5 replies to this topic

[jaredk]

During our previous meeting for BRC implementation a question was brought up and none of us had a clear answer. We were wondering if there is a requirement for the number of hand washing stations in our plant. Does anyone have clarification on the requirements for hand washing stations? Is there a rule of thumb that most food producers follow or should follow when it comes to hand wahsing stations and where they are located?


Thanks,
Jaredk

[Charles.C]

Dear jaredk,

The textbook (and guranteed BRC acceptable) answer is that the locations are based on risk analysis, ie where are the most likely places to present a safety-risk due to lack (eg inability for) of handwashing. Don't know what yr specific process is (cookies ??) but I'm sure you know the answer to that question.

Numerically, I'm less sure. There is a well-known Codex rule for number of toilets per X workers, handwashing i don't remember seeing anything. IMEX, factories always underestimate due lack of space and create queues. Anybody ?

Rgds / Charles.C

[Inesa]

Yes Charles! I think I found it !!

At, First I looked at the Workplace (Health, Safety and Welfare) Regulations 1992 http://www.legislati...4/contents/made
Same as other regulations, this one wasn't different, a piece of some blah blah . Then I searched for guidelines to this regulation- section "Welfare at work" and found this:
http://www.hse.gov.u...bns/indg293.pdf
I think it's what you asked for.
Regards to all
Inesa


p.s. location advice is f ex in
Guide to food hygiene and other regulations for the UK meat industry, part 2, chapter 1

http://www.food.gov....ov10.pdf#page=1


A11- Position – hand washbasins should be placed conveniently
close to toilets, entry points for food-handling areas and
workstations, to encourage staff to wash their hands after
visiting the toilet, before entry into food handling areas and
during food handling activities

Edited by Inesa, 20 December 2010 - 10:25 PM.

[Charles.C]

Dear Inesa,

Very nice searching.

The MIG manual is amazingly explanative (although meat oriented of course.)

I think yr”table” ref is based on codex (or vice-versa). Two small snags (maybe) - (a) stops at 100 (maybe due to problem of matching handwashing!, see my [b]), (b) I think the washbasins are assumed limited to locations adjacent to toilet. (b) is the tricky part because it may/will obviously vary with the process set-up.

Generally I think there are at least 4 difficulties in answering the handwashing query - interpretation, legal requirements (geographical?), process variety, individual concepts (ie available space)

Interpretation - The Americans tend to love “handsanitising” points in various industries which can be also equatable to handwashing. Have no experience with the cookie industry disposition referred here so have ignored this subtlety below. I suspect many European locations do not follow the same concept.

Often the Americans seem to be (RTE anyway) initially guided by Food Code – here are extracts (2005) version

5-203.11 Handwashing Sinks.*

(A) Except as specified in ¶¶ (B) and © of this section, at least 1
HANDWASHING SINK, a number of HANDWASHING SINKS necessary for
their convenient use by EMPLOYEES in areas specified under
§ 5-204.11, and not fewer than the number of HANDWASHING SINKS
required by LAW shall be provided.

(B) If APPROVED and capable of removing the types of soils
encountered in the FOOD operations involved, automatic
handwashing facilities may be substituted for HANDWASHING SINKS
in a FOOD ESTABLISHMENT that has at least one HANDWASHING SINK.

© If APPROVED, when FOOD exposure is limited and HANDWASHING
SINKS are not conveniently available, such as in some mobile or
TEMPORARY FOOD ESTABLISHMENTS or at some VENDING MACHINE
LOCATIONS, EMPLOYEES may use chemically treated towelettes for
handwashing.


5-204.11 Handwashing Sinks.*

A HANDWASHING SINK shall be located:

(A) To allow convenient use by EMPLOYEES in FOOD preparation, FOOD dispensing, and WAREWASHING areas; and

(B) In, or immediately adjacent to, toilet rooms.

[In other words – the number can vary and must relate to LAW (whatever that means!)]

