22 replies to this topic

[Frank88maurice]

Hi all,

 

We recently went through our BRC audit and made an A! Thank goodness!

 

one of the recommendation from auditor was that we should have signs on our sinks,

 

if is for hand washing only or for utensils,

 

But some of them are used for both hand washing and cleaning utensils,

 

will it be okay to sign it as

 

Hand-washing and utensils cleaning sink

 

?

 

I could find anything on the BRC regarding this.

 

my Boss told me to do some research on it but I thought i would ask you all!

 

thanks in advance.

[zac2944]

Not sure about BRC, but for SQF and in general it is a bad idea to have mixed use sinks.  Hand washing sinks are for hand washing only in my experience.  I had an issue with this in my lunch room.  We were washing coffee pots and hands in the same sink.  Not a best practice.  Someone else with BRC knowledge will have to chime in with a better interpretation of the rules.

[Charles.C]

Dear Frankmaurice,

 

IMO you are a contender for the luckiest "A" of the year.

 

Possibly combined with finding one of the most hospitable auditors around.

 

is it possible that yr Boss was being ironic ?.

 

i suspect that  textbook references for implementation of such dual sink applications in food production will be highly elusive.

 

Rgds / Charles.C

[KTD]

Dear Frank88maurice -

 

     Several years ago, USDA FSIS had a regulation that explictly required the separation and labeling of hand and utensil washing sinks...it was withdrawn some time back. If your auditor has a background in meat/poultry production in the US, that may be where he is coming from.

 

Charles -

 

    Can you elaborate on the concerns for mixed washing sinks? For the life of me, I cannot see the issues. Hands are washed above the sink itself, so no contact there. If utensils are physically set onto the sink surface during cleaning, they will still have to be sanitized before use. Typically, utensil washing does not invovle sinks full of soapy water, as in a food preparation/restaurant environment. zac2944 mentioned stated '...Not a best practice.' - not being a best practice in and of itself does not make it wrong.

[Charles.C]

Dear KTD,

 

Perhaps it’s a cultural issue. At home, I would only wash my (filthy?) hands in the kitchen sink in an emergency. I have to say that I have never seen a combined system as i think being discussed in any factory I hv ever visited. Certainly space-saving though. I deduce you are suggesting it is not unusual in USA. So SQF/BRC presumably have no objection. Interesting.

 

It does seem illogical to me to deliberately pre-contaminate an area about to be used for cleaning purposes. Or perhaps there is a third, middle, cleaning/sanitisation step after cleaning the hands but before starting on the utensils? It may be that we have a different visualisation of the processes involved.

 

Regardless, if you can point me to a reference which includes such a combined arrangement as an acceptable production option, I will reconsider my instinctive abhorrence.

.

I guess the same principle also applies to gloves ?

 

Some further inputs might be useful.

 

Rgds / Charles.C

[SQFconsultant]

Consider yourself lucky that you landed an "A"

 

BRC requires signage at hand-washing sinks and auditor should not have gone into a consulting role by advising you about the signs; the auditor should have written it up.

 

If your auditor made more than that recommendation you should take a close look at what the recommendations were, you may not be that lucky the 2nd time around.

 

Hand washing sinks are for washing hands and that's it - it's a CS item.

[KTD]

Dear Charles.C -

     I don't have any references. In my experience in the US raw poultry industry, sinks are typically not used to hold parts. The parts are generally cleaned with soap/cleaning chemical and placed in a sanitary container. It may be that when I think of sinks, I am thinking of the ones that are located in the processing area and only used in instances of incidental hand contamination. I agree that the sinks used by all plant personnel repeatedly use throughout the day every time they come in the plant are likely to be dirtier.

     I guess I am trying to determine the 'ick' factor difference between washing dirty hands and washing dirty parts.

[Douglas NIcoll]

US Food Code states that are used for cleaning utensils cannot be supplied (used) for hand washing.

