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Waterless hand cleaners? Anyone use? Any issues? Any suggestions?

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#1 Nancy@Masser's

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Posted 08 September 2015 - 06:08 PM

Hello:

I don't know if this topic has been discussed at some point and I apologize if it has.

 

We are an SQF Level 3 produce facility (mainly fresh potatoes, not RTE).  We have a packing room that currently does not have easy access to hand washing areas.  We've had to utilize this space, realizing it is not optimum, due to space issues at our facility. There is potable water available to the room, but no outlet for gray water.  So we are challenged in providing a hand wash station in this area.  Naturally, employees can wash their hands in the main part of the facility and arrive in this room with clean hands, but if they do a "dirty" task once there, they have no place to re-wash their hands in order to handle product again. 

 

My question is, would a waterless hand cleaner be acceptable for this room?  Has anyone else who is SQF certified have any experience with using these?  Is this acceptable?  Can anyone suggest a good brand of such?

 

Thanks!



#2 fcchoi

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Posted 09 September 2015 - 02:36 PM

do not believe in such a thing as waterless hand cleaners, myth...



#3 SQFconsultant

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Posted 10 September 2015 - 02:13 PM

Nope, hand cleaner will not be acceptable - you can find a portable hand washing sink complete with hot/cold water tanks and grey water waste tanks along with all the requirements that will comply with SQF Code Level III and put the proper mix into place.


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#4 esquef

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Posted 11 September 2015 - 04:47 PM

We have sanitizer dispensers scattered around our facility, but we also have an ample amount of proper hand wash stations also. The sanitizer dispensers were installed before GFSI benchmarked the requirement for hot water/dedicated hand washing sinks/disposable paper towel dispensers/trash receptacle stations and the sanitizer stations remained. We train our employees that in no way sanitizer is to be used in place of hand washing so the sanitizer dispensers really should be removed. During an FDA inspection the investigator said that although the sanitizer dispensers wasn't a violation of any kind but that due to the fact that they are in no way an acceptable substitute for proper hand washing and she didn't really like to see them in food processing plants. Another Corrective Action Register item that the boss will love.   :shades:   



#5 Simon

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Posted 17 September 2015 - 02:49 PM

I would question why they are getting their hands "dirty" in a food facility.  If is due to touching dirty machines or equipment then the cleaning schedule is not effective. If it is cause by handling packaging, you need to work with your suppliers.  You need to address the root cause.

 

Just my two pence...for what it's worth. :smile:

 

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Simon


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#6 esquef

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Posted 18 September 2015 - 08:25 PM

I would question why they are getting their hands "dirty" in a food facility.  If is due to touching dirty machines or equipment then the cleaning schedule is not effective. If it is cause by handling packaging, you need to work with your suppliers.  You need to address the root cause.

 

Just my two pence...for what it's worth. :smile:

 

Regards,

Simon

 

Simon,

 

In the U.S. the floor of a food producer is legally considered to be "filthy", so therefore anything that touches the floor becomes unsanitary either by cross-contamination (pathogens) or cross-contact (allergens).



#7 Charles.C

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Posted 18 September 2015 - 11:06 PM

Hi Nancy,

 

From an SQF POV, it presumably depends on what it says in the text in SQF. ??? Or perhaps what it doesn't say ???

 

Never encountered "grey/gray"  water. Does this mean "filthy" ?

 

@esquef - Referring yr post 4, I cannot find any evidence that GFSI specifies hot or warm water for hand washing ?? Perhaps a cGMP ? iso 22002 ?

 

http://www.foodsafet...ng-food-safety/

 

Attached File  GFSI_Guidance_Document.pdf   1.65MB   34 downloads


Kind Regards,

 

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#8 MWidra

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Posted 19 September 2015 - 01:38 AM

Hi Nancy,

 

From an SQF POV, it presumably depends on what it says in the text in SQF. ??? Or perhaps what it doesn't say ???

 

Never encountered "grey/gray"  water. Does this mean "filthy" ?