In respect to numbers of toilets, I think below is standard Codex although applied to a fish process –

The following formula could be used in assessing the adequacy of toilet facilities in relation
to the number of employees:
• 1 to 9 employees – 1 toilet
• 10 to 24 employees – 2 toilets
• 25 to 49 employees – 3 toilets
• 50 to 100 employees – 5 toilets
• for every 30 employees over 100 – 1 toilet

http://www.gipescado...is_codex/24.pdf

This approx. matches yr H&S data and extends it a bit. Note the “could”. Codex knows the problem of space etc.

But, process-wise, Codex do not predict numbers for handwashing eg (same link)–

Adequate, suitable and conveniently located changing facilities and toilets should be provided in all establishments. Toilets should be so designed as to ensure hygienic removal of aste matter. These areas should be well lit, ventilated and where appropriate heated and should not open directly on to food handling areas. Hand washing facilities with warm or hot and cold potable water, or clean sea water, a suitable hand-cleaning preparation, and with suitable hygienic means of drying hands, should be provided adjacent to toilets and in such a position that the employee must pass them when returning to the processing area. Where hot and cold water are available mixing taps should be provided. Where paper towels are used, a sufficient
number of dispensers and receptacles should be provided near to each washing faciltity. Taps of a non-hand operable type are desirable. Notices should be posted directing personnel to wash their hands after using the toilet.

Adequate and conveniently located facilities for hand washing and drying should be provided wherever the process demands. Where appropriate, facilities for hand disinfection should also be provided. Warm or hot and cold potable water or clean sea water and a suitable hand-cleaning preparation should be provided. Where hot and cold water are available mixing taps should be provided. There should be suitable hygienic means of drying hands. Where paper towels are used, a sufficient number of dispensers and receptacles should be provided adjacent to each washing facility. Taps of a non-hand operable type are desirable. The facilities should be furnished with properly trapped waste pipes leading to drains.

As an example of another formula, this one calculated toilets based on 1 per 15 workers. Beats Codex above 50.
http://ifpkochi.nic.in/IFPS3.pdf
(nice article but amazing chlorination procedure for ice production)

Soooo, IMO, no precise, comprehensive answer to handwashing positions(yet).

Rgds / Charles.C

[Inesa]

Dear Charles,

thanks for comparing all examples, you make me think and research, you infect me with researching, you're dangerous also you scary me sometimes, are you some food genius???

I think there is no law determining a precise number of hand wash basins or their precise placement- its impossible to determine it . AFAIK guides are there to explain the meaning of law and give an advise. As example, a small turn back to MIG (http://www.food.gov....uidehygienemeat ):

About the guide
As is stated in the guide (part one chapter 3):
the guide sets out the legal obligations that apply to food business operators in the meat sector and provides advice on how these obligations can be met

• compliance with the law is not voluntary but operators are not obliged to follow the advice in the guide as other ways of achieving compliance with the law may be equally valid
• the guide is not an authoritative interpretation of the law as only the courts have that power

Consultation
The guide has been developed and updated with the help of an editorial panel made up of industry organisations, enforcement authorities and Agency officials.

However in MIG, the number of toilets they link to regulations:

A10- The number of flush toilets required is regulated by the

Workplace (Health Safety and Welfare) Regulations 1992 in

GB and the Workplace (Health Safety and Welfare)

Regulations (Northern Ireland) 1993 in NI.

Shame, but I couldn't find anything about toilets in there...

Following, about hand wash they just state:

A11- The number of washbasins required to maintain good

hygiene depends on the number of staff and on the nature

and location of the operations being carried out


So IMO you're very right there is no clear rule how many ewashbasins shoul be

Edited by Inesa, 21 December 2010 - 12:30 PM.

[Tony-C]

So IMO you're very right there is no clear rule how many ewashbasins shoul be

Great efforts in researching this Charles and Inesa.

One of the problems I believe is that hand wash stations come in various sizes:

http://www.protechst...-person-hwkp50/

BRC states suitable and sufficient hand washing facilities which if you have facilities in all appropriate locations will be down to judgement of how many people are likely to use the facility and practicality of throughput at peak times e.g start of shift.