Jump to content

  • Quick Navigation
Photo
- - - - -

Audits and hand washing protocol


  • You cannot start a new topic
  • Please log in to reply
23 replies to this topic

#1 food_hygiene

food_hygiene

    Grade - Active

  • IFSQN Active
  • 11 posts
  • 0 thanks
1
Neutral

  • Earth
    Earth

Posted 27 February 2017 - 01:50 PM

Hi, 

 

I have noticed that SQF is one of the few standards that actually mandates paper towels as opposed to air dryers on plant floors (different in bathrooms). Is this enforced by auditors? Also, if known,  is there a protocol that BRC companies with air dryers have to go through to show that their air dryers are "suitably designed and located"?

 

SQF

4.3.2.2 Hand wash basins shall be constructed of stainless steel or similar non-corrosive material and as a

minimum supplied with:

i. A potable water supply at an appropriate temperature;

ii. Liquid soap contained within a fixed dispenser;

iii. Paper towels in a hands free cleanable dispenser;

iv. A means of containing used paper towels; and

v. Hand sanitizers.

 

 

BRC

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

 . . . .

single-use towels or suitably designed and located air dryers

 

 

Thanks!


  • 0

#2 Big Wally

Big Wally

    Grade - MIFSQN

  • IFSQN Member
  • 58 posts
  • 20 thanks
2
Neutral

  • United States
    United States
  • Gender:Male
  • Location:Indiana

Posted 27 February 2017 - 02:45 PM

Hello food_hygiene,

 

We have air dryers installed in our facility. We are certified to what is now formerly level 2. We risk assessed our dryers and our auditor did not have a problem with them.


  • 0

#3 food_hygiene

food_hygiene

    Grade - Active

  • IFSQN Active
  • 11 posts
  • 0 thanks
1
Neutral

  • Earth
    Earth

Posted 27 February 2017 - 02:53 PM

Thanks Big Wally,

 

Do you mind if i ask what kind of facility you work in and its size? 

 

Also, was waste the reason for opting for the dryer versus paper towel? 


  • 0

#4 Big Wally

Big Wally

    Grade - MIFSQN

  • IFSQN Member
  • 58 posts
  • 20 thanks
2
Neutral

  • United States
    United States
  • Gender:Male
  • Location:Indiana

Posted 27 February 2017 - 04:09 PM

We are a flexible packaging facility with approx. 150 employees. There is a bacterial contamination risk and here is part of our justification: 

 

"Hand drying should be an essential part of the hand hygiene process in health care. However, there appears to be little agreement regarding the most
hygienic method of hand drying. The results of different studies have also been conflicting." Citation 1.
"In a year-long study of 100 people who volunteered to have their hands contaminated with bacteria, researchers found that hand washing got rid of the same amount of germs regardless of drying style. Results were reported in Mayo Clinic Proceedings (75:705 - 708). Scientist P.D. Meers and K.Y. Leong's letter to the Journal of Hospital Infection stated "[There is] no bacteriological reason to exclude [hand dryers] from the clinical areas."
"With approval from NMH's [Northwestern Memorial Hospital's] Infection Control board, the facilities staff installed over 100 XLERATOR® high-speed, energy-efficient hand dryers the first year, thus meeting the hospital's rigorous standards for hand hygiene.
Unlike conventional hand dryers, which average 30 to 45 seconds of drying time, XLERATOR dries hands three times faster (completely in 10 seconds)..." 


  • 0

Thanked by 1 Member:

#5 adamperry2235

adamperry2235

    Grade - AIFSQN

  • IFSQN Associate
  • 26 posts
  • 14 thanks
2
Neutral

  • United States
    United States

Posted 27 February 2017 - 04:10 PM

From my conversation with our auditor I understand they prefer to have towels as opposed to air dryers. The reason being they are finding air dryers to not be clean. And from a safety standpoint they are blowing potentially contaminated air back on to your hands. So there while it isn't necessary it is recommended to prevent they transmission of pathogens. 

