10 replies to this topic

[mambo]

All,

I recently joined a snack manufacturing facility. Great place with SQF Level 2 certification and strict adherence to cGMPs. One of the operations is processing of a cheese based cream ( mixing of cheese and other ingredients). The cream is is used as a filling. Processing takes place in a temperature controlled room to minimize the possibility of time-temperature abuse for the milk-based ingredients.  Product is frozen afterwards.

 

We treat this production room as ''high risk''. As a result, shoe covers are worn by all employees before entering the room. Been asked by the COO to carry out a risk assessment and advise him on the issue of shoe covers. Are they necessary? Employees have no company supplied foot wear and there are no door foaming units to sanitize shoes. We mainly operate in a 'dry' environment like Bakeries. 

 

In my assessment, the shoe covers have no significant bearing on the safety of the food products. I would like to offer the best advice from a food safety angle. My submission will be taken seriously by the Company.

 

What are your thought? 

 

Thank you.

Mambo.

 

 

[Dr.Khan]

Yes  I agree, there is no need to have shoe covers in the process environment as you described it.

 

Regards

Humaid Khan

MD Halal International Services 

[SQFconsultant]

Have never seen any benefit for shoe covers.

[Charles.C]

Hi mambo,

 

A risk assessment requires evaluation of the possible hazards and determining whether any are significant.

 

I anticipate yr query primarily relates to cross-contamination hazards involving transmission via the floor ?

 

These will relate to yr specific layout, items handled, traffic flows, process stages, environment, etc etc.

 

IMO impossible to predict further without such knowledge.

 

I deduce yr product is RTE, regulatory possibilities of location unknown.

 

Obvious potential hazards in some scenarios wud be micro. pathogens such as L.monocytogenes.

 

You may get useful feedback by posting yr own risk assessment.

.

[JohnWheat]

Low to high risk cross contamination should be considered and risk assessed.

• What footwear being worn in low risk area
• Is this footwear swabbed at any time to check for micro loading?
• If dry environment as you say, how is the floor kept clean and tested/proved to micro clear?
• What's the motive behind removing shoe covers? Apart from cost saving haha!
• Do employee's not have ANY company supplied footwear, or do these come in quite literally off the street?

RTE material requires that all care is taken and all risks reduced. As someone once explained, if you have a minor micro issue at home then 1 or 2 in household get ill, if you have a minor issue at work you potentially make hundreds or thousands ill.

[gfdoucette07]

Mambo

 

In my opinion there has to have been some thought given as to make this room high risk in the first place.  What has determined this, the diary, the RTE, or?  If you have called it high risk what precautions are you following to mitigate the risk aside from temp controlling the room? 

I would as JohnWheat suggests look back on/conduct some swabbing on the floor of this area as well as traveled routes from the employee entrance to this area.  If all of your history shows no risk then possibly.  I am personally skeptical of non-captive footwear and uniforms.  I have no idea what people encounter on their way to work and would like to leave what ever they track at the looker room door.

Shoe covers are to me best reserved for visitors and last resorts, other forms of control should be kept up.

 

G

[mambo]

Dr. Khan, gfdoucette07, Charles C and JohnWheat,

Thank you folks for the advice and guidance. The reason why the cheese room is categorized as high risk is because the product is RTE. We don't provide any company foot wear at the moment but i presented the proposal during a management review meeting. 

 

We send samples of the finished product to an independent accredited 3rd Party lab for analysis ( Salmonella, Coliforms, e-coli, Staph aureus, Yeasts & molds and APC). Product is under QA hold until the results come back.

 

Will complete an exhaustive risk assessment and make submit my findings. Policy will remain in place till the SQF audit in April.

 

Thank you.

Mambo. 

[Tony-C]

Hi Mambo,

 

I have several concerns here and a risk assessment of all aspects seems appropriate but would like more information.

 

Is the same protective clothing worn in low risk and high risk?

 

Is the cream cheese pH protected? and are there adequate production controls to prevent toxin production?

 

There are many requirements for 'high risk areas' that you will need to consider but with regards to clothing here a few extracts from SQF:

 

SQF Code 11.3.3 Clothing
11.3.3.2 Staff engaged in high-risk areas shall change into clean clothing or don temporary protective outerwear when entering high-risk areas.

SQF 11.3.3 Auditing Guidance
Company policies on clothing, including uniforms, gloves, hairnets, snoods and footwear shall be reviewed at the initial desk audit.
Evidence may include:
• Clothing worn by staff in high risk areas is not worn off-site;
• There is clean or temporary clothing available for staff in high risk areas;

 

Kind regards,

 

Tony

[primadeli]

The idea of wearing "outdoor shoes" in a high risk area makes me very jittery.  Floors are already prone to L.monocytogenes and anything you can do to reduce that risk is of benefit to the company.

 

Company issued footwear has been available at every site I worked at.  Mostly it has been white gumboots (or whatever you folk overseas call them), but my current employer supplies Crocs (or cheap imitation of).  These are cheaper and easier to store and are as easy to clean as gumboots.  But you do then have to enforce with staff that they keep their supplied footwear clean as well as providing them with facilities to do that.  (Also periodic checks that the sole of the footwear is not perished and that there is enough grip in the tread to prevent staff from slipping over.)

 

If you can get your staff to follow the procedures on that (good luck), then it shouldn't be too long until the long term cost savings outweigh the initial outlay costs.

[mambo]

Tony-C,

Thank you for your contribution. I owe you a lot. I bought the SQF Impementation Manual from IFSQN, found it invaluable as we review our policies. Your name appears on every document as the author. Thank you for your contribution to the body of organised knowledge.

 

The employees in the cheese room don separate clothing. Long sleeved white smocks/ uniforms with a different colour of hair nets. These smocks can only be used in this production room.

 

Primadeli,

Thank you for the suggestions. 

[Tony-C]

Tony-C,

Thank you for your contribution. I owe you a lot. I bought the SQF Impementation Manual from IFSQN, found it invaluable as we review our policies. Your name appears on every document as the author. Thank you for your contribution to the boy of organised knowledge.

 

The employees in the cheese room don separate clothing. Long sleeved white smocks/ uniforms with a different colour of hair nets. These smocks can only be used in this production room.

 

Primadeli,

Thank you for the suggestions. 

 

Thank you Mambo for taking the time to post your comments, we appreciate that.

 

Kind regards,

 

Tony