can schedule chemical use training for your staff.  Lots of benefits to making a dedicated chemical company do the work for you.

[PenguinPwner]

Thanks everyone for the quick and salient replies! I had assumed that it was insufficient and that the plant manager needn't accomplish approvals, personally. But I'm just the Document Controller they designated as the site's back-up SQF practitioner. Something wasn't sitting right and I had planned to bring this up...again during our SQF meeting on Friday. My manager often jokes....? that we will "just pay the fine and move on" whenever something is brought up. 

 

Thank you all!

[Lynx42]

I have a link to each SDS on my chemical list.  I also created a sheet with all the QR codes on it posted in our sanitation closet, in our breakroom, and one in my audit binder so anyone can scan it to access the SDS.  Saves printing them out and makes for quick easy access for everyone.  If we discontinue a chemical, I do print that SDS out for our records.

[GMO]

I used to have an approved list of chemicals not just with the MSDS but also the technical data sheet as the latter for cleaning chemicals gives you what concentration is effective, the intended use etc and MSDS often does not.  I hate it when technical people only ask for the MSDS only (including SQF, sorry) as the data you need isn't often in there.  It's a safety document.

 

On lubricants, that's really important there is an approved list and that it's clear what is ok for food contact, incidental food contact and which are not permitted to be food contact.  People often claim they only have food contact but when you delve, you often have others due to the performance of the materials.  On these you also need to be looking at the lack of allergenic materials within the lubricant (there should be a positive statement to this effect).

 

All of this needs to be kept on file.  So to my mind, it's not just having the list but having the data to back it up then having that list available to people who order and receive chemicals to ensure they don't receive things not on the list.  

 

I normally keep pest management chemicals off there because they're normally only used by the pest contractor (assuming you contract out) and rarely nowadays would toxic baits be used and if they were they'd only be in locked bait stations in locked off areas, e.g. plant rooms in response to an incident.  They tend to keep their own list but it's worth checking it against what they've used in the past (even non toxic) as I've found gaps before.

 

I'm not against combining this with safety and often you may find they have a need as well for COSHH / chemical control / flammables legislation so you may be able to team up and get this done once between you.