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#1 mckief

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Posted 14 December 2010 - 07:42 AM

Hello, We recently had a Tesco audit and unfortunatley the hot water tank broke at the hand wash station just before the auditor entered the production area and cold water was only available. The auditor was quiet upset by this as is understandable but maintenance were working on the water heater and once fixed it was promptly put back. One comment the auditor made was that we were breaking the law by only having cold water for hand washing. I have trawled through various customer codes of practise and the BRC and cannot find anything about hot water being a legal requirement. The water tank has broken again today and I have irrate maintenance teams questioning the law. Please can anyone help to confirm that having cold water at hand washing for any period of time is illegal?

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#2 Mike Green

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Posted 14 December 2010 - 09:11 AM

Hello, We recently had a Tesco audit and unfortunatley the hot water tank broke at the hand wash station just before the auditor entered the production area and cold water was only available. The auditor was quiet upset by this as is understandable but maintenance were working on the water heater and once fixed it was promptly put back. One comment the auditor made was that we were breaking the law by only having cold water for hand washing. I have trawled through various customer codes of practise and the BRC and cannot find anything about hot water being a legal requirement. The water tank has broken again today and I have irrate maintenance teams questioning the law. Please can anyone help to confirm that having cold water at hand washing for any period of time is illegal?


Hi- I have never come across an actual temperature in any of the uk guidance-just references to 'warm water' or 'water at a temperature to effectivley clean hands'

There is a lot of research indicating that temperature really doesn't matter- especially with modern soaps(older soaps needed warm water to get a decent lather :biggrin: )-

Everyone has different tolerences to temperature anyway- I have heard of scalding occurring at 49 degrees celsius-which obviously isn't hot enough to kill bacteria anyway- so i can't see any government body sticking their neck out on anything hotter than that!

maybe the reference to warm water is simply to make it comfortable for effective handwashing?-if the water is freezing then their is more liklihood of a quick wash?

Regards

mike
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I may sound like a complete idiot...but actually there are a couple of bits missing

#3 Inesa

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Posted 14 December 2010 - 09:56 AM

Hi to all,

I can't imagine washing hands 20times a day in cold water. Some people have sensitive skin, I've never tried it, but I think skin irritation can occur and in food industry we must always care about our skin.

Regards


Edited by Inesa, 14 December 2010 - 10:50 AM.

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#4 Inesa

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Posted 14 December 2010 - 10:27 AM

I'm back again Posted Image

I found some answers at this page:

http://www.food.gov..../faq/fhc2qanda/



Do all food businesses have to provide handwashing facilities for staff?
Yes, all food businesses must provide a basin in food areas for staff to wash their hands. It must have hot and cold running water, soap and suitable equipment for drying hands, such as disposable towels. If unwrapped food is handled in the business, there must be a separate sink for washing food. [The Food Safety (General Food Hygiene) Regulations 1995]


Edited by Inesa, 14 December 2010 - 04:47 PM.

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#5 gtjs

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Posted 14 December 2010 - 11:52 AM

Hello, We recently had a Tesco audit and unfortunatley the hot water tank broke at the hand wash station just before the auditor entered the production area and cold water was only available. The auditor was quiet upset by this as is understandable but maintenance were working on the water heater and once fixed it was promptly put back. One comment the auditor made was that we were breaking the law by only having cold water for hand washing. I have trawled through various customer codes of practise and the BRC and cannot find anything about hot water being a legal requirement. The water tank has broken again today and I have irrate maintenance teams questioning the law. Please can anyone help to confirm that having cold water at hand washing for any period of time is illegal?


Hi Folks,

There is also the H&S aspect, as covered by Workplace (Health, Safety & Welfare) regulations 1992 reg 21 (2) ©

http://www.legislati...ulation/21/made

Cheers,
G

(My first post!)
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#6 QLD

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Posted 14 December 2010 - 12:13 PM

I have not heard of any defined temperature for warm water and its purpose is certainly not to kill bacteria. Warm water is used because it is more effective when used with soap to remove oil, soiling and bacteria from your hands.

You could argue that you are not meeting the standard of warm, but in turn you could argue you believe cold to warm but without definition it is open to interpretation.

I would like to tell the auditor to chill out but in reality just take the feedback and wait for him to leave. If the boiler keeps failing perhaps it is time for an upgrade.


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#7 GMO

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Posted 14 December 2010 - 02:44 PM

I would say it's more to encourage handwashing than any bacterial reason but it shouldn't be overlooked how reluctantly people will wash hands in cold water or do so in an ineffective way.

