Issue with sanitation chemical hoses in sink - Help!

We were recently inspected by the FDA.  While the inspector did not officially cite us for any violations, we were advised that the hoses connected to our chemical mixing stations did not meet regulations because they were below the water line and could cause "contamination". 

To explain this more clearly, we have 3-compartment sinks in our processing rooms to wash small parts, utensils, etc.  We have an automated mixing station that pumps the cleaning or sanitizing agent to the appropriate sink premixed at the right strength.  The mixing station has a backflow device so that was not the issue.  The inspector was concerned that the outside of the hose would become dirty and contaminate the water.  Following that logic, the whole sink and water is dirty from the minute you wash the first utensil or equipment part.  That is why you have 3 compartments, and you empty and refill when needed - duh.    Our crew is very diligent, and sinks and hoses are cleaned whenever the sinks are emptied.

Has anyone ever heard of such a thing?  We are planning to mount the hoses to the sink and cut the length above the water line to appease the inspectior, but I am getting push back from maintenance.  Any advice?  Am I missing a piece of the puzzle? :uhm:

As always, thanks for your input.

Hi Jennifer,

I have never heard something like this before however can see the inspectors logic. Does the hose drape in to the sink and potentially dirty water or on to the floor when not in use? If so, what could happen is that if you have filled two sinks, one containing detergent, the other sanitiser and in the detergent sink is an allergen, if the hose touches the water it will transfer the allergen to the end of the hose. Then, if you move the hose in to the sanitiser sink you will transfer that allergen to the next sink. It sounds pretty 'over the top' though, especially as everything is being thoroughly cleaned.

You could always conduct a risk assessment to see what the possible risk is of cross contamination. That way when the inspector returns you can show them. Inspectors are not always correct and providing you can justify your decisions sometimes they will be fine by your decision. 

Alternatively just do what the inspector asks and be assertive with maintenance, at least this way, when the inspector returns they will see you are listening and reacting in a positive way to their comments - which can only be a good thing.

Many thanks

Simon

Thanks for your comments, Simon.  We agree that it was a little 'over the top', especially since each sink has its own hose and are not transferred from 'dirty' water to clean water or sanitizer.  However, it was a cheap and easy fix once maintenance stopped grumbling.  We just went ahead and mounted the hoses.  It was one of those issues that was easier to address than do the justification of why we were right. 

Again, thanks for your input.

Hi, Jennifer;

I've been through both Servsafe and FDA audits and this issue was always a key point.  It's a good practice to have the feed line trimmed and fixed (eliminating more handling i.e. cross-contamination) to a minimum of 2x the diameter above the fluid level (and not mentioned specifically in your audit) to reduce contamination of the ID of the line in question.  The logic simply being; the less hand work the lower the risk. Never been gigged, but it's always an inspection point by auditors. 

Just for an update;

I had an interesting conversation about this with a plumbing contractor on the topic.  It seems the origin is with public water regulations and what is called an "air gap" on hoses that may be immersed in liquid considered "other than safe" for potable backflow. Normally chemical feeds lack backflow/vacuum break prevention on mixing vessels and hence becomes a point of inspection for state/federal investigators.  It would appear to be something as grandfathered in from older building codes during investigations.  The contractor's advice was to keep feed lines at least 1.5x the diameter of the line (but not less than one inch) above the maximum vessel fluid level.  

Just for an update;

 

I had an interesting conversation about this with a plumbing contractor on the topic.  It seems the origin is with public water regulations and what is called an "air gap" on hoses that may be immersed in liquid considered "other than safe" for potable backflow. Normally chemical feeds lack backflow/vacuum break prevention on mixing vessels and hence becomes a point of inspection for state/federal investigators.  It would appear to be something as grandfathered in from older building codes during investigations.  The contractor's advice was to keep feed lines at least 1.5x the diameter of the line (but not less than one inch) above the maximum vessel fluid level.  

Thanks for the update - as strange as this may sound, I have been watching this thread as we are redesigning our sanitation room :)

Thanks for the update - as strange as this may sound, I have been watching this thread as we are redesigning our sanitation room :)

This one was kind of driving me crazy since our last FDA audit (of course the investigator made a b-line for the first fill station he observed) and questioned me on the air gap.  He was unable to quote any reg on the matter but said it fell under point one of our daily sanitation check for water safety as explained below.

From the Wiki;

A simple example is the space between a wall mounted faucet and the sink rim (this space is the air gap). Water can easily flow from the faucet into the sink, but there is no way that water can flow from the sink into the faucet without modifying the system. This arrangement will prevent any contaminants in the sink from flowing into the potable water system by siphonage and is the least expensive form of backflow prevention.

 

So essentially if a siphonage occurs in your facility (momentary loss of positive flow), then contaminants can be drawn into your plumbing and when positive flow is regained these contaminants reenter the facility at other points (food contact surfaces, processing stations, etc.) 

Hopefully that explains the logic behind it. 

Actually, we confirmed that our mixing stations are equipped with backflow prevention devices, so siphonage is not an issue.  Like I said, it was an easy fix to cut and mount the hoses. Not a big enough issue to quibble about with the inspector.   

Thanks for all of the feedback and comments on the issue.  I feel better prepared for the next inspection.