9.7.3.2 Glass Inventory

We received a major non-coformance for not having a glass inventory for our breakroom ceramic cups/plates.  Our food processing does not use glass, ever.  Do I really need a glass inventory for the cups/plates that are contained in the breakroom/kitchen?   The breakroom is not near to the production room.  

 

This is the clause that the auditor referenced to.

 

9.7.3.2 Containers, equipment, and other utensils made of glass, porcelain, ceramics, laboratory glassware, or other similar materials shall not be permitted in food processing /contact zones (except where the product is contained in packaging made from these materials, or measurement instruments with glass dial covers, or MIG thermometers are required under regulation).

 

Where glass objects or similar material are required in food handling/contact zones, they shall be listed in a glass inventory, including details of their location and condition

Wow! I've never seen or heard of that happening.  If the auditor defines your lunchroom as a food contact zone, that's a big stretch. IMO.  Where is your lunchroom in relation to your processing//food contact areas?  Did the auditor say it was in very close proximity /no physical barriers? 

 

Do you have your lunch area on a zoning map?  If you do a risk analysis and eliminate based on lack of risk, I think that would suffice, unless there's some reason it is a risk. 

Wow! I've never seen or heard of that happening. If the auditor defines your lunchroom as a food contact zone, that's a big stretch. IMO. Where is your lunchroom in relation to your processing//food contact areas? Did the auditor say it was in very close proximity /no physical barriers?

Do you have your lunch area on a zoning map? If you do a risk analysis and eliminate based on lack of risk, I think that would suffice, unless there's some reason it is a risk.

The lunchroom is in its own room, not a big open area. There is a small boot changing/ppe room that separates the processing room from the lunch area. I too was left perplexed. So not sure?

I found this on another thread on this forum:

 

 "I included any glass or brittle plastic within the building including offices, bathrooms, break room, etc.  If something breaks where employees will walk, there is the potential for them to track the broken material back to a food safety zone.  It may have been overkill, but the auditor was happy with our program"

 

Maybe write a risk analysis, call out this risk, and write a cleanup /inspection policy to us in the instance that a glass item is broken in the lunchroom, to include inspection of employee's shoes for glass shards and a documented means for them to clean their shoes and another employee to verify all person's shoes in the affected area are clean before they re-enter the processing area? It isn't completely out of the realm of possibility when you look at it this way, so pushing back may not be worth it. 

Wow, I sure hope this was not a real audit, but a gap or preassessment etc.

 

Your Auditor did a major F-UP.

 

Total miss-application of the standard.

 

If a real audit, you must challenge and if it ever happened again you challenge before the auditor leaves the building.

I found this on another thread on this forum:

 

 "I included any glass or brittle plastic within the building including offices, bathrooms, break room, etc.  If something breaks where employees will walk, there is the potential for them to track the broken material back to a food safety zone.  It may have been overkill, but the auditor was happy with our program"

 

Maybe write a risk analysis, call out this risk, and write a cleanup /inspection policy to us in the instance that a glass item is broken in the lunchroom, to include inspection of employee's shoes for glass shards and a documented means for them to clean their shoes and another employee to verify all person's shoes in the affected area are clean before they re-enter the processing area? It isn't completely out of the realm of possibility when you look at it this way, so pushing back may not be worth it. 

 

Thanks!   But as I read the standard I thought it was only for glass items used as processing.   However, I'll take your advice and conduct a risk assessment to be on the safe side.  

Wow, I sure hope this was not a real audit, but a gap or preassessment etc.

 

Your Auditor did a major F-UP.

 

Total miss-application of the standard.

 

If a real audit, you must challenge and if it ever happened again you challenge before the auditor leaves the building.

 

Yes it was a pre-assessment audit.  This one definitely confused me.  Fortunately it was just a preassessment.   A bit scary how some clauses/elements are interpreted.  Makes me second guess myself.  

I was going to answer your question regaurding your confidence from a pre assessment audit.  It really depends on the auditor.    There will always be things that people miss, etc.   However i would be concerned with someone that missapplies the standard like this.    Perrhaps /hopefully they were trying to be exceptionally hard.  I would discount this finding a not spend much any time on it.     In food handling / contact zones means just that.  Then classifing it as a major?   concerning 

I've seen pre-assessment mentioned a few times here - can someone please explain how a pre-assessment works?

Is this a gap assessment completed internally in preparation for an audit? 

I've seen pre-assessment mentioned a few times here - can someone please explain how a pre-assessment works?

Is this a gap assessment completed internally in preparation for an audit? 

 

The pre-assessment is done by the certifying body.  It is conducted similar to a real audit but of course it is a gap/practice audit.  

9.7.3.2 Containers, equipment, and other utensils made of glass, porcelain, ceramics, laboratory glassware, or other similar materials shall not be permitted in food processing /contact zones (except where the product is contained in packaging made from these materials, or measurement instruments with glass dial covers, or MIG thermometers are required under regulation).

 

Where glass objects or similar material are required in food handling/contact zones, they shall be listed in a glass inventory, including details of their location and condition

 

Bolding for emphasis, I'm with SQFconsultant that this is an auditor's screwup.  Luckily it was in a preassessment type review, otherwise I'd be challenging the finding with the CB and SQF.

 

You do mention that a boot changing room is directly adjacent.  Now if some of your breakroom items ended up in there, say employees like to take a glass of water into that room while they're putting their boots on, then an auditor could make this argument that you're allowing glass into a production related area.  Could be worth updating any SOPs that address breakrooms to state the dishes are required to stay in the breakroom.  You could mention them in the SOP for your glass and brittle plastic control to state they are not permitted in food handling areas.  Lastly, if it becomes too much of a sticking point, remove them from the break area entirely and have employees bring their own utensils for lunch.

One of our customers, who is requiring our storage facility to become SQF, suggested we not allow glass in our breakroom.  I told my boss that was a ridiculous request and would mean no microwaves and the refrigerator would have to go.  He also suggested we put our mop buckets on the glass registry, but I pointed out they were not brittle plastic and ignored the suggestion.  He also wanted us to number each window, including in the office, but we also ignored this.

I didn't include the office area or breakroom on our glass registry, just the warehouse (no exposed food or production here), the number of lights, windows that look into the warehouse, forklifts (the various glass/brittle plastic components), exit/emergency lights, sky lights, RF scanners, insect light traps, what areas in our warehouse are dedicated to glass in customer products.  

Our GAP auditor never mentioned missing info from office or breakroom areas, she just said to be sure all the little dial covers on the lifts were included (they were). We even included cell phones even though not everyone always has them on their lifts.  I was thinking about including X number of employees wear eyeglasses but thought that would be too hard to manage in a document as staff changes and move between warehouses.