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Minor NC, storage of food and non-food products

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hacksalot

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Posted 29 October 2018 - 05:33 PM

Morning All,

 

We have an SQF Level 2 certification, and were recently re-audited.  In the past this has not been an issue with previous auditor, but this year we had a new auditor, and he gave us a minor NC in our warehouse because we had non-food products stored with food products.  We have limited room in our warehouse and sometimes we will mingle items with other parts of our business. We do recognize this is not a GMP, but take steps to minimize risk and train employees to recognize risk and minimize when we cannot segregate.  This condition is not going to change anytime soon.  My question is, I don't know how to address the NC to the certification body? I don't want to tell the auditor it will change and then next year he or someone else comes and sees the same condition we had this year.  I could in the non-conformance report tell him we minimize risk, covering food products, looking for contamination sources, and the such.  Not sure how to address?



FSQA

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Posted 29 October 2018 - 06:21 PM

What are your Non-Food Products? Any hazardous material?

 

How do you package your finished Food Products? Kraft paper/liners, etc.?



hacksalot

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Posted 29 October 2018 - 06:41 PM

Lumber, motors, conveyor belts.  We don't store hazardous materials with food items.  Finished product is in collapsible totes and are covered with cardboard covers.



Lesley.Roberts

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Posted 29 October 2018 - 08:51 PM

Warehouse size restriction has been an issue in several companies I have worked at.

 

If you could locate the non food items in a specific location (preferably ground floor) & food in another area - completing a basic risk assessment to show there is no risk of contamination (from foreign bodies or chemicals)  this usually works to satisfy the auditor.


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Posted 29 October 2018 - 09:16 PM

So, I assume this is purely co-mingling of items?  As in they are mixed in here and there?

If that is the case, there is a simple solution and the CAR will fly.

Separate - put your non-food items on the bottom part, consistently and you should not have an issue.

You won't be able to get around this one and your  minor this year could become a major next if not addressed and reported as being addressed properly.


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All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


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hacksalot

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Posted 29 October 2018 - 09:52 PM

Correct, just co-mingling of items as space permits.



FSQA

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Posted 30 October 2018 - 12:42 PM

As shared in the above post, you need to show segregation and separation of food vs non food items in your facility, and it should be fine.

 

However, as Glenn mentioned above, it should be implemented too, as this minor NC can be a major, if observed in subsequent years.


Edited by FSQA, 30 October 2018 - 12:43 PM.

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Scampi

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Posted 30 October 2018 - 01:33 PM

The other solution could be had for a relatively small cost (that is semi permanent too)

 

You can purchase shipping containers that could be put outside and can be locked. You then have space to store maintenance type stuff that is outside the building, but still totally acceptable, just ensure the pest control plan is updated to include this new "building" inside and out

 

If that is not an option, then I agree with above posts......determine the proper location for non food items and ensure it stays that way........if you have to put finished goods in that area, just ensure you follow your own deviation procedures and complete a deviation

 

The best way to be able to grow is to use this as an opportunity to get management on board and add some square footage for storage


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Please stop referring to me as Sir/sirs


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Gerard H.

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Posted 30 October 2018 - 04:34 PM

Hello,

 

For the non-food items, there may be a way to look whether all these items are still of value for your operation. You could make use 5s techniques to reduce its amount. It can be a surprising experience and it contributes to the companies' improvement.

A storage of these kind of materials in the same room can bring the following disadvantages (although all your training efforts and minimizing of the risks):

  • People tend to put more and other type of materials, so it gets a place were all the stuff gets cummulated
  • Often one can observed that clean and dirty materials are mixed
  • The above increases your contamination risk
  • It creates development and shelter conditions for pests (insects and rodents)

I wish you good luck with the resolution of the NC.

 

Kind regards,

 

Gerard Heerkens



Bo16

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Posted 31 October 2018 - 03:38 PM

I agree segregation is the best option, but we also employ a easily seen NON-FOOD caution tape that we wrap all Non-Food products in.  We do not manufacture RTE food and all our products, including non-food products are completely enclosed in packaging.  We are a specialty ingredients manufacture and we sell to both food and non-food customers (even our food grade items will go to non-food customers).

 

With our risk assessment we have never had a NC.



Scampi

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Posted 31 October 2018 - 03:59 PM

I agree segregation is the best option, but we also employ a easily seen NON-FOOD caution tape that we wrap all Non-Food products in.  We do not manufacture RTE food and all our products, including non-food products are completely enclosed in packaging.  We are a specialty ingredients manufacture and we sell to both food and non-food customers (even our food grade items will go to non-food customers).

 

With our risk assessment we have never had a NC.

 

Brilliant..............I've not seen Non-Food tape............just QA HOLD.........but a great solution for not many $$$


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