13 replies to this topic

[NorCalNate]

In order to comply with SQF section 11.6.4, I need to update our Chemical registry so that each hazardous or toxic chemical is identified. Before doing so, I'd like to confirm the definition of "Hazardous or Toxic" chemicals and where to find these classifications.

 

These designations must live on the SDS. I just need to know the exact section or subsection to look for, or if this is another vague, subjective classification that each practitioner must perform a risk-assessment on (e.g., Health Hazard score greater than 0). 

 

Insights appreciated

 

[jcieslowski]

From the code appendix 2, page 92:

 

Hazardous Chemicals and Toxic Substances: Solids, liquids or gasses that are radioactive, flammable, explosive, corrosive, oxidizing, asphyxiating, pathogenic, or allergenic, including but not restricted to detergents, sanitizers, pest control chemicals, lubricants, paints, processing aids, bio-chemical additives, which if used or handled incorrectly or in increased dosage may cause harm to the handler and/or consumer. Hazardous or toxic chemicals may be prescribed by regulation as “dangerous goods” and may carry a “poison,” “Hazmat” or “Hazchem” label depending on the jurisdiction.

 

 

https://www.sqfi.com...vrsn=7f70c75a_8

Edited by jcieslowski, Yesterday, 08:40 PM.

[NorCalNate]

Ok, so if it has ANY score greater than 0 on the hazardous info plackard it is considered hazardous? Is that the best way for me to identify which chemicals are hazardous?

 

I'm looking for a simple, straight forward way to identify hazardous, toxic or non-hazardous. There has to be a simple, YES/NO answer for this, right?

[NorCalNate]

For example, we have food-grade oil-based flavorings. They are used to flavor our product, however they have a 3-Flammable classification. Does this make it hazardous?

[Miri]

In my facility (we manufacture flavors such as the one mentioned), we have numerous chemical ingredients that are "hazardous," so we cannot go off of the placard information.  Hazardous doesn't mean the same as Hazardous Material (HazMat).  We have tried to make it simple by saying if it is not an approved raw material/ingredient we call it hazardous. That means that we include such other things as the equipment cleaner and sanitizer, laboratory chemicals, office and break room products (e.g. coffee pot cleaner) as hazardous - they do not belong in the food we make.  (We decided to lock it all up.)  If it is an ingredient that has the potential to be hazardous, we accept the risk and then manage with appropriate actions, such as controlling who has access to them, more frequent inventory monitoring to account for quantities taken, etc.  We're still developing our program, but so far this has worked for us in differentiating what is hazardous and what is not.

[SHQuality]

For example, we have food-grade oil-based flavorings. They are used to flavor our product, however they have a 3-Flammable classification. Does this make it hazardous?

A flammable product is indeed hazardous.

 

You need to store them securely and you need to be able to show auditors that you have the risk managed by not having too much stock of the material and have fire fighting equipment nearby (and competent staff to use them). Don't forget that the staff also needs to be briefed on how to use the material and the material also needs to be marked correctly (even if weighed into smaller quantities).

[Setanta]

Ok, so if it has ANY score greater than 0 on the hazardous info plackard it is considered hazardous? Is that the best way for me to identify which chemicals are hazardous?

 

I'm looking for a simple, straight forward way to identify hazardous, toxic or non-hazardous. There has to be a simple, YES/NO answer for this, right?

 

 

It isn't going to be a YES/NO answer for many items. You'll need to do Risk Analysis to determine any other factors that take into a risk category that requires special attention.

[GMO]

I would include ingredients if they're listed as hazardous. 

 

All things are poison, and nothing is without poison; the dosage alone makes it so a thing is not a poison. —Paracelsus, 1538

 

The only thing which doesn't make them hazardous in your finished product is the quantity. Therefore as an error or malicious act could introduce excessive quantity, it's valid to list all hazardous chemicals.

[jcieslowski]

 There has to be a simple, YES/NO answer for this, right?

 

Unfortunately that's rarely the case in food safety.  So many regulations and clauses but it all really boils down to - "It's what you say it is".      

 

Based on all the information you provided I would classify most of / all my liquid based food grade flavorings as hazardous in a risk analysis and my steps to control them, as others have mentioned, would be 'storage controls' (IE: only so much in one area, proper separation between pallets, not storing above other ingredients, etc.), 'spill controls' (spill control near by), 'fire control' (extinguishers, overhead sprinklers, etc), 'employee controls' (authorized people only, staff trained on how to handle the chemical, and 'engineering control' (process of removing / using chemical / ingredient is managed with a program - traffic flow, etc).   

I'm willing to bet you already do some of or most of these things, you just haven't listed it in a hazard analysis and thought about 'oh yeah, we do do that'.

