20 replies to this topic

[CaliforniaFS]

Hi All,

 

In reviewing a processing site I came across a dip station that is water and chlorine.

It was two sinks that were filled with water and chlorine. The gloves that the employees used were dipped in there as a form of disinfectant. This is my first time reviewing a processing site that has a need for a dip station and wanted to confirm that this is a standard style of a dip station.

 

The level is monitored through out the day.

 

Thank you.

[Mariah]

I have seen and used a similar process before.  Employees wash their gloves first, and then sanitize them in a dip station (100-200ppm chlorine).  The chlorine levels must be monitored. 

[CaliforniaFS]

Thank you very much for your response. It is appreciated. 

[Charles.C]

I have seen and used a similar process before.  Employees wash their gloves first, and then sanitize them in a dip station (100-200ppm chlorine).  The chlorine levels must be monitored. 

Dear Mariah,

 

You must have very high microbe levels in yr product / process environment.

 

IMEX for seafood, the level is nearer a maximum of 5ppm. 100-200ppm is used on the tables though.

 

Rgds / Charles.C

[Ruhama]

Hi all

 

I am very happy to found this post because I have been looking for the way to clean gloves in our firm. So please tell me how to do the whole process.

 

Thanks for your help in advance.

 

Regards

Ruhama

[Ruhama]

I have seen and used a similar process before.  Employees wash their gloves first, and then sanitize them in a dip station (100-200ppm chlorine).  The chlorine levels must be monitored. 

Hi Mariah

 

Can u please explain how is done. Seriously I need to practice this in our company

 

 

Thanks

Ruhama

[Slab]

Hi, Ruhama;

 

I agree with Charles.  100-200 ppm is an excessive concentration and is not really necessary unless you would like to measure contact time, followed by a rinse, followed by residual testing.  Generally in that range it is a sanitizing step for post cleaning and the solution is allowed sufficient time for oxidation prior to resumption of operations.  

Also, not all chlorine is food safe.  I would look at NSF approved products of sodium hypochlorite such as CircoSan 12

 

Another problem with chlorine is that it loses effectiveness at elevated temperatures and load, so monitoring becomes more frequent with these variables.

If you would like to pursue this method I would advise a concentration of no more than 50-100 ppm with a contact time of 1-2 minutes followed by a rinse.  
 

A concentration range to disinfect unsoiled (visible) work gloves is more closer to 2-5 ppm.

 

 

High range test strips

Low range tests strips

 

As with any sanitizer I would also use a drop kit as a control method to proof effectiveness of the strips (frequency may be regulatory)

Chlorine drop kits

 

A good source from OSU:

 Chlorine as a Sanitizer.pdf   901.46KB   118 downloads

Edited by Slab, 23 January 2014 - 09:23 PM.

[Ruhama]

Hi, Ruhama;

 

I agree with Charles.  100-200 ppm is an excessive concentration and is not really necessary unless you would like to measure contact time, followed by a rinse, followed by residual testing.  Generally in that range it is a sanitizing step for post cleaning and the solution is allowed sufficient time for oxidation prior to resumption of operations.  

Also, not all chlorine is food safe.  I would look at NSF approved products of sodium hypochlorite such as CircoSan 12

 

Another problem with chlorine is that it loses effectiveness at elevated temperatures and load, so monitoring becomes more frequent with these variables.

If you would like to pursue this method I would advise a concentration of no more than 50-100 ppm with a contact time of 1-2 minutes followed by a rinse.  
 

A concentration range to disinfect unsoiled (visible) work gloves is more closer to 2-5 ppm.

 

 

High range test strips

Low range tests strips

 

As with any sanitizer I would also use a drop kit as a control method to proof effectiveness of the strips (frequency may be regulatory)

Chlorine drop kits

 

A good source from OSU:

Chlorine as a Sanitizer.pdf

Thank you very much about this information.

[Marshenko]

I have seen and used a similar process before.  Employees wash their gloves first, and then sanitize them in a dip station (100-200ppm chlorine).  The chlorine levels must be monitored. 

 

I could see a concentration of 100-200ppm quaternary ammonium...

