Let me present two examples from my own personal past. The first scenario starts with a government food inspector’s surprise visit a number of years ago. At the time, I did everything that a QA manager was supposed to do. I made sure that I had a pre-determined monthly glass & plastic audit carried out, documented, and saved neatly on an Excel workbook. Whenever an inspection or 3rd party audit took place, I was able to produce my monthly glass & plastic audit to demonstrate that I went through the motions. One morning as I sat working through a mountain of paperwork, the receptionist called to let me know that a badge toting inspector was waiting for me in the lobby.
I asked her to offer her a coffee and I’ll be right over. On my way over to the office, I alerted the floor supervisors that an inspector was on site so they could make sure our ducks were in a row as much as possible. As I meandered to the office in a slow, purposeful manner that would allow the supervisors to clean up without the inspector calling me out for my antics, I gave the production floor an eyeball just to make sure nothing was obviously out of place. While I escorted the inspector through the plant with a feeling of pride that she was seeing a well-oiled machine in action, I took every opportunity to walk ahead of her so I could find any paper towel wads shoved inside of an I-beam because it was closer than the nearest dumpster. I followed the inspector up a flight of stairs where she wanted to walk down the mezzanine and get a better look at the operation from above.
The inspector stopped dead in her tracks, pointed to a few shards of opaque plastic that laid on the mezzanine floor and the looked directly over her head to see a nice hole in the light cover hanging from the ceiling. She was wise to the routine and was nice enough to not make a big deal of it because she noticed the broom nearby and was able to deduce for herself that some good intentioned employee more than likely ran up the stairs to clean up quickly, only to accidentally poke the light cover with the broom handle shortly before we arrived in the area. Now I’ll admit that it was probably my own poor training that led to the employee walking away instead of picking up the pieces…..the point was, for all I knew that light cover could have gotten broken the day before because my “control” amounted to a brisk walkthrough to document an audit and keep things legal.
Moving on to a GFSI audit after an actual control/audit structure was developed based on risk and successfully implemented, sweat no longer beaded up on my forehead worrying that the auditor was going to surprise me. In fact, removing all “non-essential” glass & plastic, protecting all essential (and higher risk) items, and auditing areas at frequencies according to their risk we now had actual control instead of a poorly executed audit. In fact, when we stepped into the production area and took our turns washing our hands, the auditor asked me if the plastic housing on the paper towel dispenser was on my glass register. I affirmed that it was. She asked if I thought that was ok. I told her, and I proudly quote, “Yes, that item was assessed and it was determined to be a low risk item which did not present a hazard to the open product. I even have the crack on the backside of that dispenser documented on the glass breakage register and it will be replaced at the soonest opportunity.” Until then, we will continue to audit it at an increased frequency since it is cracked. The auditor smiled and said “Good answer” and we proceeded with the rest of the audit.The Glass and Plastic program has seen its fair share of attention in the years since GFSI hit the shores of North America. It has caused a lot of head shaking and more than likely an argument or two between the maintenance and QA managers. The increased “control” came by way of improving the programs themselves though, not by adding an additional employee with a clipboard and a continuous roving glass audit. The increased control brings with it exactly what the basis of the GFSI is – safer food!
Let’s take a quick look at BRC Version 6 Clause 4.9.3
- Glass or other brittle materials should be excluded or protected against breakage where a risk of product contamination is present (is it necessary? If it is, can it be replaced with a more suitable material? If so, replace it. If not, register it.)
- Document your glass control and breakage procedures (SOP)
- Glass Register (location, number, type, condition)
- Specify frequency based on the level of risk to the product
- Detail cleaning and replacement procedures
- Document glass breakage procedures including:
- What is your procedure regarding quarantining product and blocking traffic through the breakage area
- How is the production area to be cleaned? Where should employees discard broken glass?)
- Who is responsible to inspect the area after clean up and authorize restart of production?
- Don’t forget your Tyvek bodysuit and booties!
- Who is responsible for stopping traffic, quarantining, cleaning, etc.?
- How is the breakage event going to be recorded? Who is responsible for recording it? Who is responsible for reviewing the breakage reports?
The control systems for glass/plastic need to reflect the actual risk of the hazard, and the GFSI has recognized this in their requirements. And it is great to see that a GFSI auditor understands this.
About the author
George Howlett is the CEO of Safefood 360° and one of Europe’s leading food safety experts. Before establishing Safefood 360° he worked at some of Ireland’s most prominent companies and brings the expertise with him. George also lectures in the MSc for Food Safety Management in the Dublin Institute of Technology.