Posted 02 March 2017 - 01:18 AM
If the pipes are in good condition and not leaking I might see a major finding; however by definition this is not a critical - look up the definition.
With that in mind we consulted with a food manufacturer that is housed in a building that used to be a brewery and had similar piping over (miles and miles of piping) over their packaged products in the warehouse and while many of the pipes were not in bad condition the recommedation was to seal up the ones that could not be removed, mark them ad to what they conveyed and it never came up on the audit.
I don't beleive the critical finding is justified by the SQF definition of a critical finding if what you say is correct.
Gotta know the definitions of findings when you go into your live cert on site audit so that if nessacery you can challenge a finding.
In the meantime if you can't re route the pipes you can have routine inspection of the pipes for condition, mark them as to what direction the flow is and name them. Document you pipe audits and risk analysis until you can cover, box in etc and that should satisfy the auditor.
All the Best,
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Glenn Oster.
Glenn Oster Consulting, LLC
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