 

But like Wally said if you do the risk assessment on them and find them to be acceptable and you are capable of proving it then there shouldn't be any problems


  • 0

Thanked by 1 Member:

#6 SQFconsultant

SQFconsultant

    SQFBRCconsultant

  • IFSQN Principal
  • 558 posts
  • 86 thanks
29
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:We specialize in helping food companies to develop & implement SQF & BRC programs in the United States and Panama

Posted 27 February 2017 - 04:59 PM

Hi, 

 

I have noticed that SQF is one of the few standards that actually mandates paper towels as opposed to air dryers on plant floors (different in bathrooms). Is this enforced by auditors? Also, if known,  is there a protocol that BRC companies with air dryers have to go through to show that their air dryers are "suitably designed and located"?

 

SQF

4.3.2.2 Hand wash basins shall be constructed of stainless steel or similar non-corrosive material and as a

minimum supplied with:

i. A potable water supply at an appropriate temperature;

ii. Liquid soap contained within a fixed dispenser;

iii. Paper towels in a hands free cleanable dispenser;

iv. A means of containing used paper towels; and

v. Hand sanitizers.

 

 

BRC

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

 . . . .

single-use towels or suitably designed and located air dryers

 

 

Thanks!

 

The reason for paper towels over air dryers is the friction from the towels is considered to remove a greater deal of microbs than a dryer or blower.  Some dryers use compressed air in which case air testing is needed. It is not a "preference" by Auditors, it is a requirement by the code for paper towels and it is enforced.  A company can however conduct a risk analysis like several of our clients have (that had hand dryers in place already prior to going for certification) and based on favorable results show their analysis to the SQF Auditor as needed... yes, not all Auditors pick up on the fact that hand dryers are in use, skip it or whatever. So best to have the document in place and ready if needed.


  • 0

Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


Thanked by 1 Member:

#7 food_hygiene

food_hygiene

    Grade - Active

  • IFSQN Active
  • 11 posts
  • 0 thanks
1
Neutral

  • Earth
    Earth

Posted 27 February 2017 - 09:47 PM

Thank you everyone for the responses. 

 

So, my next question is: do FDA inspectors care if you are using air dryers or paper towels? Or, do they only care if your system follows HACCP/HARPC? 

Under HACCP/HARPC protocol, wouldn't hand drying fall under a critical control point? Does every company have to show that their hand drying is not a source of contamination?

 

Appreciate the help. Very new to this field. Please realize that I have been reading  A LOT and am trying not to ask stupid questions and waste your time. I just know that the people in the field are so much more knowledgeable than any website.


  • 0

#8 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,450 posts
  • 3244 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 27 February 2017 - 10:46 PM

Thank you everyone for the responses. 

 

So, my next question is: do FDA inspectors care if you are using air dryers or paper towels? Or, do they only care if your system follows HACCP/HARPC? 

Under HACCP/HARPC protocol, wouldn't hand drying fall under a critical control point? Does every company have to show that their hand drying is not a source of contamination?

 

Appreciate the help. Very new to this field. Please realize that I have been reading  A LOT and am trying not to ask stupid questions and waste your time. I just know that the people in the field are so much more knowledgeable than any website.

.

 

30 years ago, maybe. Then came Prerequisite Programs.


  • 0

Kind Regards,

 

Charles.C


Thanked by 2 Members:

#9 Irishlass105

Irishlass105

    Grade - AIFSQN

  • IFSQN Associate
  • 44 posts
  • 7 thanks
1
Neutral

  • United Kingdom
    United Kingdom

Posted 28 February 2017 - 10:41 AM

We use both hand towels and a drier on site. We are a food manufacturing facility. Our hand dryer is ISO accredited and designed for the food industry. Nobody seems to have an issue with it but we have on file from our approved supplier how it is fit for food manufacturing and how we change the filter regularly to ensure it is in full working order.

 

I would say stick with disposable hand towels as it means no to little questions are asked!


  • 0

Thanked by 2 Members:

#10 Ryan M.

Ryan M.

    Grade - SIFSQN

  • IFSQN Senior
  • 394 posts
  • 162 thanks
28
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Los Angeles, California
  • Interests:Reading, crosswords, passionate discussions, laughing at US politics.

