14 replies to this topic

[aps]

Hi

 

I know its wrong and you will get picked up on an audit for GMP but why when you have used a squeegee on the floor and its not hung after us and lent on the wall but still in contact with the floor, why is this a non conformance?

 

cheers

[Charles.C]

Hi

 

I know its wrong and you will get picked up on an audit for GMP but why when you have used a squeegee on the floor and its not hung after us and lent on the wall but still in contact with the floor, why is this a non conformance?

 

cheers

 

Hi aps,

 

Perhaps it was a NC against GMP ? Location ? product ? process ? Opportunity for cross-contamination ? SOP states will be hung up ? Poor lunch for auditor ?

[karina.j]

Hi

 

from BRC interpretation/requirements from Standard website

 

(...) They must also be stored hygienically and in a manner that prevents contamination (e.g. not stored in contact with the floor).

 

as this is general assumption so might be treated as non conformance

[JohnWheat]

Agree with Charles - all/any of the above. An old adage on may standards is "Say what you do, do what you say". So don't state that line workers will wear gold hats but you give them Red! I know a daft example but im sure you get my meaning....... I hope.

[JohnWheat]

And Karina :)

[aps]

Thanks...... I understand the points and the reason being but playing devils advocate if they have just been used on the floor, why cant they stay in contact with the floor

 

cheers 

[RMAV]

It's not good practice.  My theory is there is projecting going on, from one type of plant to another.  In a RTE meat plant this would be a huge no-no and a big risk.  In a bottling plant making shelf-stable drinks where it's almost entirely enclosed it's a much different risk, i.e. very low.  But from our meat experience, we get it in our head that it's a big no-no, then project it onto the low risk facility.

[Mulan1010]

I agree with RMAV, it does depend on your environment.  We have a wet environment so we do not hang ours up afterwards because once it has been used then you are now just dripping down the wall and onto the floor.  We place them in a designated container with sanitizer in it.  

 

I don't know if this is the reasoning for the code or not but when I was in training years ago before the code, my trainer told me that all items must have a designated storage location so it does not end up somewhere it shouldn't (food safety), so it is not left in a way that it could become a tripping or falling hazard (personal safety) and so that everyone knows where to go to get it (good work environment).  

[teresa gonçalves]

 

Hi

 

from BRC interpretation/requirements from Standard website

 

(...) They must also be stored hygienically and in a manner that prevents contamination (e.g. not stored in contact with the floor).

 

as this is general assumption so might be treated as non conformance

 

Hello Mrs Karina, J, I agree with your answer, of course that we have a referencial like BRC that specifies what to do, but we must to think for ourselves, if we want our space cleaned and/or sanitezed we must provide it with best practices, which I mean, if we clean with mops or others cleaning tools, so we must keep this materials and tools cleaned or sanitezed so that not contamine in futur our operations; so it should be washed, cleaned and well dried (well dry and ventilated) so that couldn´t develop mold or other type of futur contamination to our plants or factories. The best way is to hang them after washed. And also to keep our space free for physical hazards to workers, a safety issue for workers to not provoque accidents.

[RMAV]

"...my trainer told me that all items must have a designated storage location so it does not end up somewhere it shouldn't (food safety), so it is not left in a way that it could become a tripping or falling hazard (personal safety) and so that everyone knows where to go to get it (good work environment).  

You know what? That's just good ole-fashioned good advice.  I was caught up in the technicalities and here you come rescuing me, bringing us back to the fundamentals. 

[Charles.C]

Hi aps,

 

Focussing on the NC,

 

As far as I understand, the BRC7 standard makes no mention of this "suspension" requirement.

 

Afaik, the content within the BRC Interpretation Guidelines is not, in itself, a valid reason for the issuance of a NC. If such material were free to download, my opinion might be different.

 

Offhand, i do not recall seeing this feature being routinely stipulated in general GMP texts, eg from 21cfr 110  -

 

 Cleaning and sanitizing of utensils and  equipment  shall  be  conducted  in  a  manner  that protects  against  contamination  of  food,  food-contact surfaces, or food-packaging materials.

  

I agree with the micro. logic for enabling food contact surfaces to fully dry after cleaning/sanitizing but i am less convinced for present item although maybe depending on product / process / layout, etc.

 

If a risk assessment regarding your implemented procedure, ie non-suspension, results in a negligible risk of cross-contamination,  I think  the NC could be challenged.

 

Some organisations may have specific requirements in relation to other contexts, for example, SOPs concerning the reprocessing of  product dropped onto the floor.

[CMHeywood]

I work for a company that makes flexible packaging for food products.

 

Our food customers that come to our plant to do audits have a mindset (paradigms) that is derived from working in an environment where there is water and food readily available to support microbial growth.

 

Their expectation has been that we do let any brooms, mops, etc sit on the floor.  If any of these sit on the floor, especially if sitting in a pool of water, likely will pick up microbial contamination that will be spread the next time the they are used.

 

We even had one food customer who said during an audit that we had to store brooms and mops no higher than knee level.  The explanation was that they wanted us to avoid a situation where an employee would brush against the broom or mop, pick up some sort of contamination, and then possibly transfer it into a machine or product.

[Charles.C]

Hi CM Heywood,

 

Thks for Interesting comments. i suppose paranoia could be a customer-related hazard.

 

I have mainly worked in a permanently wet food environment.

 

My experience has been the  exact opposite to which you refer.

 

Customers / 2nd / 3rd party audit officials have never expressed any significant degree of interest on the stored height of floor cleaning equipment. Particularly in comparison to say containers used for food transfer. This has included both RTE and non-RTE products.

 

I wonder if the mindset you refer is a spin-off from some anti-listeria guideline perhaps ?

[Niranjan]

I am agreed and also i think, needs to dry quickly to prevent bacteria multiplication 

[Ryan M.]

Every place I've been in we have a designated area for mops and either hang them to dry, or leave them in the mop bucket with sanitizer.  Mops do a great job in transferring bacteria and pathogens to different locations in the facility that may not be transferred.

 

My current facility they are a one time use because we don't have a good way to clean / sanitize them after use and they get very, very, very soiled when used.