[Urban Explorer]

We have dip stations throughout our room for them to dip gloved hands (at the entrance door) and also tools while working with food.  The thinking of glove dipping is in case they didn't wash their hands completely or touched a door or wall before entering that wasn't sanitized, etc. Just another failsafe really.

 

We use a quat sanitizer at 250-400ppm dispensed through a dosimatic pump.  We don't use chlorine because of the smell it can impart in our food and people can be sensitive to it even at low concentrations.  Usually 25-50ppm is standard.

 

Chlorine effectiveness actually decreases with strength, so having too high a concentration means longer contact time.  And also higher costs and possibilities of your employees mishandling the chemicals.

Edited by Destinee, 24 January 2014 - 11:41 PM.

[Charles.C]

Dear Destinee,

 

You might find this post / thead a little disturbing.

 

http://www.ifsqn.com...nol/#entry68133

 

Rgds / Charles.C

 

PS - added later  - Personally I have never encountered quats used for handwashing purposes in food manufacturing facilities.

 

Are they officially, eg FDA / Food Code, approved for this purpose at some recommended level?

[Marshenko]

Charles,

 

Quats are approved for use as a food-contact no-rinse sanitizer at ... well the new generation of quats are now approved at up to 400ppm (here at least).

 

The theory behind using a bucket of quat to dip already washed, then gloved hands is that, in a very technicaly sense, gloves can be considered food-contact surfaces.

 

I've seen it done for gloves for RTE food handlers as well as for guys who are deboxing meat before they open the inner bag lining of the box.  In both instances the USDA was perfectly fine with it.

[Snookie]

When measuring chlorine it is important to know whether you are measuring free chlorine or total chlorine.  100-200 total chlorine is approved for food contact.  If it is free chlorine that would very high. 

[Charles.C]

Charles,

 

Quats are approved for use as a food-contact no-rinse sanitizer at ... well the new generation of quats are now approved at up to 400ppm (here at least).

 

The theory behind using a bucket of quat to dip already washed, then gloved hands is that, in a very technicaly sense, gloves can be considered food-contact surfaces.

 

I've seen it done for gloves for RTE food handlers as well as for guys who are deboxing meat before they open the inner bag lining of the box.  In both instances the USDA was perfectly fine with it.

 

Dear Marshenko,

 

Thks yr feedback. Sounds suitably devious.

 

I also did a little more net searching on this topic so I can add a few nuggets. Relates primarily to the US scenario. There is some guesswork here and there so criticisms / comments welcome.

 

Frankly this subject appears to be a maze of  regulations / opinions, eg from CDC, WHO, USFDA, USDA. And a large miscellany  of commercial interpretations.

 

USDA, FDA seem to have similar basic, concepts regarding the use of hand sanitizers although FDA has, as far as I coud see, published considerably more explicit  requirements for acceptance, eg via the Food Code. I supppose this is a natural consequence of the “Drug” in FDA. (Maybe FDA acts as a technical support to USDA in this respect.)

 

For  starters,  this document attempts to overview the whole US regulatory spectrum and seems fairly accurate where I could compare data –

 hsan0 - ISSA, general guide to chemical cleaning product regulation.pdf   56.43KB   41 downloads

 

Here is a summary (hsan1) I found of the USDA classification system (ca. 2009). Appears rather cryptic inasmuch as actual compounds are "unspecified". Some changes may have subsequently been introduced –

 hsan1 - USDA sanitizer classification, 2009.png   258.48KB   0 downloads

The FDA viewpoint is described here –

 hsan2 - foodhandler, Hand hygiene.pdf   2.2MB   65 downloads

 hsan3 - ifsa, international flight services organisation.pdf   1.06MB   27 downloads

 

Within the above jungle,  there is a vast array of competing commercial products, all  claiming to possess specific advantages regarding the fulfilment of (varying) requirements. Here are one pro-quat and one anti- quat documents as examples.

 hsan4 - Fire-Soaps-Hand-and-Skin-Sanitizer-Data-Sheet.pdf   369.52KB   24 downloads

 

 hsan5 - alcohol vs non-alcohol based hand sanitizers.pdf   659.35KB   30 downloads

 

As a neutral viewpoint, here is the WHO’s opinion (2009) on quaternary hand sanitisers and other competitors –

 hsan6 - WHO guidelines hand hygiene in health care,2009.pdf   4.22MB   31 downloads

(see Pg35 et seq)

Although hsan6 is primarily oriented to a health care context some of the conclusions seem  disappointing  in view of all the efforts to promote quats for hand sanitisers in  food  manufacturing systems, eg

 

QACs are primarily bacteriostatic and fungistatic, although they are microbicidal against some organisms at high concentrations.

