11.3.9 Sanitary Facilities - Unclear on drainage

I'm working on implementing the requirements set forth by SQF 11.3.9 but I am unclear on 11.3.9.2 where it says that

 

"Sanitary drainage shall not be connected to any other drains within the premises and shall be directed to a septic tank or a sewerage system."

 

What exactly does this mean? I'm interpreting it as the drains from toilets shouldn't share or be connected to a drain from, say, a sink in a different part of the facility (i.e. our kitchen area). Is this correct?

 

Thanks!

That would be my understanding.  If your sanitary drains backup, where would the flow go...? onto the production floor, or into the kitchen... that wouldn't be good.

That is correct. SQF Code Guidance:
Sanitary drainage must be kept separate from drainage from food production areas.
Sanitary drainage is separated from processing facility drains.

 

Regards,

 

Tony

Thanks everyone. It seems at this point that our drainage is not separated within the building, what does this mean for us at this point? Is this something we'd fail an audit for or simply a minor/major/serious non-conformance? How do they verify that our drainage is separated or not short from our answers to them?

 

This is an expensive "fix" so at this point I think we'll take the hit on our audit before we dig up the floors of our facility and separate the drains, provided that hit isn't an immediate failure. Thoughts?

I too am interested in what level non-conformance and auditor would give on this.  

I think it would depend on two things:

 

1. What procedures you have in place should there be a problem with the drains and that you monitor to show that there is no contamination risk from the drains in normal operation.

 

2. The product risk, if you have a high risk product such as RTE perishable products such as sandwiches then I would say it is a major non-conformity if there is no evidence of risk of product contamination otherwise critical. For low risk products a minor non-conformity.

 

Regards,

 

Tony

Hi idealdreams,

 

I would hope your employees are good runners in the event of  a worst case scenario.

 

Seriously, this is surely a basic No-No.

I think it may have to do with what kind (and risk) of process you have, and how close to the drains are to the process.  I would take a hard look at the process and proximity to those drains.  I would:

-ensure the drains have good traps and backflow prevention as possible

-step up environmental micro sampling of air, equipment, walls, and floors (and cooling units if applicable);

-have a plumbing provider trained in food operations on "retainer" that is, they show up within xx minutes of your call in an emergency.

-have emergency plans to deal with a backup of the drains;

-serious and robust drain cleaning program and separate tools for that use, including cleaning of the tools used

-staff training on the subject and what to do if the drains were to be an issue

-daily monitoring of the drains to ensure they are draining properly

 

The trouble with sewer drains is it's not if they contain pathogens but which ones and how many and can they get out and contaminate your plant.

Tony and Charles beat me to it.  I agree with them.

Start digging.

As a former SQF Auditor I would ask for the plumbing schematics.

Might be a major, but could very likely be a critical.

Regardless, you really can't afford this on an audit.

Start digging.

As a former SQF Auditor I would ask for the plumbing schematics.

Might be a major, but could very likely be a critical.

Regardless, you really can't afford this on an audit.

 

Thanks for the advice. Do you believe there would be ways around a non-conformance through validation and monitoring activities to show the drains are fine the way they are? Or if we did nothing about this and were audited, we have no plumbing schematics. What other methods are there to show an auditor the way our plumbing is set up?

Thanks for the advice. Do you believe there would be ways around a non-conformance through validation and monitoring activities to show the drains are fine the way they are? Or if we did nothing about this and were audited, we have no plumbing schematics. What other methods are there to show an auditor the way our plumbing is set up?

 

Hi idealdreams,

 

I suggest you get a new plumber asap. Somebody has screwed up.

 

And hope for a long dry spell.