 

@esquef - Referring yr post 4, I cannot find any evidence that GFSI specifies hot or warm water for hand washing ?? Perhaps a cGMP ? iso 22002 ?

 

http://www.foodsafet...ng-food-safety/

 

attachicon.gifGFSI_Guidance_Document.pdf

Greywater is a commonly used term in English speaking countries for any waste water that does not contain fecal material or urine.  The water that people would wash their hands with is potable (drinkable) before it is used, but greywater after it is used to rinse the hands.  The water from a toilet/WC/loo is called blackwater.

 

https://en.wikipedia...wiki/Greywater 

 

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#9 Charles.C

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Posted 19 September 2015 - 02:32 AM

Hi Martha,

 

Thks for above.

 

TBH, IMEX the space consumed by a single handwash point located against a wall (to facilitate piping) is minimal, albeit requiring a little "excavation". (Presumably floor main drainage lines do exist already). 

 

Alternatively, IMEX, multiple, internal "handwashing" points are occasionally interpretable as a (gloved) standalone "hand-sanitizing" dip point  whose functional portion  can be routinely removed / replenished.


Kind Regards,

 

Charles.C


#10 trubertq

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Posted 19 September 2015 - 12:58 PM

BRC specifically requires 

 

" a sufficient quantity of water at a suitable temperature" I know auditors check that he water is warm, as do I when doing Internal audits.


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#11 Simon

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Posted 19 September 2015 - 04:12 PM

Simon,

 

In the U.S. the floor of a food producer is legally considered to be "filthy", so therefore anything that touches the floor becomes unsanitary either by cross-contamination (pathogens) or cross-contact (allergens).

 

Fair enough esquef.  

 

If I'm a food worker and I wash my hands before entering the shop floor and I don't get my hands dirty with the activities I carry out does there still need to be additional hand washing facilities provided on the shop floor?  Just trying to understand.

 

Regards,

Simon


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#12 RMAV

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Posted 19 September 2015 - 09:34 PM

Fair enough esquef.  

 

If I'm a food worker and I wash my hands before entering the shop floor and I don't get my hands dirty with the activities I carry out does there still need to be additional hand washing facilities provided on the shop floor?  Just trying to understand.

 

Regards,

Simon

I have yet to see an operation where hands must be used for routine work not in need of readily accessible handwashing facilities.  Undesirable things happen: a box falls on the floor and must be picked up; a package does not seal correctly soiling the hands with product; machines require adjustment and hands become soiled with lubricant;

 

There are ultra-clean operations where I could see an employee enter the shop floor and never soil his hands.  They would need relatively few handwashing stations.  However, those tend to be big $$ / £ / € facilities.  I think we'd all agree the number of stations, level of accessibility, etc should always be determined by level of need and risk.



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#13 Charles.C

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Posted 19 September 2015 - 10:56 PM

I presume this is category 4 and the relevant module is 10.

 

Module 10: Good Manufacturing Practices for Pre-processing of Plant Products

 

10.3.2      Hand Washing

10.3.2.1    Hand wash basins shall be provided adjacent to all personnel access points and in accessible locations throughout product handling, processing and packaging areas as required.

10.3.2.2    Hand  wash  basins  shall  be  constructed  of  stainless  steel  or  similar  non-corrosive  material  and  as  a minimum supplied with:

i.   A potable water supply at an appropriate temperature;

ii.   Liquid soap contained within a fixed dispenser;

iii.   Paper towels in a hands free cleanable dispenser; and

iv.   A means of containing used paper towels.

10.3.2.3    The following additional facilities shall be provided in high risk areas:

i.   Hands free operated taps; and

ii.   Hand sanitizers.

10.3.2.6    When gloves are used, personnel shall maintain the hand washing practices outlined above.

 

 

 

There seems to be no Guidance for Module 10. The M10 hand wash text looks very similar to Module 11 so I borrowed the latter’s Guidance. The relevant text is then  –

 

What does it mean?

