Risk Assessment to show Water/Backflow Testing is not applicable

Hello, Our facility is SQF Certified for Food Contact packaging. This is our first year of operations and we convert paper products. I am reviewing the SQF code on backflow testing. Our facility does not use water in the manufacturing process. I'm not sure how to go about starting a risk assessment to show that this section of the code is not applicable or very low risk. Has anyone done a risk assessment that I could review in order to start mine?

Simply describe your processes to demonstrate they don't involve water. Based on that, make a conclusion that corresponding section of SQF is not applicable

Hello, Our facility is SQF Certified for Food Contact packaging. This is our first year of operations and we convert paper products. I am reviewing the SQF code on backflow testing. Our facility does not use water in the manufacturing process. I'm not sure how to go about starting a risk assessment to show that this section of the code is not applicable or very low risk. Has anyone done a risk assessment that I could review in order to start mine?

A. where in Module 15 does it show that a "test" is required?

B. I understand you are not using water in the manufacturing process - but do you use water for sanitation?

Hi Glen-We do not use water as part of the process to clean or sanitize our manufacturing equipment. I am referencing Module 13-section  our cleaning and sanitation 13.5.2 Water Quality.

Hi Glen-We do not use water as part of the process to clean or sanitize our manufacturing equipment. I am referencing Module 13-section  our cleaning and sanitation 13.5.2 Water Quality.

My oops, I meant 13 and not 15. 

This is what was written for a client in the packaging field...

13.5.2 - Facility does not use water for manufacturing nor for sanitation and thus the need to prevent back-flow is not applicable.

easy peasy.

We are also a paperboard packaging manufacturer. What conversions do you undertake? Do you do any printing processes? If so, you likely use water in your process in some form or fashion. Does your local municipality not already require you to have backflow prevention? If you do already have backflow prevention in place, just copy the annual inspection certificate and insert it into your FSM (for ease of audit purposes) and you're in compliance. Our auditor spends 2 seconds on it, sees the cert and moves on. Quick and painless!

Okay, so I am not SQF but BRC and during my audit this year my auditor asked me to add backflow devices for next year because we added a new building that has a lunch room and a restroom that open up out into the loading dock area and at my main building lunchroom opens up to my bag storage room but again we don't use water for manufacturing nor for sanitation we dry clean. I have had my township water company say we don't need them because we are considered low hazard( I have an email) and I have had a plumber out here twice looking at me like I am crazing now saying we don't need it and to add one to our main building just because is going to be a lot of replumbing $$$ so what type of contaminated are we trying to keep out, because if a pipe busted and water made it to my other rooms they have floor drains and everything is on racks, and we word discarded anything that would be contaminated worst case. 

So, maybe I can get the plumber to sign risk assessment with me and added it to my email from water company? I always take my auditors advice to improve my program but I am not a plumber and the plumber thinks I am crazy lol HELP!!

My oops, I meant 13 and not 15. 

 

This is what was written for a client in the packaging field...

 

13.5.2 - Facility does not use water for manufacturing nor for sanitation and thus the need to prevent back-flow is not applicable.

 

easy peasy.

I would gather the info and send it to your CB's tech dept. and let them decide if you can gain exemption. Just for reasons of the health and safety of your employees you should install backflow prevention. Comparing the cost of a hospitalization for illness (or worse) due to unintentional introduction of toxins or other matter to the cost of installing the backflow valve, it's insurance and money well spent. We had our incoming 4" main dug up and raised through the floor to have one installed. One less thing we have to worry about and the inspection / test is about $150.00 / year.

Hello, Our facility is SQF Certified for Food Contact packaging. This is our first year of operations and we convert paper products. I am reviewing the SQF code on backflow testing. Our facility does not use water in the manufacturing process. I'm not sure how to go about starting a risk assessment to show that this section of the code is not applicable or very low risk. Has anyone done a risk assessment that I could review in order to start mine?

Hey there - do you happen to have a better insight on what needs to be done for food contact packaging manufacturers in regards to this now that your audit has passed? We have our audit coming up. We have backflow preventers and our mechanics check them via the PM schedule but we have not had the backflow tested by a certified third-party. Any insight here would be greatly appreciated!

We just received a non-conformance for this in our recent SQF Audit (a week ago, so no decision from CB on CARS yet). We could not produce a certificate of testing of the backflow. We explained to the Auditor we co-occupied the building and we did not even have the city water line in our portion of the building so how could we test it. Our city by-law states it needs to be tested once, at minimum a year after installation. We do not use water in our production either. Only water used it for personal handwashing, dish washing in the lunchroom, floor cleaning and some minor equipment cleaning. No risk assessment has been done either. This is the first time in 3 Audits we have been asked to show a test certificate.

UPDATE to my previous posting. I appealed the backflow valve with the certifying board and appeal was denied. Even if you only use water for hand washing you are required to have a backflow valve and a third-party testing certificate once per year. 

Did they tell you where exactly, the code says that?

from the food manufacturing code

I would reach out to SQFI directly, auditors cannot enforce what is not stipulated in the code.

It's time we all push back on this nonsensical "interpretation" of the code

Scampi, they did not. Not able to attach a screen shot of the image for the Appeal report.

same verbiage from the packaging code

13.5.1.2 The delivery of water within the premises shall ensure potable water is not contaminated. Testing of the backflow system, where possible, shall be conducted at least annually and records shall be maintained.

Go direct to SQFI, Leanne Chubbof is who you should speak with

And how would I contact Leanne? At present I've asked for an extension as my CARs have to be in by 12th and a contractor has given us a quote of approx. $2,000 Cdn. to install backflow in the adjoining business. Than we still need to have backflow tested. Not a happy camper

use the contact us form on SQFI

https://www.sqfi.com...ist-contact-us/

Leanne is listed---complete the form with as much detail as possible and she should reach back to you

what your CB is saying is absolute nonsense

Best of luck-but don't put the shovel in the ground yet

Fingers crossed, just submitted form.

Good Luck!

Fingers crossed, just submitted form.

Do you have any updates? Curious to know what the outcome was, since I'm in Canada also. 

SanderE, yes I do have updates.

We were granted an extension and our non conformance set to approved. We were told the CAR deadline extended as requested (mid-December), however, were told the evidence would be reviewed at the next re-certification and that if the work was not completed the repeat CAR would be escalated to Major.

All appeals exhausted. Response from Tammi Van Buren was "Summary of Technical Team Response:

 

SanderE, yes I do have updates.

 

We were granted an extension and our non conformance set to approved. We were told the CAR deadline extended as requested (mid-December), however, were told the evidence would be reviewed at the next re-certification and that if the work was not completed the repeat CAR would be escalated to Major.

 

All appeals exhausted. Response from Tammi Van Buren was "Summary of Technical Team Response:

Annual testing of the backflow system is a new requirement for Edition 9 of the Manufacture of Food Packaging code so disputing based on the 2 prior audits conducted to Edition 8.1 does not support removal of the non-conformance."

 

Long story short, we had the backflow valve installed just prior to the Christmas break at a cost of just over $1000. and it was just tested and passed late last week. All CAR documentation has been submitted.

 

Costly mistake on our part. We are required to test the valve yearly at a minimum cost of $100. each time.

 

Thanks for your detailed answer, and sorry to hear about the costs.