12 replies to this topic

[mkelly320]

I searched the threads, but didn't find one that addressed my question.  I'm new to this, and still picking through what my predecessor did and why...  (I'm fairly good at reading regulations, and I'm convinced that she made some things up as she went in an effort to be difficult)

 

We're having a "lively discussion" about sinks.  We have a designated handwashing station that isn't used for anything else, which I get.  We also have sinks in our mixing rooms where they're adding preservatives, citric acid, etc.  They were told that they are not allowed to have soap or paper towels at those sinks, because they are not for hand washing.  However, SDS states that if you spill potassium sorbate on your skin, you should wash with soap and water.  Can I provide them with soap and paper towels at these "non-handwashing" sinks?  Do I need signage that the sinks are not for handwashing?  How can I make this work for the employees that are actually doing the mixing, and still follow the regulations?

 

Or - I'll happily accept "you can't do that, and this is why."

 

Thank you!

[Charles.C]

Hi mkelly,

 

Welcome to the Forum ! 

 

Pls inform  the product/process.  It relates to possible Regulatory aspects, eg USDA/USFDA, etc.

 

Any other particular FS standard involved ?

[JohnWheat]

Is there a need for 'Immediate washing' ? If not a big deal then perhaps provide another sink clearly signed for hand wash only?

If there is a need, then emergency usage should be allowed and follow all normal protocols following potential contamination of product that might have happened? I'm sure you've done a risk assessment?

 

If you have answered yes, perhaps you should have considered PPE to prevent it happening? (I'm being devils advocate here )

PPE should be a last resort as you should always start by removing the hazard...

[gfdoucette07]

MKelly

 

My guess is that you have these as parts wash sinks correct?  A few placed I have worked at had both types of sinks and yes they have to be label for use, hand wash vs parts wash. 

 

Parts wash sinks cannot have soap and towels because there should not be parts in a hand wash sink. With something like ingredient label saying wash hands you should then have both or change over your parts sink to a hand wash.  When adding ingredients in all facilities I have worked at gloves were needed so may need to look at that. 

 

G

[mkelly320]

Let me see if I can answer the questions.  We're in the US, and we process canned fruit, fruit filling, and maraschino cherries, so my understanding is we're following FDA regs.

 

I just came from a production meeting, and maybe a better way to ask the question is this -

 

Previously, the line supervisors were told that we can only have the one handwashing sink just inside the employee entrance.  No other sinks in the plant could be used for hand washing.  No matter what the reason, that seems unrealistic to me.  I definitely understand the need to have everyone wash as the enter the plant.  However, I don't understand why you would require someone working on the far side of the plant to walk all the way back to the entrance to wash their hands.  If you want people actually washing every time they should, shouldn't the setup be convenient for washing?

[gfdoucette07]

Wow...sounds made up to me.  IMO you need hand wash availability anywhere near where they are working with product. If they need to pick something off they floor, wipe their sweat (from working so hard) or itch their face are they supposed to go all the way up front?   

 

If it is not being used a parts wash or to thaw frozen material I would say soap and towels, plus a receptacle!

 

G

[mkelly320]

As far as parts washing vs. hand washing, I think I need to know more about what would be defined as a part.  For instance, if I have a dipper we use to get a syrup sample from an incoming truck, can I wash that in the same sink where someone would wash their hands? 

 

If we have areas with double sinks, can one side be designated for hand washing?

 

I'm sorry - you're all probably shaking your heads at these silly questions. I came from a world of intense record-keeping, but not the world of food safety.

[gfdoucette07]

In my experience, we tried using double sinks if you can make them disciplined and label each side as such then it works however an auditor finds 1 part in the hand wash side or someone washing hands on the wrong side and you have a NC becaue your not doing what you say.

 

"Parts" is gray- In a cheese mfg facility we kept a sink full of water and changed every couple hrs.  It contained gaskets clamps, elbows, pitchers, measuring devices etc that were needed frequently and needed to be soaked.  If you are just rinsing items then any sink is fine but don't leave the parts laying in there. Have a rack or place to store

 

I've tried to say there is no silly question because we all come from different mfg, education, and upbringings.  I went from cheese/dairy to dried starches, lots of things are not as I am used to

G

[mkelly320]

This is very helpful!

 

So, in the QC lab we use strainers, and some other tools for our checks.  After each check, the tools are washed and put in a rack next to the sink to dry. Can the techs wash their hands in this sink?

 

Is there a standard or rule somewhere I can read on this?

[gfdoucette07]

I would say they can, I do not know it was a standard or a company best practice, sorry

 

G

[izent74]

I work in the airline catering industry with 25+ plants in the Latin America and Caribbean region.

 

All our facilities have separated/dedicated sinks for Wash and Sanitation of Hand, Preparation Equipment, Service Equipment, Food (Fruits and Vegetables) and Cleaning Equipment (mops, brooms, etc.).

 

Although there are specific standards we use in our industry, they are in compliance with at least the FDA Food Code (and probably with many other countries' regulations) - do you have it? You can download the PDF version on the FDA website and do a search for "Handwash" (there is a lot of information there on this topic).

 

Additionally, Hand wash facilities must be placed near where they are needed and in sufficient numbers to cover all employees for frequent washing.

 

All wash facilities need to have appropriate/dedicated equipment and signage.

 

Hand wash facilities at the entrance ONLY is definitely insufficient and was either made up or a misinterpretation at some level.

 

Proper and sufficient hand wash is fundamental to ensure safe food handling, therefore the understanding and compliance on this topic is critical.

 

Hope this helps.

[MWidra]

I'm going to address this from a personnel safety and food safety POV.  If the room is being used to handle citric acid and potassium sorbate, then there should be an eyewash station immediately available.  That means in the room.  So that has to be in a sink somewhere unless you want the flood that will result from a 20 minute flush of the eyes, which is low long you should wash anything out of your eyes.  Any eye contamination requires medical attention after the eye flush, just to make sure that there is no damage.  That's an OSHA thing.

 

If you have the working sink contain the eye wash, and put soap and towels there, you can make that a chemical sink with the appropriate safety materials available.  Your workers then would need to use a food safety handwashing station before going back into the areas that require that type of hand washing. 

 

I hope you are requiring your workers to wear safety glasses with side shields when handling those materials, along with protective gloves.  You may want to require them to wear gauntlet style gloves to protect their arms.  Lab coats are NOT considered PPE from a chemical protection POV.

 

I applaud that you have looked at the SDS and want to take care of your workers.  Worker safety is many times missed when dealing with food safety, since it is not part of the food safety audits that we normally have performed.  Bravo.

 

Martha

[mkelly320]

Thank you.  These answers are so helpful!  I really don't want to comment on our current safety/ppe requirements, except to say: Times they are a-changin'.  We do have an eyewash station and shower about 10 feet from the chemicals.  However, they were told that they could not have paper towels or soap because it wasn't a hand washing sink. 

 

This is just the kind of information I needed to take to our plant meeting to get the ball rolling.