Posted 28 February 2017 - 06:50 PM

We are SQF Level 3 certified, with initial certification late last year.  The auditor had no issue with our hand air dryers.  We have paper towel in most locations, with hand dryers in key/select locations.  Initially, the design was hand dryers everywhere, but the budget needed to be cut so they opted to leave them only in the employee entrance to the facility and before our packaging room (critical environment).

 

The hand dryers are HEPA filtered, filter is maintained per frequency based on our monthly air quality monitoring the of the from the hand dryers.  This is probably the best way to verify them.

 

Our process has the product from receipt of raw materials to packaging enclosed, no exposure, except two points.  So really there is no hand-contact anywhere.

 

The auditor didn't even bat an eye at our hand dryers....even though she reamed us on some other small, questionable, "issues" that were not in the SQF code.


  • 0

#11 food_hygiene

food_hygiene

    Grade - Active

  • IFSQN Active
  • 11 posts
  • 0 thanks
1
Neutral

  • Earth
    Earth

Posted 28 February 2017 - 06:52 PM

Thanks for the note Ryan. 

 

Just a follow-up.

 

When you were creating your pre-requisite programs, did you validate your air dryers as part of that?


  • 0

#12 CMHeywood

CMHeywood

    Grade - SIFSQN

  • IFSQN Senior
  • 318 posts
  • 78 thanks
15
Good

  • United States
    United States
  • Gender:Male
  • Location:Neenah, Wisconsin

Posted 28 February 2017 - 09:22 PM

"The reason for paper towels over air dryers is the friction from the towels is considered to remove a greater deal of microbes than a dryer or blower."  This sounds like folklore:  an opinion that continues to be communicated without validation (no proof).

 

"In a year-long study of 100 people who volunteered to have their hands contaminated with bacteria, researchers found that hand washing got rid of the same amount of germs regardless of drying style. Results were reported in Mayo Clinic Proceedings...".   Ahhh - validation at last! 


  • 0

#13 Ryan M.

Ryan M.

    Grade - SIFSQN

  • IFSQN Senior
  • 394 posts
  • 162 thanks
28
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Los Angeles, California
  • Interests:Reading, crosswords, passionate discussions, laughing at US politics.

Posted 01 March 2017 - 12:05 AM

Thanks for the note Ryan. 

 

Just a follow-up.

 

When you were creating your pre-requisite programs, did you validate your air dryers as part of that?

 

No, validation not required.


  • 0

Thanked by 1 Member:

#14 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,450 posts
  • 3244 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 01 March 2017 - 06:14 AM

"The reason for paper towels over air dryers is the friction from the towels is considered to remove a greater deal of microbes than a dryer or blower."  This sounds like folklore:  an opinion that continues to be communicated without validation (no proof).

 

"In a year-long study of 100 people who volunteered to have their hands contaminated with bacteria, researchers found that hand washing got rid of the same amount of germs regardless of drying style. Results were reported in Mayo Clinic Proceedings...".   Ahhh - validation at last! 

 

Actually not folk-lore.  See my post 7 in the parallel thread linked below. (Usual problem of 2 related threads overlapping).

 

http://www.ifsqn.com...er/#entry110550

 

JFI (and not to disparage), the Mayo evaluation quoted above/ Meers-Leong ref in Post 4 were dated 2000 and 1989 respectively.

Attached File  Hand_Dryers_and_Hygiene.pdf   62.08KB   19 downloads

 

 


  • 0

Kind Regards,

 

Charles.C


Thanked by 2 Members:

#15 food_hygiene

food_hygiene

    Grade - Active

  • IFSQN Active
  • 11 posts
  • 0 thanks
1
Neutral

  • Earth
    Earth

Posted 01 March 2017 - 02:02 PM

No, validation not required.

 

Now, I am a bit confused.

 

Do you think the validation was not required because of an anomaly in the auditor you got or because of the actual SQF scheme? From a conversation I had with the scheme makers, it seemed as if air dryers would be required to be validated to be sanitary, whereas paper towels not. 


