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13.3.2 Hand Washing - conformance for forklift drivers

Hand Washing forklift sqf 13.3.2

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#1 zac2944

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Posted 13 November 2013 - 07:57 PM

Hey Gang.  Long time lurker here with my first post.  :cool:  I could use some advice for conforming to 13.3.2 Hand Washing in the SQF standard.

 

My company makes flexible packaging material (films, laminations, foils, etc.) that we sell to food packers who will form a pouch from our material and fill or use as lid stock.  We have been certified to AIB for many years, but are now going for SQF in Q2 2014.  Some of the requirements for Hand Washing are new to us and we have gaps to close, and I could use some help understanding the requirement and how to conform.

 

In particular, 13.3.2.4.i says that "hands shall be washed on entering product contact areas".  I plan to install hand washing stations at all employee entrances to production area.  This will take care of personnel when entering production area and whenever a wash is needed after entry, but I'm not sure what to do about my forklift drivers who may need to go outside. 

 

We have two ground level overhead doors at my dock that we use regularly anytime a forlift needs to be outside.  We have some production waste (hot plastic) in steel bins that goes outside by forklift to cool and is then brought back in to the dock once cool and loaded onto a trailer for recycling.  There are other ocasional reasons like side loading maintenance items or new equiment off of a fladbed. 

 

Does this qualify as my forklift driver "entering product contact areas" when he comes back in to the plant?  I consider my dock as a GMP area. The forklifts are kept clean and the driver never gets off the truck.  Do I need a hand wash station next to my dock?  Getting on/off truck to wash hands will kill me logistically.

 

Do keep in mind that I don't have any "food" in my plant.  Just paper/poly film/poly beads/foil/ink/adhesives/etc.  Equipment is large printing presses, laminators, extruders, unwinds/rewinds, slitters, etc.  We are not a "no-risk", but certainly a low risk operation.


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#2 zac2944

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Posted 21 November 2013 - 01:31 PM

Bump.

 

Anyone?  Gotta be someone out there who's been through this with SQF and Hand Washing requirements.  Help a brother out.


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#3 Setanta

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Posted 21 November 2013 - 03:10 PM

While I have been through SQF and Hand Washing requirements, doing so with packaging is a bit out of my realm. 

 

Your packaging is food grade, correct?  If so, you need to almost treat it as food. I think I would count the warehouse/dock area as GMP and the production area as food safe. 

 

Can you restrict one or two forklifts to being outside only? The rest of the lifts could stay inside and bring production materials to the line.  This would reduce the risk of tracking something in. And, if someone can't drive from outside to the production area, it makes it easier to stop and wash hands.

 

It is tough for me to visualize your facility, just please take this with a grain of salt.

 

<food grade of course!>

 

Setanta


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#4 Charles.C

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Posted 21 November 2013 - 04:49 PM

Dear zac,

 

Apologies but i completely missed yr OP.

 

Not in packaging myself but I presume module 27 is relevant section.

 

Unfortunately i suspect there are very few people here who are using the SQF packaging standard (after looking at the list of posts in the SQF packaging forum sector)..

 

SQF appear to regard all packaging materials as low risk. Interesting.

 

The list in 7.1 / 13.3.2 looks a straight transcription from 11.3.2 for food.products. Sort of quick fix maybe. Tricky.

 

"GMP" is a rather dodgy route for evasions IMO. :smile:

 

One gets analogous problems for workers receiving low risk, wet,  food raw materials from trucks. No personal experience with SQF but never met such a restrictive interpretation as you are suggesting elsewhere. Could also involve definition of manufacturing area, eg existing segregations.

 

Sadly no relevant guidance as yet. The sqf2000 packaging edition seems of no help.

 

Needs some practical experience / input.

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#5 zac2944

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Posted 21 November 2013 - 05:34 PM

Thanks for the replies fellas.

 

My packaging is food grade.  Having dedicated fork trucks for outside/inside would be difficult and expensive.  I've got no secure place to store the outside truck, and it will be tough for me to justify the cost of a dedicated outside truck that would see very little use.

 

I believe the intent of the requirement is to ensure hands are clean when they are working with raws/wip/finished.  Make everyone wash hands before entering work areas. If I leave this work area on a for truck, go outside, then come back in, the cleanliness of my hands has not changed.  The driver does not get off the truck.  If he did get his hands dirty per GMPs he would go wash his hands, but I don't want to have to put a sink next to each over head door just for this rare instance.

 

I'm trying to understand how the auditor will interpret this.  Anyone with a food warehouse with ground level docks must have this same issue. 


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#6 ncorliss

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Posted 09 December 2013 - 07:28 PM

Hi Zac,

 

Our business is considered food packaging. One question, is your food contact product packaged in additional barriers to prevent contamination? Our product is, and we require fork truck operators to wash hands when entering the production area or handling unpackaged finished goods (rare). We have been SQF certified for 2 years and this hasn't come up yet. If you aren't going to do it, I suggest this is at least documented through your risk assessment to justify your decision. The way I look at it though, it wouldn't hurt to make it a standard practice to wash hands at any time entering the facility, just extra work from your warehouse folk.