I had a similar situation; however, fortunately without an auditor on site and contacted the soap manufacturer to ask them whether the soap was still effective; they confirmed in writing that it was and so I briefed the teams to explain it that the boiler had gone down; it was uncomfortable but still safe and please ensure hands were still washed properly. As the auditor was insisting it was illegal, however they might not have accepted that but I still think that was sensible in the factory I was in and would at least try to defend it.

I recall a similar situation though where I couldn't find a reference on what the temperature should be, until I worked in sandwiches and the British Sandwich Association came up trumps!

"i) Hand wash facilities must have taps operated by elbow, knee, foot or sensor systems and not by hand . Water should be premixed to a temperature of 45-50oC. Handwashing must be performed at appropriate intervals."

http://www.sandwiche..._practice.shtml

IMO it probably depends on your product type, your processing environment and how long the boiler would be down. The situation I'm referring to was in a factory with very little handling of product; in a sandwich factory where you can have 20 people on a line handling different components, I might feel differently.

Other thing worth thinking about is in future what would you do? If you don't have a business continuity plan get one! But if you do, have you considered what you would do if the boiler failed again or failed completely? It's worth thinking about.


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#8 RICKG

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Posted 14 December 2010 - 05:19 PM

We simply perform ongoing bacteria tests using controlled medium. We swab hands both pre & post washing and then observe the culture. We keep these results as "verification" of our GMP sanitation procedures. This testing medium is avaliable for about $60 for 15 (2-test) people. You could perform the test before washing....then swab after. That will certainly tell you if cold water degrades the hand-washing.

We perform this testing every Quarter....just to "prove" our hand-washing regimen is effective.


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#9 Charles.C

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Posted 14 December 2010 - 08:25 PM

dear All,

As per Inesa's clever find -

Do all food businesses have to provide handwashing facilities for staff?
Yes, all food businesses must provide a basin in food areas for staff to wash their hands. It must have hot and cold running water, soap and suitable equipment for drying hands, such as disposable towels. If unwrapped food is handled in the business, there must be a separate sink for washing food. [The Food Safety (General Food Hygiene) Regulations 1995]


I thought that the new EC jumbo directives had made these 1995 documents obsolete and replaced by [something else]. Apparently not ?

So Tesco win again :thumbdown: Another black mark against un-announced visits presumably. :smile:

Rgds / Charles.C
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#10 SZY

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Posted 14 December 2010 - 10:52 PM

Hello, We recently had a Tesco audit and unfortunatley the hot water tank broke at the hand wash station just before the auditor entered the production area and cold water was only available. The auditor was quiet upset by this as is understandable but maintenance were working on the water heater and once fixed it was promptly put back. One comment the auditor made was that we were breaking the law by only having cold water for hand washing. I have trawled through various customer codes of practise and the BRC and cannot find anything about hot water being a legal requirement. The water tank has broken again today and I have irrate maintenance teams questioning the law. Please can anyone help to confirm that having cold water at hand washing for any period of time is illegal?



In Australia, by law, the hand wash facilities in meat production are provided with warm water between 35 to 46 degrees from a central outlet.
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#11 Inesa

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Posted 15 December 2010 - 01:13 AM

I thought that the new EC jumbo directives had made these 1995 documents obsolete and replaced by [something else]. Apparently not ?


Dear Charles,

you made me suspicious. I looked at my "clever finding" again and saw that it's from Thursday 31 October 2002 ;)
I don't know the old law, but the newest hygiene law is EC 852/2004.


Requirement remained the same:
Annex II-> Chapter 1-> 4. ..."Washbasins for cleaning hands are to be provided with hot and cold running water,..."


regards :)



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#12 Charles.C

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Posted 15 December 2010 - 06:26 AM

Dear Inesa,

The primary UK document now appears to be this –

http://www.legislati...20060014_en.pdf

although there are already numerous amendments applied which visually defeated me (see the link below)–

http://www.food.gov....g/foodhygregeng

To be honest, the introductory explanation / interpretation which contains backward references to older UK regulations and cross-refs to a multitude of current EC directives also defeated me. The document iteslf contains no specific section on Personnel Hygiene as far I could see.
Note that the contents of this document are stated to apply to UK only (part 1, 1.c)

I daresay that somewhere there may be a statement like “personnel hygiene requirements follow EC 852/2004 except ….” but I couldn’t see it.