 

In 1994, the FDA TFM tentatively classified benzalkonium chloride and benzethonium chloride as Category IIISE active agents (insufficient data to classify as safe and effective for use as an antiseptic handwash).  Further evaluation of these agents by the FDA is in progress.

(maybe it has since been completed!)

 

A recent clinical study performed among surgical ICU HCWs found that cleaning hands with antimicrobial wipes containing a QAC was almost as effective as handwashing with plain soap and water, and that both were significantly less effective than decontaminating hands with an alcohol-based handrub.

 

Finally one more random, semi-pictorial, Canadian viewpoint, (happened to be anti-quat)  -

 

 hsan7 - DoBugsNeedDrugs five-minute-tips.pdf   3.65MB   17 downloads

 

Actually the Canadian scenario looks equally, if not more, confused than USA –

http://www.healthycl...sh/D S_pub.html

 

I do wonder if the recent European developments already mentioned will have any US impact.

 

Rgds / Charles,C

[Charles.C]

Dear All,

 

This is addenda to previous post regarding USDA hand sanitizers. Seems that I missed a portion  of  USDA’s history so my initial comments, eg hsan1, not the whole picture. Sorry about that.

 

Apparently FSIS’s program for the approval of nonfood compounds and proprietary substances for use in meat and poultry establishment ceased in 1999.

 

After FSIS announced its discontinuation of the approval program, NSF International - a not-for-profit, non-governmental organization - launched a voluntary Nonfood Compounds Registration Program to re-introduce the previous authorization program. All products used in and around food processing establishments (nonfood compounds), such as hand cleaners and sanitizers as well as hard surface sanitizers are now eligible for NSF listing. NSF listing assures inspection officials and processors that the product formulation and labels have been reviewed and meet appropriate food safety regulations.

 food safety and hand hygiene,2006.pdf   753.41KB   42 downloads

 

The official USDA version of the 1999 change appears to be described here –

 1999 changeover.pdf   6.7MB   27 downloads

(large file, may be a bit slow)

 

The introduction section is, IMO, rather obscure in its precise interpretation inasmuch as it “seems” (onwards) to be simultaneously approving both the established previous (pre-1999) recommendations and/or (?)  further added regulatory material ex FDA, eg see “2-301.16 Hand Sanitizers” in same document.

 

(Just as an aside this "USDA" document also has a comment on the use of dual function, hand cleaning stations ,–

 

2-301.15 Where to Wash

Food employees shall clean their hands in a handwashing lavatory or approved automatic handwashing facility and may not clean their hands in a sink used for food preparation, or in a service sink or a curbed cleaning facility used for the disposal of mop water and similar liquid waste. )

 

The two Appendices containing pre-1999 requirements are  no longer directly attached  but can be seen here (and on the USDA net) –

 

 appendices, pre1999.pdf   4.88MB   10 downloads

(especially see intro appendix1 and material beginning appendix2)

 

The relevant additional FDA-related material appears very similar to that in my previously attached hsanX documents.

 

The crux of the above as far as quaternary compounds are concerned is that they should (for hand use) be

listed somewhere in the variously stated reference documents. According to ISSA (2003), they (benzalkonium chloride) certainly appear in the fabled OTC, long time running, monograph where their “tentative” status as category3 is, as yet, neither approved/disapproved although (strangely?) sale is nonetheless permitted.  Based on various adverts, they are apparently approved by NSF (whose standards appear to require money). I am still rather unclear as to the precise linkage between NSF and USDA although obviously close -

 

http://www.foodsafet...establishments/.

http://www.nsf.org/s...s-publications/

 

There are a few (food-related) comments here and there that suggest alcohol–based  hand sanitizers may be  preferable but nothing definitive AFAIK. Such (alcohol) items are possibly also more easily matched to the regulatory aspects. For examples, here are 2 items, first more operational (see closing comments), second more “promotional” (see the nice-looking “validation” chart near the end –

 

 ground beef recall.pdf   792.16KB   11 downloads

 Alpet hand sanitiser.pdf   565.45KB   19 downloads

 

If some detail/opinions still missing, USA meat people here only too welcome to further enlarge my knowledge.

