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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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