7 replies to this topic

[Katja]

Hello, I received a minor non-conformity in our SQF facility audit for not validating our personal hygiene practices. If i look at the guidelines it says to validate by observing employees during internal inspection or audit to ensure that they are meeti8ng program requirements. I have done this but is this enough.
I was thinking of validating our hand-washing practices by taking random hand samples and grown on culture plates. This would be good but then how do i interpret the results, what is normal flora for the skin, what are my limits, i cannot find any relevant information on the net. What do i do, I am at a loss for this
thanks for any help

[esquef]

Auditing and observation seem like adequate validation for personnel hygeine (maybe documented induction and annual refresher training records as well). What type of products does your company produce?

[Katja]

Auditing and observation seem like adequate validation for personnel hygeine (maybe documented induction and annual refresher training records as well). What type of products does your company produce?

Mainly dry soups and sauces but we also transform raw beef into a cooked salted paste product

[esquef]

Dry soup and sauce blends are low risk and shouldn't require extremely high validation standards IMO. I'd imagine that the raw beef processing is high risk and the validation expectations are higher?

Edited by esquef, 13 January 2012 - 08:53 PM.

[Charles.C]

Dear katja,

One answer to yr query for a non-SQF thread i hv seen on another forum was to ensure (ie to have documentation and data) that yr own procedure matches an officially published SOP. This then acts as a (proxy) validation (some people might call it a verification for a [hypothesised] trial period ).The particular case was in USA and involved use of the FDA Food Code however this approach seemed quite general (and ingenious) IMO.

The above is a minimal solution and needs to be acceptable within the overall framework of yr standard (which it should be IMO). Presumably further detail would be of positive value if properly carried out.

Rgds / Charles.C

[George @ Safefood 360°]

Hi katja

The risks presented by food handlers are numerous and depend to a large degree on the products produced and the procedures for producing them. The meat process you describe appears high risk with the potential for cross contamination but a lot more information would be required to determine this.

The efficacy of hand-washing is just one part of a much bigger picture relating to food handlers. Swabbing and culturing of hands for example is IMO a qualitative exercise to determine general levels and trends for good personal hygiene practice unless you are conducting specific screening for carriers of pathogens like staph aureus in a very high risk operation where there is direct handling of RTE foods, for example.

Inspection and auditing of procedures are verification exercises.To help you make more informed decisions on issues regarding food handlers, procedures and verification and validation i have provided a link to a very useful document called 'Preventing Foodborne Disease: A Focuson the Infected Food Handler'. It also includes information on the normal flora of skin etc.

My link

[GMO]

Hi George,

I think I've been sucked into this before. I've got no experience of SQF but I believe they use the term validation in an incorrect way (wrt Codex definitions) and actually mean verification.

To thoroughly close the loop, using codex definitions here, 'true' validation could include:

Consultation with industry guidelines and best practice (consider trade associations, retailer standards etc.)
Reference to the law and government sources, e.g. in the UK the FSA produces guidelines for food handlers on illness reporting and exclusion periods
Ask for advice from industry bodies (e.g. Campden or the Canadian equivalent) on what micro loading on hands is 'acceptable' and unlikely to cause issues
Information from your soap suppliers that their products kill or remove the pathogens of concern in your field.

You'd then need documented training in the personal hygiene standards you've set.

To then verify, that could include

Audit
Review of customer complaints
Routine swabbing (a few a month)

[Katja]

Hello, thanks all, you are correct SQF use of validation is skewed and not in the traditional sense, especially when it come to validation or prerequisite programs. My problem is that i have consuted with industry bodies and have found no clear answer of what is considered normal and inversely abnormal microbial load on hands. Thanks for the suggestion of including information from my soap suppliers , it seems so basic that i forgot that one. Thanks. I may just show before and after hand washing pictures (of culture plates) and data for general quantification. I may use the codex Verification/validation suggestion that by following your own SOP for several weeks and getting consistent results you essentially validate your SOPs.