6 replies to this topic

[MSPShawn]

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

1. 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.
2. 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!

[SHQuality]

The second paragraph of the section you cited says that there should be sufficient storage space chill and freeze and store chilled or frozen the maximum anticipated throughput of product allowing for periodic cleaning. 

 

I don't know what your production runs are like now, but it's not impossible for your food grade product to go up in required amount and require additional storage space. Depending on what happens, you may need more or less space for that product as things develop. The easiest way to make sure there is enough space available is to clearly label non-food-grade storage areas and monitor the temperature in all of them.

 

Besides, I would want to know if a non-food-grade product degrades regardless. I would want to tell Sales and sell it to less critical clients who don't mind slightly degraded product. If you don't measure, you know nothing and those costs could pile up.

 

I would push for an investment on this point unless there's no chance of the required storage for each product type changing, but even then it seems to me to just be the smart choice to do it anyway.

[SQFconsultant]

If the only thing you store in cold storage is an ingredient for a non-food item you should request an exemption from your CB for this unit/area - as in an exemption for compliance with the standard, there is cause for this and you should be able to get it.

 

Contact your CB for direction on filing an exemption.

 

Keep in mind that the area would still be subject to inspection during your SQF Audits as that will ensure that no food grade items or food contact packaging, etc is stored in that area as well.

 

The exemption is formal, so it needs to be in writing/documented, accepted, etc.

[SHQuality]

If the only thing you store in cold storage is an ingredient for a non-food item you should request an exemption from your CB for this unit/area - as in an exemption for compliance with the standard, there is cause for this and you should be able to get it.

 

Contact your CB for direction on filing an exemption.

 

Keep in mind that the area would still be subject to inspection during your SQF Audits as that will ensure that no food grade items or food contact packaging, etc is stored in that area as well.

 

The exemption is formal, so it needs to be in writing/documented, accepted, etc.

My answer was based on the assumption your food grade items were also cooled and I may have misread that. If only your non-food-grade items are stored in the cool storage, SQFConsultant is absolutely right, you should apply for an exemption for that area (and make absolutely sure that it remains out of scope for food-grade material)

[MSPShawn]

Thank you both for your advice!

 

I just double checked the checklist that's currently on the SQFI site, that section is not marked as mandatory, would it still be necessary to apply for the exception?  This would otherwise be no different than not auditing the refrigerator in the QC Lab or break rooms...

[jcieslowski]

If I'm to understand what you're saying, your facility is basically at least 2 sections - 
1. A food grade area that is subject to SQF 

2. A non-food grade section that is not at all subject to SQF

 

When you sign up for your audit, you're only auditing your SQF code and areas where food activities occur?  

Your non-food product does not intermingle with your food product (IE: you don't store them together, make them in the same area, etc.)?

 

I would think if you say yes to those, then SQF doesn't 'care' about your chemical product side hustle except in ensuring that they don't mix and you don't store any of your food product with it or bring it into areas where you store your food product.

 

Honestly, this is an odd operation.  I'm not sure I know of another plant that makes food and non-food items in the same plant.

I would advise a lot of caution on cross-contact between the two, proper storage, including the non-food product in hazard analysis and risk assessments, etc.

 

Frankly, sounds like a headache and I suspect you have your work cut out for you.

 

My tentative conclusion based on the information I am assuming to be correct is to say that I side with upper management that this shouldn't really be part of your food safety plan in terms of monitoring activities but I side with you on that the refrigerator should be temperature monitored and on a cleaning schedule because if you're paying to keep something cold it makes sense to know if you're not doing that and having a clean storage area is important for more than food safety.  I would NOT include those activities or SOPS as part of your Food Safety Management Plan.

[MSPShawn]

If I'm to understand what you're saying, your facility is basically at least 2 sections - 
1. A food grade area that is subject to SQF 

2. A non-food grade section that is not at all subject to SQF

 

When you sign up for your audit, you're only auditing your SQF code and areas where food activities occur?  

Your non-food product does not intermingle with your food product (IE: you don't store them together, make them in the same area, etc.)?

 

I would think if you say yes to those, then SQF doesn't 'care' about your chemical product side hustle except in ensuring that they don't mix and you don't store any of your food product with it or bring it into areas where you store your food product.

 

Honestly, this is an odd operation.  I'm not sure I know of another plant that makes food and non-food items in the same plant.

I would advise a lot of caution on cross-contact between the two, proper storage, including the non-food product in hazard analysis and risk assessments, etc.

 

Frankly, sounds like a headache and I suspect you have your work cut out for you.

 

My tentative conclusion based on the information I am assuming to be correct is to say that I side with upper management that this shouldn't really be part of your food safety plan in terms of monitoring activities but I side with you on that the refrigerator should be temperature monitored and on a cleaning schedule because if you're paying to keep something cold it makes sense to know if you're not doing that and having a clean storage area is important for more than food safety.  I would NOT include those activities or SOPS as part of your Food Safety Management Plan.

Yes, it is quite the headache.

 

I'm going to continue to push to have the cooling unit added to the plant's temperature monitoring system so it can be alarmed for failure.

 

Thank you!