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#7 paolos

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Posted 09 December 2013 - 07:57 PM

You really need to assess the risk this poses to your process.  For example:  Does the forklift operator get off the forklift when outside of the warehouse he just exited, handle any materials that would pose a risk if he were to re-enter the warehouse and then handle your product?  Mist forklift operators do not get off their forklift until they are back inside BUT as was mentioned in a previous post, it is very difficult to comment further than this unless I could see for myself what occurs.


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#8 Simon

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Posted 12 December 2013 - 08:39 PM

Yep I agree, risk assess (documented) and if they're really not touching any product then the risk must be very, very low, so hand washing not required.


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#9 zac2944

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Posted 09 January 2014 - 08:53 PM

Yep I agree, risk assess (documented) and if they're really not touching any product then the risk must be very, very low, so hand washing not required.

 

 

Hi Zac,

 

Our business is considered food packaging. One question, is your food contact product packaged in additional barriers to prevent contamination? Our product is, and we require fork truck operators to wash hands when entering the production area or handling unpackaged finished goods (rare). We have been SQF certified for 2 years and this hasn't come up yet. If you aren't going to do it, I suggest this is at least documented through your risk assessment to justify your decision. The way I look at it though, it wouldn't hurt to make it a standard practice to wash hands at any time entering the facility, just extra work from your warehouse folk.

 

 

Yep I agree, risk assess (documented) and if they're really not touching any product then the risk must be very, very low, so hand washing not required.

 

Thanks for the advice guys.  My fork lift operators typically do not need to get off the fork lift to load/unload.  We train all employees that they must wash hands when entering manufacturing area, or any time hands are dirty. 

 

My main concern here is the requirement to have hand washing stations at all point of entry.  I don't want to install a hand washing station at this dock since it would rarely be used and I don't have a place to put one.   I've got materials on order and I'm having a few nice stations built at main employees entrances, but this ground level dock is an exception.  It is not used for employee entrance/exit, but still my fork truck driver may go in/out a few times per day.   

 

Should this risk assess be done in my HACCP Plan or a separate document?  I have a section in my Process Hazard Analysis in HACCP Plan for shipping/receiving step; should I just include this potential hazard there?  My hazard control would be that my driver doesn't get off truck, and if so follows GMPs and washes hands at nearest station if dirty.


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#10 Charles.C

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Posted 10 January 2014 - 02:51 AM

Dear zac,

 

Best advice should be from SQF users/auditees which I am not.

 

I would imagine the primary risk you need to consider is what touches the hands of yr drivers externally and where do these hands go after the forklift returns. Particularly if you have no specific forklift requirement (?) for a subsequent hand / glove washing anywhere else ("if dirty" sound a little ISOish).

 

The point is that risk assessments (particularly if textually visible) have to make practical sense to a 3rd party also.

 

IMfoodEX, forklift container loading operations rarely have proximate handwashing stations since the personnel are not able to realistically contact food related surfaces without passing through a control step. But my food experience is also that forklift drivers are somewhat analogous to engineers and are therefore likely to commit sanitary blunders at the most inconvenient times (glass beer bottle resting against the outside door springs to mind). :smile:

 

It depends on the overall format of yr haccp plan / specific SQF-checking list but personally I would refrain from emphasising this element unless you are confident of yr defensive position. GMP prerequsites ?

 

Rgds / Charles.C


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Charles.C


#11 SQFconsultant

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Posted 30 January 2014 - 03:50 AM

I don't see an issue with their hands. The issue I see is with  your forklifts going outside and then back into the plant. As an Auditor I may be looking for hand washing stations and hand sanitizer but the red flag might go up watching a forklift exit the building and then come back in -- as in what is it picking up outside from the ground/pavement and bringing back in. Having seen firsthand an issue with contamination via an indoor/outdoor forklift in a plant that is where my primary concern would be. 


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#12 zee

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Posted 30 January 2014 - 03:43 PM

Thanks for the advice guys.  My fork lift operators typically do not need to get off the fork lift to load/unload.  We train all employees that they must wash hands when entering manufacturing area, or any time hands are dirty. 

 

My main concern here is the requirement to have hand washing stations at all point of entry.  I don't want to install a hand washing station at this dock since it would rarely be used and I don't have a place to put one.   I've got materials on order and I'm having a few nice stations built at main employees entrances, but this ground level dock is an exception.  It is not used for employee entrance/exit, but still my fork truck driver may go in/out a few times per day.   

 

Should this risk assess be done in my HACCP Plan or a separate document?  I have a section in my Process Hazard Analysis in HACCP Plan for shipping/receiving step; should I just include this potential hazard there?  My hazard control would be that my driver doesn't get off truck, and if so follows GMPs and washes hands at nearest station if dirty.

I would do my risk analysis on a separate document.  Keep your HACCP as simple as possible.  As far as the issue that people have brought up with your forklifts going in and out and bringing contaminates.  You could do the same, ie environmental testing, is your facility a wet one where forklifts tires could spin and spread bacteria (I'm assuming not) 

Forklift drivers in my facility, wash their hands when returning from breaks and entering the packaging area, also if for some instance (very rare) they were to handle a food contact surface.


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