In all food manufacturing facilities, employees, contractors and visitors must have clean hands upon

entering food handling or processing areas; after each visit to a toilet; after using a handkerchief; after

smoking, eating or drinking; and after handling wash down hoses, dropped product or contaminated

material.  Hand wash stations must therefore be correctly equipped and available at convenient locations

for use.

What do I have to do?

Hand wash basins must be provided in close proximity to pedestrian entry points at each area of the facility,

with instructions for all staff, contractors and visitors to wash hands immediately before entering the

processing area.  Additional hand basins are required where hands could become contaminated prior to working with product.

Potable water at a suitable temperature, liquid soap, single-use paper towels and a means of disposing of

used paper towels need to be provided at each station.   Hands-free operated taps and hand sanitizers are

also required for high risk operations.  Hands-free operated taps can include foot, knee or elbow operated

handles, auto-sensing devices or any other method that does not require the user to touch the handle with

their washed hands to turn it off.

Hand sanitizers for low risk processes are optional. 

Where alternative methods of hand-drying are preferred (e.g. high-speed air dryers). Their use must be

justified and their effectiveness validated (refer 2.4.2.2).

Hand-wash basins are to be constructed of stainless steel or similar non-corrodible material.  Hand-wash

basins constructed of porcelain or similar materials must be located at a distance from food handling areas.

 

 

11.3.2  Auditing Guidance

The location and construction of hand-wash stations and their use by staff, contractors and visitors shall

be reviewed at each facility audit.  Evidence may include:

•      Hand wash basins are available for staff, contractors, and visitors;

•      Hand wash basins are located at personnel access points and areas where hands could become

contaminated;

•      Hand wash basins are constructed of an appropriate material;

•      Hand wash basins have potable water supplied at appropriate temperatures;

•      There is liquid soap available at hand wash stations;

•      There are paper towels available at hand wash stations;

•      There are containers for used paper towels at hand wash stations;

•      There is signage near hand wash stations instructing people to wash their hands;

•      There are hands-free taps at hand wash stations in high risk areas;

•      There is hand sanitizer at hand wash stations in high risk areas;

•      Personnel in food handling areas have clean hands;

•      Personnel wash their hands on entering processing areas;

•      Personnel wash their hands on leaving toilet areas;

•      Personnel wash their hands on leaving the lunch room;

•      Personnel wash their hands after handing food products, hoses or waste;

•      Personnel wash their hands after eating, drinking or smoking;

•      Personnel who use gloves also follow hand washing requirements

 

.

 

The number of hand wash stations would appear to depend on the layout / process (ie likelihood of contamination / auditor. The process mentioned seems conservatively to demand >=1 (eg potatoes are apt to roll) but perhaps also related to (unknown) degree of  automation. A question of historical event frequencies / persuasion technique.

 

The nearest Yes/No answer to the OP  seems to be Post #3. but the portable option mentioned looks substantially space-consuming to me ?.

 

Some waterless hand cleaners seem to be USDA approved but the usefulness of such option may depend on SQF's interpretation of  words like "stations", "basins", "liquid soap"


Kind Regards,

 

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#14 Mulan1010

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Posted 21 September 2015 - 06:47 PM

We have a couple of areas where we installed the hand sanitizer stations since we did not have handwash sinks available.  We are SQF Certified and we just had to provide a risk assessment for the use of them in the areas.  We did had swabs and used the suppliers justification materials.



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#15 Simon

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Posted 21 September 2015 - 06:56 PM

Great info all.


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#16 MWidra

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Posted 21 September 2015 - 07:02 PM

I think that an important consideration is that hand sanitizers do not "clean" hands.  They do not remove dirt.  They only "sanitize", which means that they kill SOME pathogens.  They are actually only 60% alcohol, and if the workers do not use enough of them, they are not very effective.

 

http://www.cdc.gov/h...-sanitizer.html

 

So, if dirt is part of the problem, then hand sanitizers are not good for cleaning.