[KTD]

Douglas -

     This is where US regulations don't mesh, There was a similar regulation by USDA FSIS applicable to covered meat & poultry operations. It was removed several years ago - I have not seen anything specific about the reason(s).

[DuckMan]

Interesting topic,

 

Well I can testify as far as the health code for the state of Texas is concerned, all hand sinks must be labeled as such for one specific reason, hand sinks require certain attributes to qualify as a proper hand sink such as; soap, paper towels, and water between 98-110 F.  A sink intended to wash utensils such as a the typical three chamber sink will not have hand soap or paper towels and the water may range quite hotter. If the environment of the sink does not strongly encourage hand washing with all above attributes and signage encouraging hand washing at proper times, then management has failed to establish the correct culture and mindset for employees to follow true cGMPs. Remember, its what your employees on the floor are doing when nobody is watching that determines how successful you have been at establishing a environment enriched with respect toward cGMPs.

[Charles.C]

Dear Duckman,

 

Thks for the input.

 

One query, was this quote for a specific industry, a general GMP set of food processing regulations or ?

 

Rgds / Charles.C

[DuckMan]

Amigo Charles,

 

I probably should have thrown in a "IMHO" in there somewhere

I guess it was an attempt to show that once in the mindset of questioning some entities methodologies (maybe you would agree) that when someone TELLS you that they use that sink for the washing of hands and that it is a "hand-wash sink" but upon further inspection your realize that the sink is completely unfit for such and is inadequate due to lack of hot water or being obstructed by utensils, one may be inclined to believe they are being lied to.....and that in-fact management has not established proper hand-washing procedures

 

Another example, If I was told during the audit of a facility,  (and I have been) that the rubber gloves being used (to prevent bare hand contact) are stored 30 feet away from their work station or in another manner that is an ergonomic nightmare, I know that due to the non-stop demands of production that employee will most definitely not be changing his/her gloves when necessary. I know that the demands of production will put the zap on even the most diligent of employees in regard to following cGMPs, and I'm sure it is something we have all witnessed.

[FBQFS01]

This is an very interesting topic. Our BRC audit is tomorrow and after reading this, i just realised that we don't have any handwashing signs to indicate that this is not for utensils. We do have colleagues in the US and they have made the same remark.

let's see what the audit says tomorrow

Fiona

[Charles.C]

Dear DuckMan,

 

Thks for the clarification from the Lone Star State.

 

I think you missed yr vocation. You seem to have the necessary attributes of automatic disbelief  to be a shoo-in as an  auditor.

 

Rgds / Charles.C

[Charles.C]

Dear KTD,

 

Unfortunately the OP provided no context for the original query as to the specific sink involved.

 

Here are the only (slightly reformatted) direct refs to “handwash” that I could see in BRC6 –

 

4.8.4

>>>> hand-washing during the changing procedure shall be incorporated to prevent contamination of the clean protective clothing

>>>  on entry to high-care areas, hand-washing and disinfection shall be provided.

 

4.8.5

>>>  hand-washing during the changing procedure shall be incorporated to prevent contamination of the clean protective clothing

>>> on entry to high-risk areas, hand-washing and disinfection shall be provided

 

4.8.6

Suitable and sufficient hand-washing facilities shall be provided at access to, and at other appropriate points within, production areas. Such hand-wash facilities shall provide as a minimum –

 

(1) sufficient quantity of water at a suitable temperature

(2) liquid soap

(3) single use towels or suitably designed and located air driers

(4) water taps with hand-free operation

(5) advisory signs to prompt hand-washing.

 

4.8.7

Toilets shall be adequately segregated and shall not open directly into production, packing and storage areas. Toilets shall be provided with hand-washing facilities comprising:

(1) basins with soap and water at a suitable temperature

(2) adequate hand-drying facilities

(3)advisory signs to prompt hand-washing.

Where hand-washing facilities within toilet facilities are the only facilities provided before re-entering production, the requirements of 4.8.6 shall apply and signs shall be in place to direct people to hand-wash facilities before entering production.

