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SQF Code: 11.2.2.2 - Rooms Without Drains


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#1 Ekivlen

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Posted 20 June 2014 - 02:45 PM

I'm in the process of obtaining a level III certification and trying to retro-fit a building into SQF requirements. 

A couple production rooms in the facility are lacking floor drains and plumbing. I've got to ask the critical question of whether or not anyone has experienced this and/or had any success in making it work. 

 

 

As it states in the SQF Code: 11.2.2.2 Floors should be sloped to floor drains at gradients suitable to allow the effective removal of all overflow or waste water under normal working conditions.

 

To date, this facility has scored in the high 90's in third party audits, passed several state and federal audits, and undergone numerous customer audits that have given high praises for facilities care. 

 

Has anyone ever established a no-drain program? Would a floor machine that cleans, sanitizes, and vacuums the water all at once suffice? 

 

Thank you in advance.



#2 Charles.C

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Posted 20 June 2014 - 04:17 PM

Dear ekivlen,

 

Some info. regarding yr product / process would assist.

 

I hope its a dry process. Otherwise, for me, yr situation is "challenging" or more precisely - it sounds unworkable.

 

But i hope to be proven wrong.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#3 Ekivlen

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Posted 20 June 2014 - 06:11 PM

Charles C.: We are a USDA/FDA food processing facility. Approximately 20,000 square feet in size. Approximately 95% of our items are classified heat treated, not fully cooked, not shelf stable. We do produce a fully cooked line as well. We prepare raw, process, package, freeze, and ship. 

 

To date our sanitation process for room cleaning without floor drains is squeegee to a dry mop and pull up by hand. This is conducted multiple times per day as numerous line changes take place per day ---> Supremely inefficient, but funding will be allocated in order to accomplish an SQF certification. I'm wondering whether we can make it happen by simply purchasing a floor machine or if the substantial investment must be needed in order to drill through concrete to tie into existing plumbing for a floor drain.



#4 Charles.C

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Posted 21 June 2014 - 03:54 AM

Dear ekivlen,

 

Thks yr input.

 

Seems this could be meat, poultry, seafood, fresh or permutations thereof.

 

I assume your intended SQF scope is for all.

 

Frankly i am rather amazed that you are USDA/FDA approved. For myself this is a unique scenario for a seemingly large scale, wet process but maybe not in USA / yr product(s). Must have some interesting microbiological control concerns, eg Listeria.

 

 i hv never used SQF but I can predict an initial SQF question ? What is the FS / Risk Assesment ?

 

Any risk assessment  relates to the specific product / process. Other things being equal,  the RTE material will be a primary focus as i am sure you are aware.

 

Since it appears that the facility is probably "unmatchable" to the basic drainage expectations of SQF, i imagine it will be necessary to demonstrate that no significant product FS risk has thereby ensued. Maybe yr official approval status, especially for fully cooked goods,  will satisfy that requirement. It probably depends on what data is used to achieve the current approved status.

 

Hopefully some USA (or perhaps anyone/SQF) posters here will have direct experience of yr type of situation.??

 

Rgds / Charles.C

 

PS - i have encountered facilities using vacuum equipment in wet processsing but only to solve the concomitant removal of cooking oil from floors vis-a-vis local environmental drainage BOD limitations. From memory, was not a cheap enterprise.


Kind Regards,

 

Charles.C


#5 Mulan1010

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Posted 25 June 2014 - 09:47 PM

Dear Ekivlen,

 

In my experience with SQF (5 years), Charles.C is giving you some great advice.  If you do not meet the code as it is written then you must provide the auditor with a risk assessment explaining your procedures along with some type of validation that the procedures are effective.  The simplest way I have found to validate something is effective is with sampling results.  If you do not have any sampling results then you might consider taking some samples to validate your procedures are effective.

 

If you do go with a floor machine, plan on developing a preventive maintenance plan and sanitary procedures because the equipment itself could possibly become a source of cross-contamination if it is not well maintained.  Also, if you change your procedure to the floor machine then you will need new data to validate the new procedures are effective.

 

I hope this helps.

 

Best Regards,

Lee.M



#6 FoodChick

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Posted 26 June 2014 - 12:30 PM

I am also in a facility that was not originally constructed as a food manufacturing facility so the drains are not in the ideal locations, to say the least.  The guidance document for SQF Edition 7.1 states "Where drainage and gradients are not ideal, a written SOP shall address the timely and effective removal of waste water to a drain."  This is what we did for our SQF Level II audit, we put procedures into place to deal with floor areas that were not correctly designed or constructed as doing so would be a very costly project.  We have a drain cleaning program for the drains we do have and then a procedure for removal of water where we have no drains (or a no-drain program as you phrased it). 

 

It sounds like you have sanitation procedures in place for the removal of standing water but make sure they are clearly documented with method and frequency.  Make sure the frequency is adequate as standing water can present a possible risk  Then follow up with Charles' good advice and do a risk assessment that the procedure you have in place are effective. 

 

My facility is SQF Level II certified so it is certainly possible to pass with less than ideal conditions under 11.2.2.2 with the proper risk assessment and procedures.



#7 Ekivlen

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Posted 27 June 2014 - 02:14 PM

Thank you for all the responses. Some great advice.

 

They confirmed my thoughts exactly. $15,000 to route a drain into the room or invest much less money and time into validating a program designed to ensure safety and compliance. I would assume, as with all other control points, the pathogen of concern would be Lm. Correct me if you should differ in opinion. 



#8 papulus

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Posted 26 March 2017 - 05:56 PM

I am also in a facility that was not originally constructed as a food manufacturing facility so the drains are not in the ideal locations, to say the least.  The guidance document for SQF Edition 7.1 states "Where drainage and gradients are not ideal, a written SOP shall address the timely and effective removal of waste water to a drain."  This is what we did for our SQF Level II audit, we put procedures into place to deal with floor areas that were not correctly designed or constructed as doing so would be a very costly project.  We have a drain cleaning program for the drains we do have and then a procedure for removal of water where we have no drains (or a no-drain program as you phrased it). 

 

It sounds like you have sanitation procedures in place for the removal of standing water but make sure they are clearly documented with method and frequency.  Make sure the frequency is adequate as standing water can present a possible risk  Then follow up with Charles' good advice and do a risk assessment that the procedure you have in place are effective. 

 

My facility is SQF Level II certified so it is certainly possible to pass with less than ideal conditions under 11.2.2.2 with the proper risk assessment and procedures.

 

Hello, I don't have any experience with SQF but I need to write SOP for "Where drainage and gradients are not ideal, a written SOP shall address the timely and effective removal of waste water to a drain." Can you sent me some example .

Thanks,

Rob



#9 FoodChick

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Posted 10 April 2017 - 02:36 PM

You need to do an analysis to determine "timely" and what method is "effective."  For example:  "Every hour, plus or minus 10 minutes, the operator will use a blue squeegee to remove standing water underneath the XX towards Drain #1."   Or maybe it only needs to be done 2 times a shift, etc. 



#10 Charles.C

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Posted 11 April 2017 - 01:41 AM

Unfortunately the original OP never revealed the product of specific interest/its risk status.

The primary hazard was likely to be microbiolgical particularly as related to basic GMP/Prerequisite limitations.

3 years on, I still find it "remarkable" that FDA/USFDA (apparently) approved a (water?) wet RTE(?) cooking line in an environment with no drains.

 

@Rob, IMO you need to clarify the Product and the Process for meaningful comment, SQF or otherwise.


Kind Regards,

 

Charles.C





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