[GMO]

Unfortunately that's rarely the case in food safety.  So many regulations and clauses but it all really boils down to - "It's what you say it is".      

 

Based on all the information you provided I would classify most of / all my liquid based food grade flavorings as hazardous in a risk analysis and my steps to control them, as others have mentioned, would be 'storage controls' (IE: only so much in one area, proper separation between pallets, not storing above other ingredients, etc.), 'spill controls' (spill control near by), 'fire control' (extinguishers, overhead sprinklers, etc), 'employee controls' (authorized people only, staff trained on how to handle the chemical, and 'engineering control' (process of removing / using chemical / ingredient is managed with a program - traffic flow, etc).   

I'm willing to bet you already do some of or most of these things, you just haven't listed it in a hazard analysis and thought about 'oh yeah, we do do that'.

 

Remember this is for SQF so food safety not health and safety. Health and safety is important, just not what's being asked for here IMO.

[jcieslowski]

Remember this is for SQF so food safety not health and safety. Health and safety is important, just not what's being asked for here IMO.

 

Very true.  I just would put it all together if possible on ingredients just to save the work.  I do feel like it would also leave the auditor with a sense that the analysis was thoughtful and robust.  Additionally, a fire or spill can contaminate other product and ingredients so, while less of a food safety risk than a fire risk, I think the argument could be made that a flammable ingredient has specifically food safety implications.

[GMO]

True but don't forget the food safety implications including food defence risks.

[Miri]

I think what is boils down to is how does SQF define a hazardous chemical.  A quick google AI search summarized it fairly well (see red text below).  But then you have to go back and read the section.  Focus on answering the requirements (I use the SQF Edition 9 Checklist to get the specifics) and see if you can generalize how you comply with the SQF code based on the hazard type.  

 

While SQF (Safe Quality Food) isn't a federal agency defining chemicals, it aligns with global standards, meaning a hazardous chemical under SQF is broadly any substance posing physical or health risks (like toxic, flammable, corrosive, sensitizing), requiring strict management (handling, labeling, storage) to protect consumers, staff, and the environment, often following OSHA's HCS (Hazard Communication Standard) or similar GHS/national rules, to prevent contamination or injury in food/beverage production. 

 

Key Characteristics of Hazardous Chemicals (SQF Context):

Physical Hazards: Flammable, combustible, explosive, reactive, or generates pressure.

Health Hazards: Toxic, corrosive, irritant, strong sensitizer, causes serious illness (acute/chronic).

Broad Scope: Includes cleaning agents, pesticides, additives, lubricants, and naturally occurring toxins exceeding safe levels. 

 

SQF's Focus (Beyond Definition):

Control: Identifying, documenting, and controlling these chemicals (e.g., pest control, sanitation).

Management: Ensuring proper storage, handling, labeling, and training (MSDS/SDS availability).

Risk Mitigation: Preventing chemical contamination of food products and ensuring worker safety. 

 

In essence, if a chemical can harm someone (worker or consumer) or the food, it's "hazardous" and needs rigorous SQF control measures, often guided by regulations like OSHA's Hazard Communication Standard. 

[jfrey123]

From the code appendix 2, page 92:

 

Hazardous Chemicals and Toxic Substances: Solids, liquids or gasses that are radioactive, flammable, explosive, corrosive, oxidizing, asphyxiating, pathogenic, or allergenic, including but not restricted to detergents, sanitizers, pest control chemicals, lubricants, paints, processing aids, bio-chemical additives, which if used or handled incorrectly or in increased dosage may cause harm to the handler and/or consumer. Hazardous or toxic chemicals may be prescribed by regulation as “dangerous goods” and may carry a “poison,” “Hazmat” or “Hazchem” label depending on the jurisdiction.

 

 

https://www.sqfi.com...vrsn=7f70c75a_8

 

 

For example, we have food-grade oil-based flavorings. They are used to flavor our product, however they have a 3-Flammable classification. Does this make it hazardous?

 

I bolded the part of the SQF definition that I think might apply to your question here NorCalNate.  For your food-grade oil-based flavorings, could consuming them straight cause someone harm?  Could they harm someone if a bad actor decided to quadruple the dose in your finished product, or even if someone just added too much by accident?  If yes, then likely you need to treat the ingredient as toxic per your program.

 

By comparison, alcohol is a flammable liquid but not treated as toxic as it takes a significant amount of straight dosing to harm someone.  (Yes, I know this could be debated to death but please don't as I'm just throwing out a flammable food/beverage item as an example).  Hell, flour is explosive if the dust is allowed to build to a certain level in a confined space, but it's not classified as a toxic chemical despite being a solid with the ability to explode per that SQF definition.

 

As always, clear as mud.  And common sense must prevail at some point.