 

 

It appears to me that the only (non-icky  ) contender for a shared (hand/utensil) usage might be  4.8.6 , and specifically for “within”

IMO, Note (5) appears (by “omission”) to exclude a shared function of the type under discussion (and implicitly to also exclude utensil-cleaning in the "process" arena altogether).

 

One (production) hygiene comment I found to justify  not implementing shared handwash/X sinks is here –

 handwashing.png   84.87KB   2 downloads

 

Not exactly definitive but not implausible IMO.

 

I could not find any examples  “recommending” shared options however the previous attachment implies that their occurrence is nonetheless “frequent” as you originally intimated.

Icky or otherwise, approved or not, such is life in the fast lane I suppose. 

 

 

Rgds / Charles

[Azhar Sayyed]

Several years ago, USDA FSIS had a regulation that explictly required the separation and labeling of hand and utensil washing sinks...it was withdrawn some time back. If your auditor has a background in meat/poultry production in the US, that may be where he is coming from.

[Charles.C]

Several years ago, USDA FSIS had a regulation that explictly required the separation and labeling of hand and utensil washing sinks...it was withdrawn some time back. If your auditor has a background in meat/poultry production in the US, that may be where he is coming from.

Dear Azhar Sayyed,

 

Please refer Post #4 _

 

Several years ago, USDA FSIS had a regulation that explictly required the separation and labeling of hand and utensil washing sinks...it was withdrawn some time back. If your auditor has a background in meat/poultry production in the US, that may be where he is coming from

 

????? !

 

Rgds / Charles.C

[Zahn.R]

It depends on the risk level of the food you are producing I would think.  It would be best to do a food safety risk assessment on the contamination that can take place.  If you have a high risk then you will probable have to do something about it. 

[Bean Queen]

Sinks used for specific purposes are well defined according to the Food Code {FDA)

Those use for food contact, utensil, food preparation, or service sinks.

Handwashing sinks

Utility/Mop Sinks

Each with specific requirements

[Charles.C]

Sinks used for specific purposes are well defined according to the Food Code {FDA)

Those use for food contact, utensil, food preparation, or service sinks.

Handwashing sinks

Utility/Mop Sinks

Each with specific requirements

 

Dear Bean Queen,

 

Thks for the comments.

 

Also see posts 4,7,8,9,15.

 

A potential difficulty is that the OP never revealed the nature of the business.

 

Does USDA reference the FDA (Retail?) Food Code within its legislatory (or any) control activities ? Probably not I suspect but equally unconfirmed up to now AFAIK.

 

And then you have State regulations.

 

Rgds / Charles.C

[KTD]

Charles -

 

I also do not know the regulatory agency over the OP; however, for plants under USDA FSIS inspection, their own regulations are the ones that count - except in those rare instances where they specifically reference another agency's...usually FDA. There used to be a USDA regulation requiring separate identified sinks, but it was withdrawn when USDA embraced HACCP - the plants were then allowed to conduct their own risk analysis.

 

KTD

[fgjuadi]

Dear KTD,

 

Perhaps it’s a cultural issue. At home, I would only wash my (filthy?) hands in the kitchen sink in an emergency.

 

What if your bathroom is occupied and the kitchen sink is empty and you're REALLY drunk?  I mean, it's culturally acceptable to wash hands / vomit / pee in it then, right?  I'm pretty sure that's OK, even if you're not at your house, but at your sister's house, or bestest friend's house, or at a total stranger's house. Not okay at houses of people you wan tto continue to talk to but aren't emotionally bound forever with.

 

We separate them in the factory.  It's actually an efficieny problem because the hand washing sink is so far from the main workstation.  We have plans to move the workstation equipment sink area and use the plumbing for a handwash station!  Hooray! It was too close for comfort anyway!

-Majors

[Charles.C]

Dear magenta_m,

 

 

Perhaps a wee bit too much information.    

 

Reminded me of the Bridesmaids/food poisoning scene ? (warning to the sensitive - avoid when eating !)

 

Rgds / Charles.C