Work
Environment
Writing
a work environmental management program is not an easy task, considering various
food industry risk mitigation requirements, food safety, regulatory
requirements, and customer requirements that are inherent to any given specific
food. However, the work environment is the most impactful area where little
ignorance can cost disasters while being most cost-effective for food
manufacturers to look at as a way of eliminating the root causes at minimal
impact. Thus, there are various factors to look at while designing an
individual plan for a specific food product or processing facility, depending
on whether it manufactures a single product or multiple products. If so, are
there any high risk, low-risk product mix or any allergen is used in the
manufacture if a wet process or dry process is used, what kind of human or
machinery involvement, how they are cleaned, what chemicals are used, etc. need
to be assessed while considering CCPs, OPRPs, and risk zones within the
manufacture and site schematics of the facility? Hence, you have to develop a comprehensive environmental management program that balanced the internal environmental requirements as well as out side environment.
Environmental
Impacts Plan and Controls
The
following activity will help you carry out a risk assessment of the
environmental impact of your food facility. If you have more than one site,
assess the risk for each site separately. Start by taking an overview of all
the processes and activities on your site.
Decide
if they present a high, medium, or low actual or potential environmental risk
during normal operating conditions or if you had an accident. Then identify
areas as High, Medium, or low risk and complete an individual assessment on
each considerable environmental risk identified.
Factors
to consider as you carry out your risk assessment can include but are not
limited to processes, activities, and equipment such as raw material storage,
including the condition of containers, plant operation and maintenance, oil
separator operation and maintenance, and material transport routes.
Raw
materials, water, energy, and waste must be evaluated based on volumes of raw
material used, recorded/ metered water use, gas and electricity used, recycling/recovery,
and disposal of waste.
Site
location and impact on the local environment and communities need to be
evaluated on the distance to surface waters, groundwater and water abstraction
points, surface water drains and foul drains/sewers that flow across and off
your site, soakaways, Sustainable Drainage Systems, and unsurfaced ground, your
sites flood risk, housing, and community facilities near your site, protected
areas or toxic environments.
You
should assess what could happen if you had a spill or accident and risks posed
to the environment and people, as well as possible effects of accidents,
flooding, vandalism, and failure of containment. Nonetheless, the physical,
chemical and biological properties of any material that may be spilled during
the operation need to be identified and provide pollution control equipment.
Site
Plan
Prepare
a site plan that shows locations of the following items, including site
entrances and exits available to the emergency services and the buildings and
other main constructions.
The
drainage is a very critical area, which must include, foul drainage (marked in
red), surface water drainage (marked in blue), combined drainage marked with a
red ‘C,’ and showing the direction of flow, discharge points to the sewer,
watercourse or soakaway and location of manhole covers and drains, location of
stop and diverter valves and interceptors, location of pollution control
equipment, for example, drain covers and spill kits.
Service
mains must be identified, including the routes of water supply, gas,
electricity, mains water stop tap, and gas and electrical supply isolating
valves/switch.
Clearly
mark accident and emergency response items, such as personal protective
equipment, fire extinguishers, fire hydrants, fire water tanks/ponds, pollution
control equipment (spill kits), sand bags, alarms, first aid kits, etc.
Identify
vulnerable receptors on-site or adjacent receptors that could be affected by
the site operations, such as porous/unmade ground, watercourses, springs,
boreholes, ecologically sensitive sites, residential properties, schools,
offices, hospitals etc.
Most
importantly, identify internal pollution control points, such as inspection or
monitoring points, raw or processed areas.
Identify
the location of any on-site trade effluent or sewage effluent treatment plant.
Once
you conducted the given activities, you come to a point where you need to write
down it into a procedure that is basically covered under Prerequisite Programs
of the ISO 22000. The following is an example of how to write a generic
environmental management program that was based on a single product (black tea
manufacturing facility) with medium risk under wet and dry manufacturing processes.
The procedure can be used in ISO 22000: 2018 or FSSC 22000 food safety
management systems with specific modifications for a given site.