The FSA have also issued a maze of guidance documents, same comment as per above FSA link

http://www.food.gov....id/fhlguidance/

I also noticed that the EC852/2004 already contains a few zigzags, eg see (III.2.a,e) -

Requirements for movable and/or temporary premises (such as marquees, market stalls, mobile sales vehicles), premises used primarily as a private dwelling-house but where foods are regularly prepared for placing on the market and vending machines

(a) appropriate facilities are to be available to maintain adequate personal hygiene (including facilities for the hygienic washing and drying of hands, hygienic sanitary arrangements and changing facilities);
(e) an adequate supply of hot and/or cold potable water is to be available;

Perhaps not on a volume basis but with respect to (my) perceived risk, this seems (relative to the chunk you previously posted) contrary to logic if RTE.

AFAIK, all these laws are (somehow) potentially overlapped to the Sovereign Rights issue for any country in the EC. I hv no idea how / where the dividing line is placed assuming that a defined procedure exists. :biggrin:

Rgds / Charles.C


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#13 Caddyshack

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Posted 15 December 2010 - 09:12 AM

Tesco Standard



Employee Facilities and Personal Protective Equipment Sect 8.15

Base

Where hand wash facilities are provided, they must have water at a suitable temperature to ensure effective hand washing (e.g. approx 37 0C),

Water temperature should be monitored and recorded. 8.5.2

What good looks like

Water temperature will be suitably controlled via ring main systems or sink specific thermostats.



Sprenger - Hygiene for Management



The temperature of the water used for hand washing is not critical however a temperature of around 35°C to 45°C is recommended as no one likes washing hands in cold water <20°C or hot water >49°C.

Hands should be washed thoroughly in warm water running at around 4-8 litres per minute.




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#14 GMO

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Posted 15 December 2010 - 05:41 PM

Tesco Standard



Employee Facilities and Personal Protective Equipment Sect 8.15

Base

Where hand wash facilities are provided, they must have water at a suitable temperature to ensure effective hand washing (e.g. approx 37 0C),

Water temperature should be monitored and recorded. 8.5.2

What good looks like

Water temperature will be suitably controlled via ring main systems or sink specific thermostats.



Sprenger - Hygiene for Management



The temperature of the water used for hand washing is not critical however a temperature of around 35°C to 45°C is recommended as no one likes washing hands in cold water <20°C or hot water >49°C.

Hands should be washed thoroughly in warm water running at around 4-8 litres per minute.





Certainly that's the ideal; but this was the exception. I'd be interested to hear if your Tesco technologist expected you to stop the lines risking shorts?

Also I asked about the product as I do feel that makes a difference. Are you prepared to divulge?
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#15 Inesa

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Posted 15 December 2010 - 06:43 PM

Dear Inesa,

The primary UK document now appears to be this –

http://www.legislati...20060014_en.pdf

although there are already numerous amendments applied which visually defeated me (see the link below)–

http://www.food.gov....g/foodhygregeng

To be honest, the introductory explanation / interpretation which contains backward references to older UK regulations and cross-refs to a multitude of current EC directives also defeated me. The document iteslf contains no specific section on Personnel Hygiene as far I could see.
Note that the contents of this document are stated to apply to UK only (part 1, 1.c)

I daresay that somewhere there may be a statement like “personnel hygiene requirements follow EC 852/2004 except ….” but I couldn’t see it.

The FSA have also issued a maze of guidance documents, same comment as per above FSA link

http://www.food.gov....id/fhlguidance/

I also noticed that the EC852/2004 already contains a few zigzags, eg see (III.2.a,e) -

Requirements for movable and/or temporary premises (such as marquees, market stalls, mobile sales vehicles), premises used primarily as a private dwelling-house but where foods are regularly prepared for placing on the market and vending machines

(a) appropriate facilities are to be available to maintain adequate personal hygiene (including facilities for the hygienic washing and drying of hands, hygienic sanitary arrangements and changing facilities);
(e) an adequate supply of hot and/or cold potable water is to be available;

Perhaps not on a volume basis but with respect to (my) perceived risk, this seems (relative to the chunk you previously posted) contrary to logic if RTE.

AFAIK, all these laws are (somehow) potentially overlapped to the Sovereign Rights issue for any country in the EC. I hv no idea how / where the dividing line is placed assuming that a defined procedure exists. :biggrin:

Rgds / Charles.C



Dear Charles,

welcome to the club "Defeated by all these laws" Posted Image

Regarding to old British laws from 1995 I found a small explanation in here http://www.food.gov....fo/foodhygknow/
-------------------------------------------------------------------------------

Has any UK legislation been removed because of the new EU legislation?
The Food Safety (General Food Hygiene) Regulations 1995 and the Food Safety (Temperature Control) Regulations 1995 do not apply anymore. Many of the requirements of these regulations are included in the new EU legislation, so this means that what businesses need to do from day to day has not changed very much. The main new requirement is to have 'food safety management procedures' and keep up-to-date records of these.

