4 replies to this topic

[Pacman]

Hello peeps I'm Pacman QA Manager for a slitting biz, we provide great quality products for 35 years and now I'm told we need BRC to continue so I got a copy of the standard. Most of it is GMP and we have a lot of the stuff in place as part of customer requests. Mostly we slit material used with food like films, foils, laminates, so I agree with some of the stuff, but what frustrate me is bacteria. Can someone tell me what the risk is to my product from an operator not washing hands after the toilet, they never, ever touch the material it's all done with lifting equipment. And let's say they did touch it could bacteria ACTUALLY live on the material and could that ACTUALLY go into the food days / weeks later. Has anyone studied this to see how germs perform on different packaging material surfaces? What's the problem? I don't believe it!

Cheerio for now
Pacman

[Simon]

You make some very good points Pacman.

If you slit direct contact packaging then you are category B and 7.3.4 applies 'Hand Washing shall be carried out by all personnel when entering a production area.' Never mind after using the toilet, eating, smoking or drinking (7.3.3).

If there is absolutely no touching maybe you could apply for an exclusion on 7.3.4, but you would have to see your Certification Body about this. I doubt whether you could get an exclusion on 7.3.3 as not washing hands at these times could cause illness within the employees at your factory which could be hazardous and in any case would be undesirable for you regarding sick leave.

I'm not a microbiologist and I would be very interested to see the results of studies on the survival / growth of different pathogens, yeasts. moulds (molds) etc. on different packaging substrates. I have always been dubious without any evidence.

Maybe Witch our resident microbiologist may know if there have been any such studies?

Regards,
Simon

[Witch]

...could bacteria ACTUALLY live on the material and could that ACTUALLY go into the food days / weeks later. 

<{POST_SNAPBACK}>

Hey pacman, in fact they can!
Lots of bacteria and all funghi can produce spores to overcome bad times. (Its similar to sleep) That means they are very capable to resist dry environment or times without food. Afterwards they "awake" and grow again...
If you do not wash your hands after the toilet, you have 100 or 1000nds of bacteria on them and leave them whereever you touch. (thats the way diarrhoea spreads: the next person who touches uptakes your microbes).
So it is not only a question of contaminating your products, but a question of how much money you want to spend into illness of your employees.
And as personal hygiene is a central topic, no auditor will follow your explanation that there is no chance to contaminate anything. Every touch spreads the microbes! And dry spores even can be transferred via air and wind.

[Pacman]

I'm back and Ouch!!! Does this mean we have to plumb in an extra hand wash station in the factory or will the one in our lavatories be OK if we provide instruction on all of the times hand-washing is needed. Could work out pretty costly!!!

P.S. I cannot really use my PC at work for visiting here or for doing anything that's not construed as work. Anyway thanks for your valuable feedback.

Pacman

[Witch]

Does this mean we have to plumb in an extra hand wash station in the factory or will the one in our lavatories be OK if we provide instruction on all of the times hand-washing is needed. 

<{POST_SNAPBACK}>

I think, if you do not allow eating or drinking during production and if you have a detailed instruction on when and how hands have to be washed and if you will use a desinfection soap, this will be enough. Maybe they will honour a dispenser for isoprop at the entrances (sometimes we avoided the cost-intensive hand wash stations with that!)