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How often are locker inspections required for SQF?

Started by , Aug 30 2022 10:33 PM
10 Replies

How often are locker inspections required for SQF?
We have our audit in about 3 weeks.

Our HR director, operations manager, etc, have all started since I started in December.   I'm not sure they know it's needed.

At my last job, we did them 1 or 2 times a year (I didn't do them, so can't really remember)

 

What's allowed and not allowed?
I know no food/beverage.  No meds.  Basically clothes, keys, wallet, watch, that type of stuff.

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It depends on where your lockers are located.

 

We previously had the lockers located outside of the change room, but still inside the warehouse. This did not work since employees wanted to keep snacks and medications there since there was no storage in the break room. We then moved the lockers to the break room, which is not considered to be part of the clean zone. Because the lockers are in the break room, we do not inspect lockers nor restrict what items may be kept in there.

 

We also do not allow any personal items (apart from street shoes, which are being changed out of) to be kept in the change room.

 

I'm assuming that your lockers are somewhere closer to your production area, which is why you are asking these questions. We found it easier to move the lockers but with a risk analysis you can come up with the best way in your situation to prevent product contamination.

It depends on where your lockers are located.

 

We previously had the lockers located outside of the change room, but still inside the warehouse. This did not work since employees wanted to keep snacks and medications there since there was no storage in the break room. We then moved the lockers to the break room, which is not considered to be part of the clean zone. Because the lockers are in the break room, we do not inspect lockers nor restrict what items may be kept in there.

 

We also do not allow any personal items (apart from street shoes, which are being changed out of) to be kept in the change room.

 

I'm assuming that your lockers are somewhere closer to your production area, which is why you are asking these questions. We found it easier to move the lockers but with a risk analysis you can come up with the best way in your situation to prevent product contamination.

 

 Our entire facility is one building.  Production is the lower floor, then down the hall is locker rooms, restrooms and the QC labs.  Upstairs is office and lunchroom.

We did them quarterly under SQF but I dont recall the frequency being specified. 

SQF does not specify how often you are to do these inspections

Hi Miss Frankie,

 

I would cover locker inspection as part of my inspections of Staff Amenities as per 2.5.4 Internal Audits and Inspections (Mandatory) at a frequency based on risk and the area where the lockers are located:

Regular inspections of the site and equipment shall be planned and carried out to verify Good Manufacturing Practices and facility and equipment maintenance are compliant to the SQF Food Safety Code: Food Manufacturing.

 

Previous SQF Guidance reference to lockers typically covers the design of lockers/locker areas not inspection of lockers:

The areas shall be designed so materials and personal items cannot be stored on top of the lockers. The area around and under lockers if not fully sealed, must be able to be easily cleaned. It is generally recommended that lockers be fitted flush with the ceiling and placed on stands raised off the floor to allow ease of cleaning.

 

From 2.8.1 Allergen Management (Mandatory) your assessment may have led you decide that you needed to inspect lockers at a specific frequency due to allergen risks:

2.8.1.1 The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented. The allergen management program shall include:

i. A risk analysis of those raw materials, ingredients, and processing aids, including food grade lubricants, that contain food allergens;

ii. An assessment of workplace-related food allergens that may originate from locker rooms, vending machines, lunchrooms, and visitors;

 

Obviously personal medicines need to be controlled to ensure they do not constitute a risk to product, so they should be prohibited from product areas but may be permitted to be stored in secure lockers along with other personal items. You should also consider how the medicines are packaged for example, exclusion of medicines in glass bottles.

 

Kind regards,

 

Tony

 

 

We did quarterly locker inspections and cleaning. We would also have our pest control company spray the locker rooms/bathrooms and we would inspect the lockers for any maintenance repair (mainly rust). This was all done on off hours. Only locks issued by HR are allowed too.

We did quarterly locker inspections and cleaning. We would also have our pest control company spray the locker rooms/bathrooms and we would inspect the lockers for any maintenance repair (mainly rust). This was all done on off hours. Only locks issued by HR are allowed too.

 

Hi kfromNE,

 

ü Quarterly locker inspections and cleaning

ü Inspect the lockers for any maintenance repair

ü Only locks issued by HR are allowed

ý Pest control company spray the locker rooms/bathrooms

 

Spray with what? Pesticide? I'm not sure routine spraying with pesticide is a good idea, perhaps a one off if there is an issue but proper hygiene and housekeeping should ensure that locker rooms are pest free.

 

Kind regards,

 

Tony

Hi Miss Frankie, 

 

At my old facility (500+ emp & two locations) we would do daily locker cleanings. The lockers / locker room were cleaned after break and between shifts via the in-house cleaning team. Random checks were conducted by the quality team at least once per quarter. This documentation supported the pest control program, security, GMP and allergen program. We never scored lower than a 96% on the SQF audit. I believe this was a game changer. 

 

Best of luck!  

Again, SQF does not require the inspection of the inside of lockers. It specifies the proper exterior design.

A risk analysis should be done covering allergens and glass, however an interior inspection is not required under SQF. 

 

If you want to include one, I would make it part of the GMP audit at whatever frequency your policy/program states. Its easy to add that as an additional inspection versus creating an entire program just for an inspection of locker.

 

I will also include, that the new hire/ annual GMP training should include and have a section that focuses on NO ALLERGENS and NO GLASS be brought into plant and/or stored in lockers. This helps shore up your no inspection or limited inspection.

I've historically included lockers in my GMP checks in various facilities, but all have been located in breakrooms so their contents fell to the general rules under breakrooms.  Personal food/drink were permitted, at that point it makes no difference to say "no food in lockers" when we're permitting food in a refrigerator or a cabinet 3 feet away.

 

I've never liked requiring HR issued locks, as it seems to offer the SQF auditor an opportunity to demand a locked locker be opened.  Open lockers are free game as an auditor inspects breakrooms, but locked with a personal lock stops an auditor.  This has been found to comply with 11.3.5.4 as the provision for employees to store personal items, so long as the risk assessment for allergens located in breakrooms is also performed.


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