Glass procedure for fish factory

We are a whole seller company of seafood. We process fresh fish for sale but we have some traded products.

company is BRC certified.

we have small amount of cavier jars that is stored in one of the chill.

in last years because we knew which day is audit day (announced) we removed the jars from factory but this year is unannounced.

is there any solution to keep the jars but through the risk assessment shows risk of contamination is very low? 

You need a risk assessment on hand for the glass jars, and a glass breakage procedure (with training) that includes what you'd do to clean it up, and that a food safety assessment would be done to see how much other product could be sold or dumped

Are the caviar jars something you produce, or is the jarred caviar something you purchase as an ingredient to use in your process?  I haven't gone through a BRC audit personally, but reviewing the code there are allowances for glass ingredient containers so long as your program accounts for breakage.  If you document inspections of the jars after their use, inspections of where they are stored, and reporting of broken glass incidents, and your programs explain how you control the hazard, it seems like you should be able to justify their inclusion in your plant.

You need a risk assessment on hand for the glass jars, and a glass breakage procedure (with training) that includes what you'd do to clean it up, and that a food safety assessment would be done to see how much other product could be sold or dumped

Thank you

we keep these caviar jars in a chill and other products in this chill are packed and there is not any exposed fish crates in this chill.

I prepared a procedure for glass and brittle plastic for how to clean the place after breakage happen.

for risk assessment how I can do the analysis? I meant for which factors? I do all risk asseessments by using matrix of grading to give number for severity and probability. 

Are the caviar jars something you produce, or is the jarred caviar something you purchase as an ingredient to use in your process?  I haven't gone through a BRC audit personally, but reviewing the code there are allowances for glass ingredient containers so long as your program accounts for breakage.  If you document inspections of the jars after their use, inspections of where they are stored, and reporting of broken glass incidents, and your programs explain how you control the hazard, it seems like you should be able to justify their inclusion in your plant.

These are cavier jars we bought them from a supplier and sold them. We do not produce them. We buy them in jar, keep them and sell.

These are cavier jars we bought them from a supplier and sold them. We do not produce them. We buy them in jar, keep them and sell.

Understood.  Seeing your other question about risk assessment, I'm assuming you have a flow chart/plan for these and/or similar items you sell but do not produce.  Within the hazard analysis for that plan, I'd list glass breakage as a physical hazard at each step of your handling of them from receiving to shipping.  As they're essentially a cross-dock item that doesn't go through your production, the risk to your processes seems low.  In whichever matrix you're using, you'll have to judge the likelihood of breakage on your own, and then list how you ensure broken glass jars aren't going to be shipped to your customers.  Be sure employees handling this product for receiving/order filling/shipping are trained in glass breakage procedures, and in my mind you'd be good to go for your upcoming audits.

You actually remove the jars for the audit?

Sorry, but that is rather funny but then again one of my clients years ago that it was a good idea to bring in family members to replace the employees that might say something bad on audit day!
 

I thought it was funny as well, and have had clients do the same type of thing.  One client decided to run a skeleton crew during an SQF audit for the same reason (not wanting employees to say the wrong thing to the auditor), and in their infinite wisdom they didn't schedule any metal detector trained operators for their CCP demonstration...  Plant manager looked at me like "oh god, what do we do?" when they realized this, and I couldn't help but laugh.  Auditor thought it was wonderful to see a plant manager acting as a metal detection tech when the time came, some real management commitment there...

Understood.  Seeing your other question about risk assessment, I'm assuming you have a flow chart/plan for these and/or similar items you sell but do not produce.  Within the hazard analysis for that plan, I'd list glass breakage as a physical hazard at each step of your handling of them from receiving to shipping.  As they're essentially a cross-dock item that doesn't go through your production, the risk to your processes seems low.  In whichever matrix you're using, you'll have to judge the likelihood of breakage on your own, and then list how you ensure broken glass jars aren't going to be shipped to your customers.  Be sure employees handling this product for receiving/order filling/shipping are trained in glass breakage procedures, and in my mind you'd be good to go for your upcoming audits.

Thank you!

Hi

I updated procedure for glass breakage. I prepared a map that shows routs for glass jar product movement and a process flow. I did risk assessment for glass jar risk assessment.

I added glass breakage to the incoming form in intake section.

staffs stick a FRAGILE label on box.

I prepared a cleaning equipment kit for the chill that is the place for storage of packed product in glass jar and in case of glass breakage, only this kit can be used for cleaning to prevent from glass pieces movement and contaminating other sections.

training staffs who handle the packed products in glass jar to follow the procedure is the most important part.

- shatter proof all your bulbs

- minimize usage of glass in the facility

- if you use glass, keep a glass register. 

- lastly, to determine, if you really need to invest time in controlling glass hazards, conduct a risk assessment. It will tell you if you need to control it or not.