Code 11.7.5 - Glass Policy
I would first like to introduce myself. My name is Lee and I have recently taken over practitioner duties at my company. The previous practitioner is no longer at my company which has presented a few problems but I have found this forum extremely helpful!
I am currently working on code 11.7.5 and feel I am interpreting the glass policy, specifically brittle plastic, differently than the previous practitioner. She created an extensive glass/hard plastic log. Our plant contain a large amount of plastic items that I feel would be absurd to monitor such as bathroom signs.
She also included items made from polycarbonate plastic. Do these need to be included?
I have tried to find clarification on this forum but found conflicting information depending on which standard it is being applied to. Some say only clear plastic must be listed. Others say it depends on the risk. Others say it depends on the material.
I would like to keep it as simple as possible yet cover the code.
Thanks in advance,
Lee
11.7.5 Control of Foreign Matter Contamination -- I would suggest a review of SQF Code Ed. 7.1 Module 11 Guidance document (available from SQFI website) It is very clear as to what the requirements area.
I have reviewed the guide but would like clarification as to what is considered "brittle plastic and other materials". We have plastic paper towel dispensers, soap dispensers, electrical boxes, signs, etc. in production rooms as well as in warehouses. Do all of these items in every area need to be included in the register and inspected?
"She also included items made from polycarbonate plastic. Do these need to be included?"
Generally speaking polycarbonate is not considered a brittle plastic. Here's an article from AIB that deals with brittle plastics that may be helpful to you:
As an auditor I found that control of glass and brittle plastics an area where companies generally struggled. The biggest failing was to include everything and anything vaguely glass or plastic like on a register then fail to audit to the frequency required by the internal policy or not react to damge/breakage of items on the list as per internal procedure. For me the audited items should be fixed items only (items that are moveable such as scoops, trays, containers should be monitored as part of general GMP during usage) and risk assessed in terms of location (warehouse, prep areas, dispatch etc), by liklihood of damage (low, high) and ability to contaminate food if broken (low, high). From all these factors you should be able to determine an all encompasing list but schedule your monitoring/auditing frequencies of each item in relation to that risk (daily, weekly, monthly etc) so making the system far more manageable. Also a risk assessment on the action to be taken and associated timescales for these actions is also useful - this again helps to prioritize what order to deal with issues.
If you would like to see a copy of my glasss and hard plastic control procedure I would happily post this for you.
Kind regards,
Sarah
Thanks everyone for your input. Sarah, your post was very helpful and clear. I believe I have everything I need!
Sarah,
I like how your policy sounds. Not sure if you posted a copy of it. Please do.
Thank You,
CB
2.010 Glass & Hard Plastic Audit.docx 25.07KB 337 downloads
2.010Ra Daily GHP audit Low Care.docx 20.27KB 249 downloads
Hi CB
Please find attached my GHP audit procedure. We are a very small facility so the procedure is fairly basic as we do not have a lot of equipment in the factory, but you can use the principles for larger facilities. I have also included a copy of the record sheet we use - I have individual sheets for each area and frequency - again as we are small I can manage this, but a larger facility would probably need to record in a differnt format.
Hope this is useful.
Sarah