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Room Entry Procedures - Medium Care

Hand washing Changing procedure

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#1 harrypotterOZ

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Posted 11 March 2015 - 06:18 AM

Hello Everyone,

 

As required by our Customers below is the required changing or Medium care room entry procedure:

Personnel must enter Medium areas following the below changing and hand washing procedure.

The procedure must follow the order below:

1. Put in ear plugs and surgical masks (where required)

2. Put on a clean hair covering (if not already worn from Base area)

3. Remove street shoes and put on site captive shoes (if captive shoes are not already worn from Base area)

4. Wash, dry, and sanitise hands

5. Put on knee-length coats

6. Enter Medium area

7. Wash, dry, and sanitise hands

8. Put on disposable clothing at work station Hands must be washed, dried, and sanitised following any adjustment to hair or beard covers.

On exit from the Medium area the Medium area coat must be removed.

 

We do baked goods - pie, quiches, cakes etc.

 

The issue is that we do not have a hand wash sink to comply by point 4. Instead, we follow 1 to 3, then sanitise (Only) and put on coats, enter the area and wash, dry, sanitise hands. 

 

Now the customer is asking us either to meet their requirements  (install a hand wash unit) or to provide a risk assessment? 

 

Could some one please help me out here - i have no idea how to justify/risk assess this situation.. 

 

Thanks heaps


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#2 Charles.C

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Posted 11 March 2015 - 07:46 AM

Dear harrypotteroz,

 

The relative risk logic of yr list of steps depends on the process layout / objectives of the actions.

 

AFAIK, Medium care is not a frequently used term in EC.  Low/high are more common. The only use I know of "medium" utilizes this term as a control stage between low/high processes. Ozland may be different. :smile:

 

If above corresponds to yr own situation I suggest you refer yr customer to a standard reference on hygienic factory design, eg Holah, specifically to this extract which appears to remove yr problem –

 

Attached File  medium care area.doc   95.5KB   65 downloads

 

If the above layout not applicable, it may be necessary for you to elaborate your layout.

 

Rgds / Charles.C


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Charles.C


#3 harrypotterOZ

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Posted 11 March 2015 - 09:20 PM

Thanks Charles.

 

As per our supplier standards (vch is almost a ditto of TESCO) processing areas are divided into: Base, Medium & High care areas. 

 

Base

Base areas are those where the raw materials, packaging, and finished products are handled and / or stored as fully enclosed or packaged. Example: An ingredients warehouse (ambient or temperature controlled) is likely to be a Base area. The ingredients are sealed from contaminants.

Medium

Medium requirements shall be applicable to products that support the growth of microorganisms but a further kill step is applied by the consumer such as raw meat and poultry, or for products which do not support the growth of pathogens either due to pH control or water activity.

These requirements specifically apply to areas of the site where food is OPEN or EXPOSED to contamination, therefore increasing the risk in these areas. Associated areas or processes e.g. utensil washing / storage, de-boxing, handling food contact packaging, equipment used for filling containers, etc. shall also be considered Medium areas.

High

These requirements apply to all areas that are identified as handling or processing high-care products.

The elements classified as High shall be applicable, in addition to the relevant Base and Medium requirements.

 

 

IMO, the only risk would be someone coming in with a heavy load of microbes on their hands, use sanitiser (wont be quite effective due to the high load) and then put on their coats - thus contaminating their coats.

 

Any more ideas..?

 

If nothing works out, might end up getting a saniflo sink - though we dont prefer it due to space constraints.

 

Cheers,

Anna


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#4 Charles.C

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Posted 12 March 2015 - 02:18 AM

Dear harrypotteroz,

 

Thks yr comments.

The Tesco logic is specific to them. And presumably their clones. For example (standard,5th ed) this Pythonesque beauty -

 


To ensure that our requirements for some sectors of the industry e.g. ready-to-eat chilled foods, are not overly burdensome on other sectors, each  clause of the TFMS has been  given  one of
four classifications i.e.  Base, Medium, High & Aspiration. The first 3 classifications relate to areas  of  a  factory  and  the  controls  required.  They  must  not  be  confused  with  common  food
industry  terminology  e.g.  Base  must  not  be  used  to  describe  ‘Low  Risk.’    The  requirements detailed for both Base & Medium may well apply in a Low Risk environment (see glossary).  

 

(Nonetheless,  if it works for them ....)

 

A generic RA is possible but needs details on the process/factory layout /product. 

 

Personally, I would suggest it may not be too cost-effective to (RA) challenge them over one sink/accoutrements. Not to mention the probable head-banging to follow. :smile:

 

My own familiarity (not baking/not Tesco-related) consists of (a) an entry section >  (b) a Low risk area > © a high risk area.

a,b,c are physically separated

 

handwashing/sanitising points are, more or less -

 

(1) within body of (a)

(2) interface (a,b)(just prior) to (b)

(3) within body of (b)

(4) interface (bc)(just prior to ©

(5) within body of ©

 

IMEX, the most (risk) disputed step(s) is 2. regarding necessity or location and 4. regarding location. Local regulators have it as shown on their checklist. So be it. :smile:

Sometimes it's nice to have a QA-validated excuse to avoid hassle.

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#5 Madam A. D-tor

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Posted 12 March 2015 - 07:00 AM

 

IMO, the only risk would be someone coming in with a heavy load of microbes on their hands, use sanitiser (wont be quite effective due to the high load) and then put on their coats - thus contaminating their coats.

 

Any more ideas..?

 

 

 

Dear Anna,

 

This is also the only relevant thing I can come up with.

There might be some physical thing from ears and hairs and socks, but I think it is hard to transfer this with your hand on your coat without noticing.

 

Are their in your 'medium care' area any transfer possibilities from coat to area or from coat to product. Might be transferred via hands.

Perhaps your workers use disposable aprons and the risk for cross contamination is very low.

You can use this information in your risk assessment.

 

On other hand, if it is not possible to place a sink for hand washing, is it perhaps possible that you have 1 worker (or more) with washed hands, that opened the coats and hold them for his/her colleagues, so the other workers can put on the coats without actual touching the coat.

Hmm. I think it will be the same space as a sink.

 

Sorry. No other ideas.


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Madam A. D-tor

#6 harrypotterOZ

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Posted 13 March 2015 - 04:24 AM

Thanks again Charles. We are pushing to get a sink too - tho the management is a bit resistant. It better to comply with easier clauses than do a risk assessment :)

 

Madam A D-tor... we do use disposable apron but never actually thought in that angle. Clever!! Will suggest the idea to the supplier team and hopefully they can grant us an exemption until we get the sink up and going. Thanks heaps!


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#7 Madam A. D-tor

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Posted 13 March 2015 - 06:18 AM

good luck!


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Madam A. D-tor





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