Glass and Brittle Plastic Registry

I'm trying to fully wrap my brain around this topic. We are a Wine Production and Bottling facility. Is a Glass and Brittle Plastic Registry an SQF Requirement? If so, in order to comply do we just need to note each item in our Production area and inspect periodically? 

Is this something that a Risk Assessment might be able to take care of? From our perspective, we are not too concerned with this topic as all our product goes through multiple filtering stages including sterile filtered prior to bottling. 

Another NC we got was that our facility windows aren't shatter proof. For us this is definitely not a Food Safety risk, so my thoughts are to address this NC in a Risk Assessment. Otherwise, we will not get Mgt approval to replace ALL our windows.

Yes, for SQF you need a registry where you document all glass and brittle plastic and it needs to be inspected periodically.  I do this as part of my Monthly GMP Audit, I have a line item for "Items listed on the Foreign Matter Register are in acceptable condition."  I also have a risk assessment where I detail the risk I have attached to the items in my register.

As for the windows, I think there are self adhesive coatings you can purchase that coat your windows with to make them shatterproof.  On a quick Google Search I found this:

https://www.vevor.co...CUaAh3HEALw_wcB

Yes they all need to be listed.
The idea of the list is actually to see if you can exclude some of the items, or protect them. Say for example you have a clock, this can have a protective film. Same for any screens on equipment :).
The frequency of the checks has to be based off a risk assessment.
Say for example, you assess the risk as very low because of all the filters etc, and the product is not open, then you might get away with every quarter.
But a facility with open product, with hard plastic close to the line, might need daily.
That doesn't mean all items on your list need the same frequency of checks.
There should also be a column where the condition of the item is noted.
If it has a crack, for example this should be noted.
Then any breakages should be recorded. There should also be a procedure to deal with broken glass/hard plastic (you probably already have one).
I check everything monthly just before the GMP audit. Because I am new at and our facility has a lot of items, I almost find a new item to add every time I go around.
I find the best thing about this audit is that the staff are interested, understand the importance and will point out broken items to me

Ps Spidey I am looking for film for windows and I couldn't follow the link. Would you try post again? :)

Sorry about that, it opens when I test it on my computer.

https://www.vevor.co...-p_010422753681

We just got our windows lightly tinted, which counts as a window film, and also cooled down our production area.

And I'm not SQF, but we do have a glass and brittle plastic checklist of everything in the building, and I have to check it off on my monthly self inspection.

YES.

but dont include your glass bottles that toy package product in as that is evee changing. You would want to include tbat under tou procedures prefill, just everythung else that might qualify such as glass diak faces, machine dial faces, clock covers etc.

I'm trying to fully wrap my brain around this topic. We are a Wine Production and Bottling facility. Is a Glass and Brittle Plastic Registry an SQF Requirement? If so, in order to comply do we just need to note each item in our Production area and inspect periodically? 

 

Is this something that a Risk Assessment might be able to take care of? From our perspective, we are not too concerned with this topic as all our product goes through multiple filtering stages including sterile filtered prior to bottling. 

 

Another NC we got was that our facility windows aren't shatter proof. For us this is definitely not a Food Safety risk, so my thoughts are to address this NC in a Risk Assessment. Otherwise, we will not get Mgt approval to replace ALL our windows.

The glass and brittle plastics register is a requirement, however, the SQFI just did a free webinar on risk assessments and using them as exemptions to parts of the code. They did say that you had to provide any sort of exemptions up front to your certification body prior to them coming on site and scheduling a visit. I think that coupled with a glass and plastics breakage/clean-up procedure would be more than adequate. SQF Code Edition 9 Presentations - SQFI

If you were to go the route of the risk assessment, it would be best done as an appeal to your non-conformance, not as a corrective action. 

Having the glass and plastics audit is a good way to keep up with maintenance and ensure that everything that breaks is cleaned/ repaired appropriately to not contaminate your product. If you can prove that the tiniest piece of glass would never get through your filter, or damage the filter, great! As for the windows, that could go into glass and brittle plastics policy and simply put in place a plan for what would be done if a window were to break and how you would check the safety of the environment/product. Then say how you would replace them with shatterproof. You don't need to do it all at once. It's a huge cost.