 

Rgds / Charles.C

 

PS -

 

Summary for  Quaternary Compounds Regarding  Approval for Use as Hand Sanitizer

 

(1) For Processes under FDA Jurisdiction

(a) Processes within Jurisdiction of Food Code Control (latest ed.2013)

Requirement – Compliance with Paragraphs such as in attachments hsan2,3 (updated to 2013 if necessary)

An example of  compliance data is in attachment (“Alpet ….”) in this post

 

(b) Processes not within Jurisdiction of Food Code

Eg seafood in general. Currently No Idea. Suggestions welcome.

 

(2) For Processes under USDA/FSIS Jurisdiction ( eg Meat / Poultry)

The following comments are speculative for reasons such as the rather bizarre last paragraph of the introduction in the attachment referred in (iii) below.

The possibilities seem to be –

(i) A chemical approved by USDA  prior 1999 (eg see appendix2 in attachment “appendices,pre 1999”)

(Presumably implies one of the  type “E” products. AFAI can see, there is no explicit mention of quaternary compounds.)

Or

(ii) A chemical “approved” by NSF, (presumably) since 1999

Or

(iii) A chemical approved as described in section 2.301.16 in the attachment “1999 changeover ….”

(this section is probably a direct extract from the Food Code, ie similar to (1)(a) above)

[FurFarmandFork]

Old topic, but from the 2017 FDA Investigations Operations Manual:

 

Determine the use, or absence of, sanitizing solutions both for sanitizing equipment and utensils as well as for hand dipping. If chlorine is used, 50 ppm - 200 ppm should be used for equipment and utensils, while a 100 ppm will suffice for hand dipping solutions. Sanitizing solutions rapidly lose strength with the addition of organic material. The strength of the solution should be checked several times during the inspection.

 

[OrRedFood]

Old topic, but from the 2017 FDA Investigations Operations Manual:

 

Hi Austin - This is an old thread but applies to my current question - The label for quat as a sanitizer says 1 minute contact time at 200 ppm as a hand dip.  Hand dips don't lend themselves to a 1-minute contact time when you are on a sorting line.  Chlorine get broken down so quickly that we can't keep up with monitoring and refreshing (this is a fruit canning/juice pasteurizing operation). Do you have any suggestions? I have been through so many audits where contact time was not even brought up for quat @200 ppm, but now that I'm thinking about it I want to be dure we are hand sanitizing effectively. Thanks!

[Scampi]

As long as hands are not being dried, you would get really close to the 1 min contact time by the time it air dries, and that time should be included in the contact time equation

[OrRedFood]

As long as hands are not being dried, you would get really close to the 1 min contact time by the time it air dries, and that time should be included in the contact time equation

Excellent point.  It's such an industry wide practice, it doesn't make sense that anyone would dip their hands and then count to 60 before returning to the sorting line. Thanks!

[GMO]

Blimey... Why is my first question?  Why not insist on hand washing and buy in gloves which are uncontaminated?

 

And then there's the question on whether gloves are a good idea anyway.  They're a risk of making people think they're being more hygienic than they are.

 

I've never encountered hand dips for gloves.  Ever.  The foot baths were removed years ago in most places as they become more of a hazard than what they were trying to solve.  Has anyone actually demonstrated there is a risk which these glove baths are controlling or is it just assumed?

[MDaleDDF]

Blimey... Why is my first question?  Why not insist on hand washing and buy in gloves which are uncontaminated?

 

And then there's the question on whether gloves are a good idea anyway.  They're a risk of making people think they're being more hygienic than they are.

 

I've never encountered hand dips for gloves.  Ever.  The foot baths were removed years ago in most places as they become more of a hazard than what they were trying to solve.  Has anyone actually demonstrated there is a risk which these glove baths are controlling or is it just assumed?

The food business rules at two things.    Akronym overuse, and solutions in search of a problem.....lol.

Not that I want to wade into this issue.  Beyond my experience, and interest...