11.6.2 Cold Storage, Freezing, and Chilling of Foods
11.6.2.1
The site shall provide confirmation of the effective operational performance of freezing, chilling, and cold storage facilities. Chillers, blast freezers, and cold storage rooms shall be designed and constructed to allow for the hygienic and efficient refrigeration of food and be easily accessible for inspection and cleaning
11.6.2.2
Sufficient refrigeration capacity shall be available to chill, freeze, store chilled, or store frozen the maximum anticipated throughput of product with allowance for periodic cleaning of refrigerated areas
11.6.2.3
- The site shall have a written procedure for monitoring temperatures, including the frequency of checks, and corrective actions, if the temperature is out of specification.
- Freezing, chilling, and cold storage rooms shall be fitted with temperature monitoring equipment that is located to monitor the warmest part of the room and be fitted with a temperature measurement device that is easily readable and accessible. Records shall be kept of frozen, cold, and chilled storage room temperatures
I caught something on my Internal Audit that was not included on the previous year's audit (Marked as N/A), and when raising these concerns to upper management, I'm getting some push back as it's "not a concern". So I'll display all the nuanced but obfuscated details and listen to your wisdom on how to proceed:
My facility is fairly unique for a SQF audited facility in that only a small portion of our products are food grade. We do have a refrigerated walk in unit for storing one ingredient. This ingredient is not used in any food grade products, or organic grade products, and is considered a hazardous chemical, so we would not be able to store any food grade or organic grade ingredients in this cooler. This ingredient does not get used in the same equipment either. The ingredient is only being cooled as it helps to slow the degradation of the ingredient, it is not being cooled to control microbial growth. The ingredient would not be more dangerous if it degrades, it would simply not react as efficiently as it should.
Upper management thinks these sections do not apply as the ingredient is not food, and the final product is not food. They do not want to box ourselves in to any required actions.
I think the refrigeration unit should at least be connected to the temperature monitoring of the rest of the facility with alarms if the unit fails, and be included in the cleaning schedule. The SOP on the unit could basically just state that no food or organic ingredients are allowed in the unit and the unit is monitored remotely and alarmed for failure. A simple yearly validation that the temperature matches what is being recorded should be sufficient. This can be done at the same time that other temperature checks are being done.
Thank you for any advise!
