Hey Gang. Long time lurker here with my first post. I could use some advice for conforming to 13.3.2 Hand Washing in the SQF standard.
My company makes flexible packaging material (films, laminations, foils, etc.) that we sell to food packers who will form a pouch from our material and fill or use as lid stock. We have been certified to AIB for many years, but are now going for SQF in Q2 2014. Some of the requirements for Hand Washing are new to us and we have gaps to close, and I could use some help understanding the requirement and how to conform.
In particular, 220.127.116.11.i says that "hands shall be washed on entering product contact areas". I plan to install hand washing stations at all employee entrances to production area. This will take care of personnel when entering production area and whenever a wash is needed after entry, but I'm not sure what to do about my forklift drivers who may need to go outside.
We have two ground level overhead doors at my dock that we use regularly anytime a forlift needs to be outside. We have some production waste (hot plastic) in steel bins that goes outside by forklift to cool and is then brought back in to the dock once cool and loaded onto a trailer for recycling. There are other ocasional reasons like side loading maintenance items or new equiment off of a fladbed.
Does this qualify as my forklift driver "entering product contact areas" when he comes back in to the plant? I consider my dock as a GMP area. The forklifts are kept clean and the driver never gets off the truck. Do I need a hand wash station next to my dock? Getting on/off truck to wash hands will kill me logistically.
Do keep in mind that I don't have any "food" in my plant. Just paper/poly film/poly beads/foil/ink/adhesives/etc. Equipment is large printing presses, laminators, extruders, unwinds/rewinds, slitters, etc. We are not a "no-risk", but certainly a low risk operation.