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SQF 11.3.9.1 - Airlock Restrooms?

SQF toilet rooms; airlock;

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#1 SQF Queen

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Posted 20 March 2015 - 08:04 PM

SQF 7.2 code states:

11.3.9.1 Toilet rooms shall be:

i. Designed and constructed so that they are accessible to staff and separate from any processing and food handling operations;
ii. Accessed from the processing area via an airlock vented to the exterior or through an adjoining room;
 
So I need some advice and opinions.
 
In some of my facilities we have restrooms that open directly into the processing area.  In the past USDA has always considered negative pressure to be sufficient but this question came up this week during another discussion and I want to make sure that the plants that this affects are covered before their audit.  The plants with negative pressure have fans vented tot he outside that are sufficient to draw a flame around the door, which is the method that we have seen USDA use in the past. I have never dealt with an "airlock" and in 2 plants in particular constructing an adjoining room would be out of the question, it would require new construction to move the rest rooms completely.
 
Any suggestions or input is greatly appreciated.
 
Thank you 



#2 RG3

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Posted 20 March 2015 - 08:42 PM

SQF Queen,

 

   What I have done in the past is put up a false wall between the toilet and the sink to break the flow between the toilet and the door that leads out into production. This appeared to suffice all the auditors we had. Only a suggestion from experience, but I'm sure Charles C. can dig up some sort of literature for you.



#3 Slab

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Posted 20 March 2015 - 11:44 PM

SQF 7.2 code states:

11.3.9.1 Toilet rooms shall be:

i. Designed and constructed so that they are accessible to staff and separate from any processing and food handling operations;
ii. Accessed from the processing area via an airlock vented to the exterior or through an adjoining room;
 
So I need some advice and opinions.
 
In some of my facilities we have restrooms that open directly into the processing area.  In the past USDA has always considered negative pressure to be sufficient but this question came up this week during another discussion and I want to make sure that the plants that this affects are covered before their audit.  The plants with negative pressure have fans vented tot he outside that are sufficient to draw a flame around the door, which is the method that we have seen USDA use in the past. I have never dealt with an "airlock" and in 2 plants in particular constructing an adjoining room would be out of the question, it would require new construction to move the rest rooms completely.
 
Any suggestions or input is greatly appreciated.
 
Thank you 

 

Hi, SQF Queen;

 

I assume you mean positive air? An "airlock" is simply just a barrier of air pressure differential (i.e. room and door). You would require positive air or validate air quality in processing areas with environmental testing to prove control on this section. I would like to ask as well what your processing risk is. Are you low risk raw etc?


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#4 Charles.C

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Posted 21 March 2015 - 12:09 AM

SQF Queen,

Thanks for yr query and Welcome to the Forum !

 

I noted the oft-magic word "shall" in the quoted Code.

Typically, shall = Compulsory however SQF can be sometimes illogical, both wrt to the Code and their own Guidance.

 

From the Guidance manual -

 

Restroom/toilet facilities must be located so that they do not open directly into the processing area.  In
existing facilities where they are in close proximity to areas where product is exposed, an airlock vented to the
exterior must be maintained (negative pressure).  Staff shall enter toilet rooms from processing areas through
either an intervening change room or air lock which is ventilated to external air.  
Where exhaust fans are fitted, they must be exhausted to the outside and not into a food production area.  
The light and exhaust fan can be inter-wired to create negative pressure as an option or the light and exhaust
fan can be left on continuously.   
To eliminate the risk of air flow from restrooms into the processing room, exhaust fan off-switches may be on
timer delay.  The light and exhaust fan may be on a single switch located on the outside of the restroom.

 

 

Based on the above i would surmise you may have a difficulty. SQF/USDA users (unlike myself) may be better able to advise on the precise scope of the clause's auditorial requirements.

 

Maybe also see this thread -

 

http://www.ifsqn.com...cks/#entry56674

 

@RG3 - i appreciate yr commendation.

TBH  my first thought was that the query concerned food processing on a Space Station. Airlock is not a particularly familiar food term  IMEX.

I am fortunate to have mostly worked in relatively expansive facilities which possessed corridoors/hallways. But some of the toilet facilities I have encountered as an auditor (not targetting GFSI recognition) did require a more flexible tolerance than maybe at present.


Kind Regards,

 

Charles.C


#5 SQF Queen

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Posted 21 March 2015 - 12:41 AM

I work for a shell egg processing plant. So we are considered a high risk product but a low risk process, if that makes sense. Because of the natural protective barrier of the shell, shell membrane, and the cuticle, we have a low risk of our product being contaminated.

My issue with using the guidance document as my frame of reference to solve this problem is that it has not been updated for many of the changes that have evolved in SQF with the version changes.

I understand the negative pressure concept and that is what we have used in the past. It has always sufficed when we used the USDA plant systems audit but now with the wording of the code I am just not sure. I don't really want to leave it up to an auditor to find and write it up on my audit and have a small time frame to correct what might well require a large scale construction project.

The plant in question is a very small facility and building a room outside the restroom to meet the code is not feasible.

Could I possibly build a complete wall (floor to ceiling) with a door inside the room between the toilet and the sink and relocate the vent fan over the toilet? Would that be able to be considered a room to separate the toilet facility from the plant?
Or should my negative pressure (drawing air into the restroom and vented to the outside to prevent the air in the room from exiting into the plant) suffice?
How do I go about proving that my negative pressure is high enough?
Is there a known regulation in any food sector that addresses this issue that I could possibly use as a frame of reference to try to figure out what to do? (I haven't found one yet but I am by far not an expert on any other food processing regulations)

Any and all thoughts are a huge help!

Thank you



#6 Spudslinger

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Posted 05 March 2021 - 04:40 PM

Would something as simple as a plastic curtain over the door frame suffice? Our bathrooms open near processing, but the product is enclosed in dryers, about 15 meters around the corner is an exposed conveyor with product. We are not human grade, and we dehydrate potatoes. 



#7 Charles.C

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Posted 05 March 2021 - 05:18 PM

Would something as simple as a plastic curtain over the door frame suffice? Our bathrooms open near processing, but the product is enclosed in dryers, about 15 meters around the corner is an exposed conveyor with product. We are not human grade, and we dehydrate potatoes. 

 

Hi Spudslinger,

 

Thks input.

 

^^^ - Robots ?

 

Interesting that 6 years later the  same 2 clauses seem to be essentially unchanged albeit expanded.

 

I'm curious, do you have SQF certification ?


Kind Regards,

 

Charles.C


#8 Spudslinger

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Posted 05 March 2021 - 05:24 PM

Hi Spudslinger,

 

Thks input.

 

^^^ - Robots ?

 

Interesting that 6 years later the  same 2 clauses seem to be essentially unchanged albeit expanded.

 

I'm curious, do you have SQF certification ?

 

 

Yes we just had our 3rd SQF audit, and it had never been an issue in the past. Whether it was just overlooked prior years, we did receive it as a non-conformance this year. We are just curious if a curtain is enough. The bathroom doors open into the bathroom, they are fairly small already. So I can't see us putting a temporary wall inside the bathroom entrance. Also, we can't extend the wall outside of the bathroom, because we wouldn't be able to drive a forklift through the walkway. 







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