ISO 22000 -
PREREQUISITE PROGRAMME
PRP 00 – WORK
ENVIRONMENT
Distribution:
Director/General
Manager
Factory
Manager
Factory
Officer
Quality
Assurance Manager
Assistant
Factory Officers
Consultant
– FSMS
Objective
The objective is to outline the
establishment, management, and maintenance of a clean and safe work
environment.
Scope
This
procedure covers the processing and storage areas of orthodox black tea
manufacture, which covers the handling of refuse tea and appropriate disposal
according to SLTB regulations.
Responsibility
General Manager – Providing guidance and establishing requirements
Factory Manager – Providing necessary facilities
–
Maintenance of the facilities
Q A Manager – Identification of necessary requirements
Asst. Factory Officers – Monitoring the effectiveness
Consultant – FSMS – Ensuring the FSMS requirements are fulfilled
Activities
The
process flow is
designed and organized to create a continuous flow of product through the
process and prevent cross-contamination.
The process and storage areas must be separated, the flow of personnel and
cross movements must be restricted.
Pathways
must be demarcated to prevent cross-contamination.
Packaging materials and
other inventories must be received and stored separately from raw materials to
ensure that there is no cross-contamination.
Unprocessed raw materials must be received and segregated to ensure that
there is no cross-contamination.
A
sufficient supply of fresh air must be provided to each processing area,
depending on the operation.
According
to the situation, necessary resources must be disposed of as and when required
to provide a clean and hassle-free work environment for the employees.
The
management must ensure to create non-discriminatory, non-confrontational
working conditions to reduce environmental stress to obtain an effective work
attitude from the employees.
High-risk
foods must be processed under controlled conditions and subjected to
post-process handling, which is protected/segregated from other processes, raw
materials, or operators who handle the raw materials to ensure
cross-contamination is minimized.
Areas
in which high-risk processes are conducted must only be serviced by operators
dedicated to that function.
Employee
access points must be located, designed, and equipped to provide employees with
facilities to practice a high standard of personal hygiene and the use of
distinctive protective clothing to prevent product contamination. Employees
engaged in high-risk areas must change into clean clothing or temporary
protective outerwear when entering high-risk areas. Employees entering the
production and high-risk areas must:
Take
a clean, white smock from the rack outside the production area and put it on,
and smocks must cover outer clothing.
Take
the correct size, clean recommended shoes from the shelves outside the
production area, remove street shoes, and put them on.
Take
a disposable hair cover from the box by the entry point and put it on, and make
sure to capture all loose hair; as well as the men with facial hair must also
use beard nets.
Wash
hands just before entering the production area, following the procedures posted
by the sink, and apply a clean pair of gloves.
When
exiting the room, deposit smocks and shoes in the receptacles provided and do
not return them to the clean smocks and shoe racks.
Maintenance
workers and visitors must use foot covers and clean smocks when entering
production areas, where traffic must be minimized during the production.
The
sanitation supervisor must visually observe the presence of the adequately
smocked employees at the beginning of the shift and after the lunch break, and
every 2 hours. If employees are found to be inappropriately dressed, they are
instructed to dress correctly.
Product
transfer points must be located and designed so as not to compromise high-risk
segregation and to minimize the risk of cross-contamination.
The
humidity, temperature/heat, light, airflow, and noise must be controlled, or
protection measures will be provided when required.
Inspections
for foreign matter contamination must be conducted to ensure plant and
equipment remain in good condition, the equipment has not deteriorated, and is
free from potential contaminants.
Glass-made
materials used in the facility must be listed in a glass register, including
details of their location.
Containers,
equipment, and other utensils made of glass, porcelain, ceramics, laboratory
glassware, or other such material must not be permitted in food processing
/contact zones, except if the product is contained in packaging made from such
materials or measurement instruments with glass dial covers or thermometers.
Regular
inspections must be conducted to ensure food handling/contact zones are free of
glass or other such material and to establish changes to the condition of the
objects listed in the glass register.
