16 replies to this topic

[moshes]

Hi Simon,
In many cases the packaging plants here have asbestous roofs. In most cases in the stores areas (raw materials and finished goods), but in other cases also in the production areas.
Based on the BRC/IOP what should such a plant do ?
The auditors have a very clear opinion that this is unacceptable.
Can you comment ?

[Simon]

The auditors have a very clear opinion that this is unacceptable.

Which auditors Moshes? BRC/IOP or Customer? If it's BRC/IOP what clause are they pinning the nonconformity against? In the BRC/IOP Packaging Standard it doesn't specifically mention asbestos however, the fabric of the site, buildings and facilities should be suitable for intended purpose. Is it suitable for intended purpose? I'm not exactly sure, but it's definitely not the material of choice. I would ask:

- Is it cleanable?
- Is it intact?
- Is it safe?
- Can it be coated or protected?

At the end of the day if your customers say it's unacceptable and they're worth keeping then it's unacceptable.

Regards,
Simon

[moshes]

Which auditors Moshes?  BRC/IOP or Customer?  If it's BRC/IOP what clause are they pinning the nonconformity against?  In the BRC/IOP Packaging Standard it doesn't specifically mention asbestos however, the fabric of the site, buildings and facilities should be suitable for intended purpose.  Is it suitable for intended purpose? I'm not exactly sure, but it's definitely not the material of choice.  I would ask:

- Is it cleanable? 
- Is it intact? 
- Is it safe? 
- Can it be coated or protected?

At the end of the day if your customers say it's unacceptable and they're worth keeping then it's unacceptable.

Regards,
Simon

Thanks for prompt answer.
The auditors are mainly the BRC/IOP, stating that the fabric (asbestous) is unsuitable, posing a potential hazard (difficult to control) to the final customer.
It is of course uncleanable, and it is also unsafe,
Coating is a possibility. protecting is another, which the auditors may well accept as a solution.
What do you think ?

Regards,
Moshe

[Simon]

We agree that something must be done, but moving to a purpose built factory or completely changing the roof is not feasible. The question then is what can we do to minimise the risk to a safe and acceptable level and pass the audit.

I think coating or protecting in some way sounds sensible, although I'm not an expert and cannot comment on how successful or long lasting this would be. Before carrying out any work I would check with the auditor(s) to verify that this will be acceptable.

Regards,
Simon

[moshes]

Thanks Simon for your help and constructive suggestion.
I would like to hear also the experience of the forum members on this issue.
Regards,
Moshes

We agree that something must be done, but moving to a purpose built factory or completely changing the roof is not feasible.  The question then is what can we do to minimise the risk to a safe and acceptable level and pass the audit. 

I think coating or protecting in some way sounds sensible, although I'm not an expert and cannot comment on how successful or long lasting this would be.  Before carrying out any work I would check with the auditor(s) to verify that this will be acceptable.

Regards,
Simon

<{POST_SNAPBACK}>

[rheath]

Hi all,

Just about to go into my appraisal so will keep it brief.

Dependent of the type of asbestos & the condition - Current HSE advise states that you are best to leave asbestos as long as there is a suitable & sufficient Risk Assessment & that there are suitable monitoring and control measures in place for damage, maintenance etc.

Obviously if your roof is falling down then action needs to be taken BUT in most instances there is more risk from disturbing the roof than there is in keeping it controlled.

Please see attached guidance

Regards

Richard

Attached Files

•  HSEasbestos.pdf   1.42MB   68 downloads

Edited by rheath, 29 July 2004 - 12:52 PM.

[Charles Chew]

[/QUOTE]a potential hazard (difficult to control) to the final customer.
It is of course uncleanable, and it is also unsafe,[QUOTE]

Hi Moshes

Your question on the auditor's remarks seems vague.

Asbestos ceiling is generally harmful to the lungs and is considered carcinogenous. Therefore, base on SA-8000 or ISO 18001, I can agree with your auditor that asbestos materials may be hazardous to worker's health.

However, my opinion for food or packaging materials (lets separate the occupational hazard issues), BRC/IOP (as Simon confirmed it) and/or HACCP does not through CODEX contain specific mention that asbestos cannot be used in a facility. (On this, can you ask your auditor to back up his notation ) - where does the risk to final consumer come into the picture?

In my experience, where food is involved, we simply have an enclosure to cover ONLY the "high risk" area where food exposure is at the highest prior to final packaging. (I am sure you would know what to do for you specific process)

My opinion is that the auditor would have much difficulties in justifiying this corrective action request although, I always DO NOT recommend my clients to go for asbestos ceilings, BUT those who already have it, may well have to do with it unless they wish to proceed to ISO 18001, OHSAS or SA-8000............but thats another chapter.

Charles Chew

[moshes]

Hi friends,
I think your answers make a lot of sense, and I shall use your helpful advices.
Richard, can you rectify the pdf file you have attached as it is impossible to open it (even with Acrobat 6).
Many Thanks for cooperation,
Moshes

[Simon]

I'm experiencing the same problem Moshes.

Regards,
Simon

[rheath]

Simon,

I'm sure I added a post here yesterday, Anyway download should work now although it does take a little while due to file size.

Regards

Richard

[Charles Chew]

Richard,

Good relevant article on asbestos.

TQ
Charles Chew

[rheath]

Thanks Charles,

Moshes,

Basically I would take the view that as long as you can demonstrate compliance with the HSE guidance for Managing Asbestos, I dont see how any food auditor could make you take further action than this.

Afterall, the most immediate risk is for that of your workers, if this is managed to an acceptable level then the food safety risk can pretty much be seen as low.

If the auditor is not happy with the reponse you could refer them to the HSE who I'm sure would put them in their place.

Regards

Richard

[Simon]

Afterall, the most immediate risk is for that of your workers, if this is managed to an acceptable level then the food safety risk can pretty much be seen as low.

<{POST_SNAPBACK}>

You've got it spot on Richard.

Regards,
Simon

[YongYM]

Dear all:

Mentioned about ceiling, is there any one carry out checking at the void above the FALSE CEILING as stated in BRC -Food Ver. 4?

Need your comment. TQ.

[cazyncymru]

Dear all:

Mentioned about ceiling, is there any one carry out checking at the void above the FALSE CEILING as stated in BRC -Food Ver. 4?

Need your comment. TQ.

you should be covering your roof voids as part of your pest plan!

[Gaskit]

We actually have the false roof void on pest control plan and is checked on pest control visits, and funily enough on a pervious BRC inspection the auditor actually gave us a non-conformance due to us not cleaning the roof void, now every year around this time I go up there (FLT and cage) with a hoover and clean the tops of tiles etc and take pics before and after.

Regards,

Steve

[Simon]

now every year around this time I go up there (FLT and cage) with a hoover and clean the tops of tiles etc and take pics before and after.

We're not worthy, we're not worthy.