3 replies to this topic

[shmmccarty]

We had our annual SQF audit, and one of the NCs was that we did not inspect our Soda Ash railcar during receiving. We are a chemical plant that produces a food product from some ingredients including bulk Soda Ash.  The SQF standard cited for this is 11.6.5.1, but in that standard it specifically calls out food only.  Bulk Soda Ash is not considered a food at this point and must undergo a synthesis process where there is no risk of any bacterial contaminants or foreign materals making it into the final product from the Soda Ash.  

 

Would these railcars still require inspection per 11.6.5.1 given this?

[SQFconsultant]

Yes. 

[TimG]

I am assuming this was explained to the auditor during the closing meeting, and they still felt they would give it as a finding?

At this point I would take one of two routes:

1. Contest the finding citing exactly what you've cited here, maybe adding in info on how you keep this non food grade item segregated from any food deliveries -OR-
2. Update your soda ash receiving doc to include ANYTHING that has to be checked (COA to purity standards, etc.)

I worked in a chem plant that took in anhydrous ammonia, hydrochloric and sulfuric acids. NONE of them food grade. We used them to make food grade salts. While I wasn't SQF in that facility, many auditors did attempt to shoehorn us into similar requirements and the fact we checked a COA (for purity) typically sufficed as our 'receiving program'. I don't see why that wouldn't also suffice for SQF.

However, all that being said, I'd probably just contest this one with the auditing body. It's not food when you take it in...

[G M]

We had our annual SQF audit, and one of the NCs was that we did not inspect our Soda Ash railcar during receiving. We are a chemical plant that produces a food product from some ingredients including bulk Soda Ash.  The SQF standard cited for this is 11.6.5.1, but in that standard it specifically calls out food only.  Bulk Soda Ash is not considered a food at this point and must undergo a synthesis process where there is no risk of any bacterial contaminants or foreign materals making it into the final product from the Soda Ash.  

 

Would these railcars still require inspection per 11.6.5.1 given this?

 

By your own description you produce food using this ingredient, so the argument that this material is not edible at this stage seems very weak.  I can imagine the potential for chemical contamination that would certainly pose a food safety risk at later stages if container integrity or unloading conditions were not controlled or monitored adequately.

 

Take a recent example like lead in cinnamon making its way into children's apple sauce.  Far enough up the chain someone though it was a good idea to use lead to boost their stats.  Extrapolating that to your situation I can imagine a toxic mineral with similar organoleptic or reactive properties entering a chemical refining process if no one is checking seals, or monitoring containers for contamination.

 

 

 

11.6.5 Loading, Transport, and Unloading Practices

11.6.5.1 The practices applied during loading, transport, and unloading of food shall be documented, implemented, and designed to maintain appropriate storage conditions and product integrity. Foods shall be loaded, transported, and unloaded under conditions suitable to prevent cross-contamination.