  • 0

#16 Dapulu

Dapulu

    Grade - Active

  • IFSQN Active
  • 17 posts
  • 5 thanks
0
Neutral

  • Mexico
    Mexico

Posted 01 March 2017 - 02:46 PM

In the few years of experience and discussions I've had with colleagues in the industry, using paper my be a better option to avoid picky auditors questions and confirmation of risk-free hand dryers.

 

In my experience operators in some factories that have hand dryers do not dry their hands properly, and as a result they've got water in their hands and more water for any kind of microorganism that may come along the road. While using paper to dry them is in a way easier and quicker (debatable) and they do scrub every part of their hands to get them dry. Talking with them and making them follow their GMP properly is an everyday issue. The current factory I'm at only has hand dryers, and while we're not at our best right now, we're getting there.

 

Hand washing is part of your prerequisite programs and out of the 6-7 auditors that have come to the factory, none of them had a problem with our HD. They did ask for a technical datasheet, and specs. As long as you properly mantain them and every now and then verify with micro, I don't see the issue.


  • 0

#17 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,450 posts
  • 3244 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 01 March 2017 - 02:58 PM

Now, I am a bit confused.

 

Do you think the validation was not required because of an anomaly in the auditor you got or because of the actual SQF scheme? From a conversation I had with the scheme makers, it seemed as if air dryers would be required to be validated to be sanitary, whereas paper towels not. 

 

Hi food hygiene,

 

Ryan may have a different answer but, technically, SQF Code 7.2  no longer requires "validation" of prerequisite programs. In practice, it seems that some SQF auditors may have their own interpretations.

 

See this post -

 

http://www.ifsqn.com...ts/#entry110157


  • 0

Kind Regards,

 

Charles.C


Thanked by 1 Member:

#18 Ryan M.

Ryan M.

    Grade - SIFSQN

  • IFSQN Senior
  • 394 posts
  • 162 thanks
28
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Los Angeles, California
  • Interests:Reading, crosswords, passionate discussions, laughing at US politics.

Posted 01 March 2017 - 04:01 PM

Now, I am a bit confused.

 

Do you think the validation was not required because of an anomaly in the auditor you got or because of the actual SQF scheme? From a conversation I had with the scheme makers, it seemed as if air dryers would be required to be validated to be sanitary, whereas paper towels not. 

 

Hand-washing is typically part of a GMP program, which is typically a pre-requisite program.  SQF does not require validation for pre-requisite programs.  If the auditor brings this up you can validate it against a regulatory body, such as the CDC on hand-washing procedures.

 

https://www.cdc.gov/handwashing/


  • 0

Thanked by 2 Members:

#19 moskito

moskito

    Grade - MIFSQN

  • IFSQN Member
  • 210 posts
  • 44 thanks
7
Neutral

  • Germany
    Germany
  • Gender:Male

Posted 12 March 2017 - 01:24 PM

Hi,

 

we are a BRC/IFS certified bakery and are audited by German, French and UK retailers.

We have installed Hand Dryer in Locks and changing rooms, not in the production/hygiene area itself. Workers have to covers working cloth worn inside the building (trousers + T-shirt) with a white work coat in hygiene areas. Order: Hair net, coat, hand washing, drying, sanitation.

For microbiological reasons Hand Dryer only permitted are such working on sucking (not blowing).

Auditors asked how to dry if more than hand washing is require e.g. face oder lower arms if no other option than air dryers are offered? We have both in place.

 

Rgds

moskito


  • 0

#20 Bakerkid

Bakerkid

    Grade - Active

  • IFSQN Active
  • 9 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 22 August 2017 - 06:18 PM

There are some hand dryers now that come with HEPA filtration.   The add says "proven to remove 99.97% of potentially present bacteria at 0.3 microns" has to be an improvement over the old style hand dryers.


  • 0

#21 FurFarmandFork

FurFarmandFork

    QA Manager/FS Blogger

  • IFSQN Senior
  • 447 posts
  • 225 thanks
35
Excellent

  • United States
    United States
  • Gender:Male
  • Location:USA

Posted 22 August 2017 - 09:35 PM

Going back to the Code, bot 7.2 and version 8 actually make a distinction between packaging and food production.