 

If the workers are going to clean their hands before entering the area, and the sanitizers are for maintaining the low level of microbes, then they could be useful.

 

Many places are allowing Grey Water to be used for watering lawns, so you may be able to pipe the waste from the sink out onto your lawn.  Then you only need a source of warm water and not worry about sewage connections.  I would check it out.

 

Martha


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#17 Simon

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Posted 21 September 2015 - 07:21 PM

I think that an important consideration is that hand sanitizers do not "clean" hands.  They do not remove dirt.  They only "sanitize", which means that they kill SOME pathogens.  They are actually only 60% alcohol, and if the workers do not use enough of them, they are not very effective.

 

http://www.cdc.gov/h...-sanitizer.html

 

So, if dirt is part of the problem, then hand sanitizers are not good for cleaning.

 

If the workers are going to clean their hands before entering the area, and the sanitizers are for maintaining the low level of microbes, then they could be useful.

 

Many places are allowing Grey Water to be used for watering lawns, so you may be able to pipe the waste from the sink out onto your lawn.  Then you only need a source of warm water and not worry about sewage connections.  I would check it out.

 

Martha

 

Attached File  i3.jpg   122.53KB   0 downloads


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#18 Charles.C

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Posted 21 September 2015 - 08:27 PM

I think that an important consideration is that hand sanitizers do not "clean" hands.  They do not remove dirt.  They only "sanitize", which means that they kill SOME pathogens.  They are actually only 60% alcohol, and if the workers do not use enough of them, they are not very effective.

 

http://www.cdc.gov/h...-sanitizer.html

 

So, if dirt is part of the problem, then hand sanitizers are not good for cleaning.

 

If the workers are going to clean their hands before entering the area, and the sanitizers are for maintaining the low level of microbes, then they could be useful.

 

Many places are allowing Grey Water to be used for watering lawns, so you may be able to pipe the waste from the sink out onto your lawn.  Then you only need a source of warm water and not worry about sewage connections.  I would check it out.

 

Martha

 

Hi Martha,

 

I didn't pursue the chemistry in depth but i got the impression that, at least in some cases, USDA-approved products labelled as "waterless hand cleaners" were literally that.

 

In contrast to products labelled as w.h.Sanitizers.


Kind Regards,

 

Charles.C


#19 MWidra

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Posted 21 September 2015 - 08:56 PM

Hi Martha,

 

I didn't pursue the chemistry in depth but i got the impression that, at least in some cases, USDA-approved products labelled as "waterless hand cleaners" were literally that.

 

In contrast to products labelled as w.h.Sanitizers.

Waterless hand cleaners generally are for removing grease, grime, tar, ink, paint and oil.  They are designed to be used by mechanics and other workmen, but they are not designed to remove dirt.  They are solvents that are compatible with human skin, and are now usually derived from the rind of citrus fruits.  They do not remove or kill microbes, and are not intended for use in the food industry.

 

When they are used, there is a need for a very absorbent towel to remove both the oil, grease, etc that is removed, but also to remove the cleaner itself.  They mostly have a pungent citrus-like odor that persists, which you would not want in your food.  I've used the solvent to dissolve paraffin, and it gets to you after a while.

 

There was one that I saw that says it is USDA approved.  It is analyzed to be 80% biobased by an USDA approved laboratory.  I also saw a sanitizer that was USDA approved, but under the USDA BioPreferred label program that is about sustainability.  It's another functionality of the USDA, unrelated to the food production arm.  I may have missed some, but Google did not fetch much more.

 

I have not seen any that the USDA allows to be used in a food production facility.

 

Martha


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#20 Charles.C

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Posted 21 September 2015 - 09:52 PM

Hi Martha,

 

I agree with you. Seeing would be believing.

 

This slightly ageing review supports yr statement (Pg 8).

 

Attached File  cleaners-sanitizers-appropriate-food-safety.pdf   37.14KB   37 downloads

 

So the simple, direct, one word answer to the OP is NO.  Multiply.


Kind Regards,

 

Charles.C


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