WQA v8 13.2 - Equipment shall not be washed on the floor

Hi everyone,

We're a company that is complying with WQA v8 and we are struggling with one of the requirements in the standard.

WQA v8 13.2 pg 49 says

"equipment shall not be washed on the floor".

In order for us to clean our equipment, we need to pull apart large stainless steel pieces, wash them individually and assemble the pieces back together. 

The operators usually sit the equipment against a wall, wash it with detergent, rinse it down and after it has dried assemble the pieces back onto the machine.

With this standard I have now provided a plastic pallet that they need to wash the equipment on. For this to happen they have to carry the heavy pieces over to where the plastic pallet is, wash it there and bring the equipment back to the machine. (Before they washed it on the floor close to the machine) This is a labourous job and they keep questioning me as to what the 'big' difference is between washing it on a plastic pallet or on the floor.

I can sort of relate to what the operators are saying, I mean in the end the bottom of the equipment is only coming in contact with the equipment right? And we rinse the bottom down before it gets placed back onto the machine..

Am I being too dismissive of the danger of washing the equipment on the floor?

If others are complying to this standard what methods are you using?

Thanks in advance

I can sort of relate to what the operators are saying, I mean in the end the bottom of the equipment is only coming in contact with the floor** right?

Equipment shall not be washed on the floor. The word shall means its a strict rule unlike the word should and for good reason. The floor is one of the dirtiest areas of your production. You don't want to run the risk of contamination/cross contamination. One you're placing it on the floor and you're more than likely hitting it with a high pressure hose which in turn you're contaminating more than just that piece of equipment. Let's try to put this in a day to day perspective: If I place a spoon on the floor and wash it on the floor and then rinse it and hand it to you to eat, would you feel comfortable eating from that spoon? Using the 5S rule "a place for everything and everything in its place" and the floor is not for equipment. You're on the right path, however in order to make it more ergonomic I would suggest you use a heavy duty utility cart to place the equipment on to clean.

Dear kedelai,

The nature of the equipment / cleanliness might be relevant. and the product / process. And the location, ie risk assessment.

I hope we are not discussing the internal components of an oil-lubricated compressor. :smile:

Regardless, appropriately placed sheets of rigid plastic or thin SS (quite cheap these days) might perhaps alleviate the problem ?

Rgds / Charles.C

depends on the size of the equipment but maybe use a plastic pallet to wash the equipment on and keep the pallet clean at all times

The floor is where every bad thing ends up.  A lot of bacteria could be present on the floor even between cleaning.  This is why nothing should be stored, cleaned, etc on the floor.

How about a rolling rack like a bakers rack?  Like other people have said nobody knows the size of what is being cleaned but a bakers rack style cart allows the water to flow over the equipment and will go to the floor.  It would need to be cleaned, of course, but it will help transport the equipment being cleaned as well as facilitate keeping the equipment off the floor while being cleaned.

By bakers rack I'm thinking of the metal mesh type of things.  They are typically really tall and on wheels but I believe you can get shorter ones.

kind of like this is what I envision:

just shorter

Details will allow us to be more helpful. 

Washing food contact items directly on the floor or placing (storing) food contact items (bins, trays, tubs, etc.) directly on the floor is the quickest way to get written up (Noncompliance Record) by the USDA.  I should know, I wrote this particular noncompliance many times as an inspector.  And it still makes me twitch when I see it as a QA Manager.

If the cleaning crew finds the equipment to heavy or cumbersome to move to and from the cleaning area and plastic pallet, perhaps providing several plastic pallets for more of a "Clean-in Place, rather than drag it into the next zip code" might work better

Sounds like everyone there realizes that the plastic pallet isn't really providing any protection from the floor.  

In the past I've used plastic pallets for large (room sized) equipment.  But those items literally took two days to disassemble, and were 8 pallets across.   For anything you're taking apart regularly, I'm used to having
1. two - man lift onto an adjustable cart with wheels

2. Move the cart to the sink or sanitation room (follow traffic control / alcohol wheel sprays where needed)

3. Move the equipment into the sink OR a flat metal table with slats on the wall

4. Clean with high pressure hose / 3 compartment sink /  whatever

5. Move back with cart

A rack on wheels sounds like the best option, a picture would help Kedelai

Thank you everyone for your input.

The rack is a good idea, but it's just becomes another object to clean afterwards and I think the operators won't like that.

The plastic pallet has been working for us so far - with grumbling employees.

Thanks again!

A quick question regarding the above.

Is there a specific call out not to wash items directly on the floor?  I just need to prove with a written regulation, not just common sense that this is an absolute requirement....FDA code, Food safety regulation or SQF section requirement would be great!

thanks, herb