The Food Hygiene (England) Regulations 2006 provide the framework for the EU legislation to be enforced in England. There are similar regulations in Wales, Scotland and Northern Ireland.

-----------------------------------------------------------------------------------

I think normally everyone should focus more on National guides (all member states have their own Nguides) for EU regulations, or any standard requirements (if company is certified) they are also made in compliance with EU law. Guidelines make things more understandable. As example guides for


Guide to food hygiene and other regulations for the UK meat industry (http://www.food.gov....uidehygienemeat)

A11. An adequate number of washbasins is to be available, suitably located and designated for cleaning hands. Washbasins for cleaning hands are to be provided with hot and cold running water, materials for cleaning hands and for hygienic drying. Where necessary, the facilities for washing food are to be separate from the handwashing facility.852/2004 Annex II Food Premises: Chapter I point 4***

Water Supply - hot and cold water can be supplied through
separate taps, but a mixed supply is preferable. Water
should be at a suitable and comfortable temperature so that
staff are not discouraged from using the facilities provided.
Soap/hand drying etc. – see Chapter 7 (Personal Hygiene).
Food Washing Facilities – separate basins are required for
hand and for food washing - see B3 below.
Where else to look for answers for the questions like in this topic- about if it's illegal to not to have hot water. Posted Image

Another:
I don't understand why people in this topic discussing exact water temperature? Is an auditor ever coming with thermometer and checking hot water temperature???

I'm totaly confused Posted Image

Regards
Inesa

Edited by Inesa, 15 December 2010 - 07:09 PM.

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#16 vlh2020

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Posted 15 December 2010 - 09:07 PM

Does anyone know where to find the specific USA - FDA requirements for hand wash station water temperature and also for location requirements? We are working on SQF certification and are struggleing with the section 5.2.11.3 "Additional hand wash basins shall be provided .....and in a accessible locations throughout food handling and processing areas as required". Who defines "as required". Any guidance on this would be greatly appreciated.


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#17 Charles.C

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Posted 15 December 2010 - 11:07 PM

Dear Inesa,

Very well spotted :thumbup: .

Indeed the MIG is an amazing manual. Certainly one of the most ambitious attempts I hv ever seen to provide a detailed working book for its users. It is also fortunate (or perhaps not?) in that its subject area is singled out in the EC regs for intensive detailing.

It is sort of off-topic in this thread however the HACCP section is illustrative of the determination of the authors to cover every aspect of the processing pattern. This ultimately causes some real problems in the presented text IMHO. Some of the discussion included in the manual in the micro. criteria section suggest that for certain aspects there were outright disagreements between the members on how to proceed.

As examples of resulting practical problems, I include 2 extracts from the model HACCP plan and carcass monitoring procedure respectively. The obvious question regarding the stated monitoring procedure in 1st example is “How?” The absence of a corrective action is perhaps an acknowledgement of the problem faced ?. In the second case, I wonder what (operationally) happens if the progressive criteria are ultimately failed.

Attached File  salmonella.png   27.04KB   36 downloads

Attached File  salmonella2.png   30.53KB   31 downloads

A related aspect to the above is the highly debated use of regulatory CCPs within the famous USA / pathogen reduction scheme (and also in the MIG though less emphasised.)

Rgds / Charles.C


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#18 Simon

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Posted 02 May 2012 - 11:20 AM

If the hot water tank is a distance away from the sink then there will be an amount of cold water always in the pipework before the water runs warm. In this case is it acceptable to have an instruction sign at the sinks stating.

"Please allow water to run for a few seconds until warm."

Or do you have to rebuild the factory?

By the way what are the requirements in BRC / SQF / FSSC, IFS etc. on this subject?

Thanks,
Simon


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#19 stsqf

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Posted 03 May 2012 - 03:42 PM

SQF states it as "a potable water supply at an appropriate temperature"... no specified termperatures for being "appropriate".


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#20 Tim1

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Posted 03 May 2012 - 04:38 PM

I agree with all the statements above and tend to agree that there isn't clearly stated as to temps. The code states warm water and when our auditor had came through he checked everyone of our sinks for warm water. Another thing that he stated was you had about 10 secs to get it warm to stay in compliance. So in turn, we had to add numerous water heaters through our facility to accomplish this. Hope this helps. :rolleyes:


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