Hazard Analysis - Bulk Bag Lifting frame in production areas

Hi All,

In my workplace there is a new customer who provide us with raw material in tonne bags. These bags only open from the bottom, reason why we are thinking to use a lifting frame within the production area. 

Currently in this area packing a product which is allergen free and the product in the tonne bags has got gluten. As the risk is there someone suggest that could be open in the warehouse with help of a forklift. From technical perspective we refuse that idea, but only option is to use the room where the other product is produce.

In ideal world, refuse to do it will be the best option. But under the current times, the company want to take the chances. 

Has anyone work with lifting frame or tonne bags within production areas? if so, which other hazard have you consider in you hazard analysis. 

I will appreciated your comments.

Are you sure that you are unable to open from the top? Typically at the manufacturer, they load the bag from the top and you unload into a bulk system from the bottom, however, there should be an opening at the top and bottom like the photo attached. 

Please avoid double posting.. It can cause confusion.

Yes I've used that kind of bag in production areas.  Forklifts can be used but only in low risk.  

I'd consider foreign matter issues and certainly that was an issue in the past, both with the forklift and frame etc.

For the gluten hazard, I'm assuming it's a powdery ingredient?  That is a concern.  There will be dust released as the bag is opened.

What I'd suggest is some testing where you do a settle test.  E.g. you could put some of your product on a tray close to the bag being opened or worst case scenario in terms of distance.  Then test the produce by leaving it for as long as the longest breakdown time would be (plus a comfort factor).  So for example, if you have a rule where if they line breaks down for 20 minutes, you clear it, I'd leave the tray for 30 minutes.  If you have no rule like that, think about worst case scenario, e.g. the line is stopped for break then breaks down for 4 hours if that has happened.

Then I'd test the product from the settle test for gluten.  If found, you obviously have a problem you can really quantify.  If not, it doesn't mean it's zero risk (but at least it's due diligence).

Either way, if you can, even if you have a room where this is used with other products, you could also consider putting in some white walls around the bag, i.e. on three sides maybe?  Separate completely if you can?  Another thought could be dust extraction.

But it all comes down to risk and risk assessment.  Remember you can't just slap "may contain" on everything as a substitute for control.  Also I wouldn't be massively tempted to use smaller hand opened bags instead.  Remember that the big pallecon bag is going to be a risk when it's opened but (probably) minimal risk in use.  Hand opened bags will contaminate an operator several times a shift who then may walk to and work on another line.  

As I get older I am more of a "maybe" person than I used to be.  "Technical says no" may still be the right answer but if you can demonstrate to your superiors what the risks are and that you've considered them, then at least the "no" is from a place of putting the effort in and trying to find a way to say "yes".  Or at least if you do say "yes", it's "yes but these are the risks, do we feel comfortable with them?"

I used to work with a lot of supersack'd material in my spice plant.  I'll assume you already have a process down for the normal FM risks associated with having to work with the sacks, but it's not the end of the world to address the allergen concerns.  Without knowing your full process and building layout, some capital investment to segregate the allergen processing area may be called for.  You can accomplish this with a good curtain system around the area you'll process allergens (less ideal; curtains take a beating and rip, and in my experience auditors just don't like them from a sanitation perspective).  You could consider physically walling off your allergen processing area to prevent dust migration, and you'll just need to address making sure it doesn't migrate out from the area via foot or vehicle traffic.

If that's not something management will go for, you can consider minimizing the risk with timing.  Run your non-allergen products earlier in the day or week, to be followed by an allergen run afterward.  That's sometimes a hard sell with your production and sales people, which you can then loop back to capital investment.  Production often wants to have their cake and eat it too, which makes it our job to present multiple avenues to mitigate the food safety concerns sufficiently to keep the plant running optimally.