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Interpretation of 4.8.1 (high risk): hand washing facilities


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Fien

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Posted 22 August 2014 - 08:38 PM

Hello,

 

1/can someone give a clear interpretation of the sentence: '...handwashing facilities shall be sited at the entrance to the production area.'

 

We just had an external audit and the auditor gave us a major remark because we do not have handwashing facilities inside the production area immediately at the doors coming into production area!

 

But the toilets, with handwashing facility, are situated right next to the entrance door going into the production area! And at each working place handwashing facility is also avalable. All with the required warm water, soap, towels, ... as specified in 4.8.1 of BRC Iop.

 

Additional, at the inside of the production site, at each entrance door, dispensers with disinfectant product is avalable!

 

+ in our instructions to staff and visitors about hygiene, handwashing before entering production area has been mentionned...

 

2/The auditor also wants us to prove everyone entering the production site has clean hands, free of bacteria!

 

Are these fair points, or is this auditor simply overreacting...?!

 

Thank you to anyone replying...

 

Fien


Edited by Charles.C, 25 August 2014 - 02:17 AM.
topic moved from food > packaging


MCIAN

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Posted 23 August 2014 - 04:35 AM

Hi Fien!

 

Welcome to IFSQN!

 

What about your changing area? You did not mention it. I asked because that is where our main employees handwashing sinks are located. The sink at the toilets are different from the main entrance sink. We did not put sink inside our production area since that would invite bacteria into the area because of the moisture and our packaging are all paper based.

 

i guess if you can prove through hazard analysis that you are 'safe' with what u have and support that with micro test results, the auditor might accept.

 

btw, what type of external audit was that?

 

 

Regards

 

 

 

:gleam:


Edited by MCIAN, 23 August 2014 - 04:36 AM.


jel

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Posted 23 August 2014 - 04:39 AM

On the second point, since it is literally impossible to prove that the hands of all those who enter the production site have their hands free of bacteria, could do a test (in fact it is something that should be done) with a statistically representative sample of the population to evaluate the entire process of hand washing. 
 
Regarding the first point, I think the auditor is overreacting, and like many auditors, understand the requirements of the respective standard they are auditing, but they don't known about food safety. 
 
An auditor must see the whole forest, not just the trees individually. 
 
Are you getting generate safety products? The purpose of each of the requirements is that


Charles.C

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Posted 23 August 2014 - 10:35 AM

Hello,

 

1/can someone give a clear interpretation of the sentence: '...handwashing facilities shall be sited at the entrance to the production area.'

 

We just had an external audit and the auditor gave us a major remark because we do not have handwashing facilities inside the production area immediately at the doors coming into production area!

 

But the toilets, with handwashing facility, are situated right next to the entrance door going into the production area! And at each working place handwashing facility is also avalable. All with the required warm water, soap, towels, ... as specified in 4.8.1 of BRC Iop.

 

Additional, at the inside of the production site, at each entrance door, dispensers with disinfectant product is avalable!

 

+ in our instructions to staff and visitors about hygiene, handwashing before entering production area has been mentionned...

 

2/The auditor also wants us to prove everyone entering the production site has clean hands, free of bacteria!

 

Are these fair points, or is this auditor simply overreacting...?!

 

Thank you to anyone replying...

 

Fien

Dear Fien,

 

I presume yr post relates to packaging although posted in food forum ?

 

i am familiar with BRC food but can offer an opinion anyway.

 

handwashing facilities shall be sited at the entrance to the production area.'

 

IMEX this means a handwashing station is installed "immediately"  prior to the entry point into the high risk production area.

 

I found yr post a little unclear so unsure whether that matches yr present arrangement as described or not.

 

IMEX, it is considered not good practice to locate toilets in close proximity to the entrance to a production area. From a BRC auditor's POV, i would not expect a handwashing station designated for toilets to replace that mentioned in the quoted extract.

 

Regarding hands, for food, AFAIK there are no uniform microbiological standards for "clean" although opinions for  typical levels of non-pathogenic species exist for some processes / locations. Pathogens such as Salmonella would be expected to be undetected.

It is possible to purchase "simulation" kits for assessing efficiency of handwashing, eg 

http://www.glogerm.com/ 

(some textbooks also consider monitoring the overall bacterial levels on hands to be a waste of time)

 

Rgds / Charles.C

 

PS - for food/ HR production area, BRC typically demands a completely segregated, changing room - handwashing section but perhaps the requirements for packaging production are less rigorous. :dunno:


Kind Regards,

 

Charles.C


Mike Green

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Posted 23 August 2014 - 04:06 PM

Hello,

 

1/can someone give a clear interpretation of the sentence: '...handwashing facilities shall be sited at the entrance to the production area.'

 

We just had an external audit and the auditor gave us a major remark because we do not have handwashing facilities inside the production area immediately at the doors coming into production area!

 

But the toilets, with handwashing facility, are situated right next to the entrance door going into the production area! And at each working place handwashing facility is also avalable. All with the required warm water, soap, towels, ... as specified in 4.8.1 of BRC Iop.

 

Additional, at the inside of the production site, at each entrance door, dispensers with disinfectant product is avalable!

 

+ in our instructions to staff and visitors about hygiene, handwashing before entering production area has been mentionned...

 

2/The auditor also wants us to prove everyone entering the production site has clean hands, free of bacteria!

 

Are these fair points, or is this auditor simply overreacting...?!

 

Thank you to anyone replying...

 

Fien

 

Ah my favourite topic!!!

 

IMO -if the auditor specified that you must prove that hands are bacteria free on enetring the production area-he is living on a different planet-that is impossible

 

Regarding location of sinks-for me, the ones in the toilet are obviously important to have-but in this instance are irrelevant(as stated above)- I would also discount the chemical sanitiser stations (unless they were sited for use after handwashing on clean hands)

 

I have seen sinks just inside & just outside the production area work just as well as eachother-(or just as badly)-I personally prefer just inside as it is more obvious to everyone when hands are being washed and therefore IMO it's more likely to happen!!!!

 

By far the most important aspect in handwashing is effectiveness of technique (as intinmated by Charles,C above) and the 'simulated germ' kits are excellent for this purpose.and IMEX a regular program of training and retraining and effective supervision (along with random swabs if you like) is the best way to prove effectiveness of handwashing irrespective of sink location!

 

Kind Regards

Mike


I may sound like a complete idiot...but actually there are a couple of bits missing

Fien

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Posted 24 August 2014 - 08:00 PM

Hello Everyone,

 

thank you for posting your opinions, it gives me ideas to take actions concerning this topic since we have only 28 days to do so.

 

Answers to some questions:

 

1/ changing area's are located on first floor, no sinks avalable there

2/ external auditor was a subcontractor for Lloyd's Register

3/ my post relates to packaging (BRC - IoP, but high risk level), we print for example in-mould labels

 

I think safest way to handle this will be making hazard analysis + purchase a kit, do random swabs + give extra training and plan retraining

 

Installing sinks is technically impossible and would not solve the question of proving hands are clean enough...

 

Still, we were very dissappointed because in his closing meeting the auditor mentionned it was the cleanest and most organised place he ever audited!?

But ok, standards have to be applied :)

 

Thanks for the advice!

 

fien

 






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