Glass
instrument dial covers on processing equipment and thermometers must be
inspected at the start and the end of each shift to confirm that they have not
been damaged.
Wooden
pallets and other wooden utensils used in food handling/contact zones must be
subject to regular inspection for their suitability and dedicated for the
purpose, kept clean, and maintained in good order.
The
knives and cutting instruments used in processing and packaging operations must
be controlled, kept clean, and well maintained.
The
responsibility, methods, and frequency for monitoring, maintaining,
calibrating, and using screens, sieves, filters, or other technologies to
remove or detect foreign matter must be documented and implemented.
Metal
detectors or other physical contaminant detection technologies must be
routinely monitored, validated, and verified for operational effectiveness. The
equipment must be designed to isolate defective products and indicate when it
is rejected.
Records
must be maintained of the inspection of foreign object detection devices and
any products rejected or removed by them. Records must include any corrective
actions resulting from the assessments.
In
all foreign matter contamination cases, the affected batch or item must be
isolated, inspected, reworked, or disposed of.
If
glass or similar material breakage occurs, the affected area must be isolated,
cleaned, and thoroughly inspected, including cleaning equipment and footwear,
and cleared after inspection by the responsible AFO prior to the commencement
of operations.
The
employees must be fairly treated according to the human resource policies
implemented.
Relevant
occupational health and safety measures must be implemented, including fire
safety, smoke protection, maximum weight limits, including protective uniforms,
goggles and gumboots, and first aid whenever applicable.
The
sickroom and relevant infrastructure must be provided with on-call facilities
for medical treatments in case of an emergency.
Floors
of processing areas must be maintained clean and dry during production time.
Walls,
roofs, ceilings, and overhead fixtures must be cleaned regularly to prevent the
accumulation of dirt and dust.
All
solid waste must be collected in closed bins and removed from the factory to
the enclosed collection point regularly to prevent accumulation.
The
collected waste must be disposed of with care to avoid cross-contamination and
multiplication.
All
internal drains must be maintained clean to prevent the stagnation of water.
All
external drains must be cleaned once a month to prevent water stagnation.
External
housekeeping activities must be supervised by an Assistant Factory Officer on a
rotatory basis.
Environmental
monitoring (microbiological tests) must be conducted according to the testing
schedule to evaluate the level of air-bone contamination.
Necessary
improvements and upgrades must be made based on the findings of periodic
evaluations.
Continuous
communication between officials of the core production processes and support
services must be ensured.
The
refuse tea released to the environment must be confirmed to the legal
requirements.
The
functionality and effectiveness of waste disposal must be monitored by the
Factory Manager.
Solid
waste must be disposed of according to the statutory and regulatory
requirements.
Sewage
disposal must comply with sanitary and regulatory requirements specified by the
regional health inspection services.
Facilities
and methods of disposal of the contracted refuse tea collectors (if any) must
be monitored and approved by the company.
The
administration buildings and peripheral areas must be kept organized and well
cleaned, where individual cleaning staff must be hired as necessary.
References
The
testing schedule for environmental monitoring
Refuse
tea disposal methods and schedules of SLTB
Environmental
Risk Assessment
Site
Plan
List of Key Site and Emergency Contacts
List of Substances and Storage Facilities
Preventing Accidents / Possible incidents and what to do if they
happen.
Records
Test
report – environmental monitoring – FSMS 04/PRP/10/RP/01
Cleaning
checklist for admin and peripheral areas – FSMS 04/PRP/10/RC/02
Glass,
brittle plastic, and ceramic preventive control plan – FSMS 04/PRP/10/RC/03
Reference:
ISO/FSSC 22000/FSMA Preventive Control Generic Model: FSSC/ISO
22000 & FSMA Preventive Controls Integrated Food Safety Management System –
A private Label Version
http://www.fwr.org/WQreg/Appendices/Food_and_drink_LIT_8422_963b8b.pdf