A quick question to my colleagues here on the IFSQN forum:
What is your opinion of a food manufacturer policy that allows use of a sweeping brush used on the floor also allowed to be able to be used to sweep off a Zone 2 surface (surface adjacent to a food contact surface)?
Where I work as a food safety manager I've always prohibited any use of floor cleaning implements on any other surfaces. I recently came across a supplier that didn't adhere to that policy and allowed floor cleaning implements to be used on Zone 2 surfaces and when questioned on this practice they replied that a risk analysis had been conducted which supports the position that this practice is acceptable from a food safety point of view. To be clear I'll point out my concerns:
- No shoe sanitizer system is being used
- Allergen cross contact potential is not addressed in the risk analysis (yes, they have multiple allergens as ingredients
Is anyone aware of U.S. regulation prohibiting this practice, even with a fairly weak risk analysis used as support?
Thanks in advance for any input on this topic.
Regards,
esquef
Hi Esquef,
I have no idea how that could possibly be risk assessed to be considered ok. I will say that would not be tolerated in our facility, and I have never heard of anyone actually doing that.
As far as BRC standards are concerned:
- 5.3.8 - "Equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination by allergens. The cleaning methods shall be validated to ensure they are effective and the effectiveness of the procedure routinely verified. Cleaning equipment used to clean allergenic materials shall either be identifiable and specific for allergen use, single use, or effectively cleaned after use." How are they addressing the effective cleaning of these cleaning implements for allergens? How are they showing that the equipment framework and so forth is not being hit with cross-contamination due to the use of these cleaning implements? Have they done any testing? As you said -- they are not even addressing that point in the risk assessment.
- 4.11.6 - "Cleaning equipment shall be: hygienically designed and fit for purpose, suitably identified for intended use (color coded or labeled), cleaned and stored in a hygienic manner to prevent contamination". How are they addressing the "preventing contamination" part of this? Although I have found out the Interpretation Guideline is not auditable, there is actually quite a bit of detail in this part of the guide that details floor cleaning equipment should be designated as separate from cleaning production equipment; which would essentially render the risk assessment to be invalid. However, as that document is not auditable, I'm not sure you can actually justify it based on that blurb...but there is no way that I can imagine they are preventing contamination by using floor cleaning implements for Zone 2s.
Those are the two major areas where I can see this being an issue. Overall, it's good practice not to use floor implements on anything other than..well, floors. I would have thought this to be sort of an understood and implied measure, if not necessarily written down.
QAGB
