Chemical Control Policy - how detailed?
Hi,
We are getting ready for our second SQF Storage and Distribution audit. I was doing the internal audit on our chemical control program and realized I never really get a definitive answer on some questions. Is it just chemicals that will be used in the warehouse itself, or is it everything in the facility?
How detailed does this need to be as far as what chemicals are on there?
- Passed the initial, didn't have the fire extinguisher chemicals listed. A customer mentioned it once, but never said anything again even though they visit 4 times a year (same person).
- We bought one kind of hand sanitizer for office staff to use and some didn't like it so we are back to 10 desks with 6 different brands/types of sanitizer. Only 2 of them go into the warehouse (dry storage - no food contact) regularly and we have a sink in the warehouse for staff to use as they enter.
- We had dish soap in the breakroom listed, but when the bottle emptied someone brought in another kind. Employee use only.
- We now have 2 kinds of hand soap in the office bathroom because someone is allergic to the stuff we put in the dispenser on the wall. Most people use the hand pump. (The warehouse sink has the soap that is on the chemical list)
- All the women have some kind of hand lotion on their desks.
- Management decided we needed to do away with cleaning wipes because we had a bunch of different kinds, but everyone is complaining now because our cleaning crew doesn't clean our desks and they don't want to use Simple Green and paper towels.
We use two types of cleaning chemicals - Simple Green for mopping and general cleaning, and an RTU disinfectant for the bathrooms, high touch cleaning, and for the tables when we are do special projects (still no direct food contact but we are moving product inner packaging from one case to another and it never actually touches the table, but we clean it at the start of the day while the project is in progress).
A) Does our chemical list need to include everything, even personal items, in the office that never goes near the warehouse door?
B) All staff knows that hand sanitizer (per customer request) can't be used in the warehouse and hands must be washed when exiting the office area.
C) Does the chemical list need to include the stuff in our fire extinguishers?
D) Does the paint we use to retouch the white lines need to be included on the list. I did put it on there last year, but a manager said that was overboard (but banning cleaning wipes wasn't?) because we don't always have it on-site.
A) Does our chemical list need to include everything, even personal items, in the office that never goes near the warehouse door?
The point of having a chemical list is to have an inventory of dangerous chemicals, potentially dangerous chemicals and chemicals that could pose a cross-contamination risk. The chemicals themselves may not go near the warehouse, but there is a reason that food manufacturing companies typically do not allow strong-smelling perfumes, foods, medication and other unauthorized chemicals in production and storage areas.
One mindless mistake and that peanut butter sandwhich for lunch can contaminate a box and next thing you know one of your customer has an allergen cross-contamination in their plant when they open up the contaminated box.
B) All staff knows that hand sanitizer (per customer request) can't be used in the warehouse and hands must be washed when exiting the office area.
They know, but do they actually do it 100% of the time, even when they're under time pressure? Do you have control measures in place to prevent it? Do you have clear reminders posted near the entrance to the warehouse area?
C) Does the chemical list need to include the stuff in our fire extinguishers?
If those fire extinguishers are used, the chemicals inside them will be in contact with the stored pallets. They need to be on the register, so their documentation is regularly updated. If you ever have a fire, you want to know all the risks associated with the extinguisher materials immediately without requesting the info and waiting for a week.
Still, there is some room for interpretation, so I'm keen to hear what others think.
D) Does the paint we use to retouch the white lines need to be included on the list. I did put it on there last year, but a manager said that was overboard (but banning cleaning wipes wasn't?) because we don't always have it on-site.
It may not always be on-site, but you want to have it properly documented when it does show up. Having the documentation ready, so the material can be brought in without any delays is probably desirable -- and yes paint absolutely needs to be on the register.