 

Food, module 11:

 

 

11.3.2.1 Hand wash basins shall be provided adjacent to all personnel access points and in accessible locations throughout food handling and processing areas as required. 11.3.2.2 Hand wash basins shall be constructed of stainless steel or similar non-corrosive material and as a minimum supplied with: i. A potable water supply at an appropriate temperature; ii. Liquid soap contained within a fixed dispenser; iii. Paper towels in a hands free cleanable dispenser; and iv. A means of containing used paper towels. 11.3.2.3 The following additional facilities shall be provided in high risk areas: i. Hands free operated taps; and ii. Hand sanitizers. 11.3.2.4 A sign instructing people to wash their hands, and in appropriate languages, shall be provided in a prominent position. 11.3.2.5 Personnel shall have clean hands and hands shall be washed by all personnel, including staff, contractors and visitors: i. On entering food handling or processing areas; ii. After each visit to a toilet; iii. After using a handkerchief; iv. After smoking, eating or drinking; and v. After handling wash down hoses, dropped product or contaminated material. 11.3.2.6 When gloves are used, personnel shall maintain the hand washing practices outlined above

 

In the food packaging code, module 13:

 

13.3.2.1 Hand wash basins shall be provided in appropriate areas. 13.3.2.2 Hand wash basins shall be constructed of stainless steel or similar non-corrosive material and as a minimum supplied with: i. A potable water supply at an appropriate temperature; ii. Liquid soap contained within a fixed dispenser; iii. Paper towels or effective hand dryer; and iv. A means of containing used paper towels. 13.3.2.3 A sign instructing people to wash their hands, and in appropriate languages, shall be provided in a prominent position. 13.3.2.4 Personnel shall have clean hands and hands shall be washed by all personnel, including staff, contractors and visitors: i. On entering production areas; ii. After each visit to a toilet; iii. After using a handkerchief; iv. After smoking, eating or drinking; and v. After handling waste or chemicals. 13.3.2.5 When gloves are used, personnel shall maintain the hand washing practices outlined above.

 

 

So the code by the letter permits hand dryers in packaging and distribution modules, but not in the food module. At another company I worked, we provided paper towels at sinks located in actual production areas, but used hand dryers at plant entrances and bathrooms.

 

SQF also clarifies requirements for using hand dryers in the guidance documents for both modules (7.2 guidance):

 

Where alternative methods of hand-drying are preferred (e.g. high-speed air dryers). Their use must be justified and their effectiveness validated (refer 2.4.2.2).

 

 

So there. Complete a risk assessment that will satisfy your auditor, and you can then use hand dryers wherever you want.


  • 0

For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


Thanked by 1 Member:

#22 slaynboi

slaynboi

    Grade - Active

  • IFSQN Active
  • 2 posts
  • 0 thanks
0
Neutral

  • Earth
    Earth

Posted 23 August 2017 - 04:54 AM

For SQF food packaging code, has anyone defined 'effective' for effective hand dryers?  I assume the modern high speed dryers would be 'effective'.  Can anyone recommend one?


  • 0

#23 Albertus@2806

Albertus@2806

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • South Africa
    South Africa

Posted 23 August 2017 - 11:22 AM

Thanks


  • 0

#24 food_hygiene

food_hygiene

    Grade - Active

  • IFSQN Active
  • 11 posts
  • 0 thanks
1
Neutral

  • Earth
    Earth

Posted 23 August 2017 - 01:16 PM

There are some hand dryers now that come with HEPA filtration.   The add says "proven to remove 99.97% of potentially present bacteria at 0.3 microns" has to be an improvement over the old style hand dryers.

 

 

Hi Bakerkid,

 

No doubt these new air dryers are much better but they still have their issues. I think this ad is a bit misleading too, because although the HEPA filter (which has to be maintained and changed regularly to be effective) is good at keeping the air of the actual unit clean, it does not solve the problem of aerosolization and dispersal of potentially pathogenic material and water still on your hands after washing. And, it does not protect against touching your hands against the unit (the fomite problem - think dipping your hands into airblades and touching the sides) and spreading germs. Basically a 400 MPH blast of air is really good at drying your hands but also taking whatever was on your hands and putting in the air around you.


  • 1




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users