6.2.2 Hand washing - Purell Sanitizer in Lieu of Hand Washing Station

Hello,

Can anybody help me if the company's plan would be adequate? Below is the line from BRC Packaging Standard regarding the Hand washing station requirement but management looks into getting Hand Sanitizer in the entrances to production and storage areas instead of the Hand Washing station. I wanted to get advise before any action starts.

Thank you so much in advance!

I'm not a BRC user but I think there is a big difference between hand washing and hand sanitizing in the eyes of food safety. I would suggest that you have at least one hand washing station at every entrance to your food processing/handling areas and then use stations with hand sanitizer at various other places through out your facility if necessary.

I agree with idealdreams.  A sanitizer is an extra precaution for use on already "clean" hands; if you're hands are dirty then a sanitizer just moves dirt around.

Hi Idealdreams and Simon,

Thank you for your quick response. The reason behind that is one of the new Management Personnel from another Packaging Manufacturer (our close competitor) said that it is what they have at his previous workplace and they are AIB Certified-so it was ok.

My concern though is I'm not sure how AIB operates, or even how detailed it is on their standard. BRC as stated, is clear "Hand Washing station" and it is "shall" so I don't really agree with just sanitizer. For me, I gather advise from professionals and if they still insist, then that's for them.

But anyway, I wanted to know if anyone with BRC certification dealt with issues like this.

Thanks!!

Hello,

 

 

Can anybody help me if the company's plan would be adequate? Below is the line from BRC Packaging Standard regarding the Hand washing station requirement but management looks into getting Hand Sanitizer in the entrances to production and storage areas instead of the Hand Washing station. I wanted to get advise before any action starts.

 

6.2.2 Hand washing shall be performed on entry to the production areas and at a frequency that is appropriate to minimise the risk of product contamination.

 

 

Thank you so much in advance!

The company plan would be inadequate. The standard is quite clear as to what the requirement is and a person can not "wash" their hands with sanitizer.  Sanitizer would be the enhancement to a hand washing station but never a replacement.

I'm SQF and not BRC, but we had sanitizer all over my facility back when we were AIB, but with the GFSI focus on hand washing I've removed sanitizer entirely from my plant.  The problem with sanitizer (for us) was that my employees thought just like you; that it was some how better than washing hands.  This became a management issue, so we removed the sanitizer and really had to push hand washing for a while until the process became ingrained.  Having the sanitizer around was like sending a mixed message.  It is great if you can get folks to wash and then sanitize, but you have to ensure they don't substitute the sanitizer for a good 20-30 second soapy water scrub of those hands. 

Hi Loren,

I agree with the above posters, hand sanitizers are not an adequate replacement for hand washing. Decisions about this kind of thing are really supposed to be about food safety risks, as well as about satisfying the requirements of a standard.  If you need extra means to encourage management to install proper plumbing, you could educate them on the risk of norovirus.

Most waterless hand sanitisers, although effective against bacterial contamination, do not adequately remove norovirus from hands.  Norovirus is very infective and a single person who is carrying the virus and who has not washed their hands properly could potentially transfer infective doses to hundreds of surfaces in your facility.  In packaging plants I have personally seen bare hand contact with food contact surfaces, such as the inside of IBC lids and valves and single use utensils after the molding process.  Norovirus can persist on surfaces for over three weeks so it could potentially make many people sick via your packaging materials.   In my opinion it presents a much greater food safety risk in this scenario than bacterial contamination.   Soap and water hand washing is effective at removing norovirus from hands.

I hope this helps with the decision.

Karen

Hi All,

I deduce from the OP that this BRC thread relates to a (BRC categorized) High Risk Packaging product.

(BRC has an interestingly less rigorous handwashing requirement for Low Risk Packaging).

I assume that the clauses in BRC Packaging Standard  as related to handwashing are conceptually based on  -

Prerequisite programmes  The basic environmental and operational conditions in a packaging business that are necessary for the production of safe and hygienic packaging materials. These control generic hazards, covering good manufacturing and good hygienic practice as detailed in Part II, sections 4–6

I note that the BRC Food Packaging Standard does not mention the words sanitize/sanitizer/sanitiser/swab.

I'm not a Packaging person but offhand i would have thought that for both H/L Risk packaging any significant, environmental, food-related microbiological hazards in a typical food packaging environment are minimal. ?

(Non-safety micro hazards such as APC might be a different matter, eg with respect to a Packaging micro. specification, but I have seen little, if any, data in this forum to suggest this is a common problem ?)

I also get the impression from threads on this forum that most Packaging Production plants, both Low and High, do not routinely carry out surface swabbing procedures ?.

It does not apear to me that BRC expect to see the routine use of Sanitizers in a High Risk Packaging Plant. Although a particular Plant may justify it perhaps from their Risk asssessment.

(Doesn't necessarily mean a BRC auditor will dislike it of course, and not to forget potential Customers)

i wonder if any Packaging Plants which do include Sanitizers have justified their usage ?

You will still need both systems. We train our employees on washing their hands once they enter the facility.  Also purell stations at the end of each aisle.  It works because if an employee gets grease on their hands, the purell wont work.  You would need to go to a hand washing station.

I'm SQF and not BRC, but we had sanitizer all over my facility back when we were AIB, but with the GFSI focus on hand washing I've removed sanitizer entirely from my plant.  The problem with sanitizer (for us) was that my employees thought just like you; that it was some how better than washing hands.  This became a management issue, so we removed the sanitizer and really had to push hand washing for a while until the process became ingrained.  Having the sanitizer around was like sending a mixed message.  It is great if you can get folks to wash and then sanitize, but you have to ensure they don't substitute the sanitizer for a good 20-30 second soapy water scrub of those hands. 

This is a great idea! My biggest fight is that the hand sanitizer is not a replacement of hand washing but people skip the sinks and go for it instead all the time. 

As for the original question, we are SQF so I don't know about BRC, but just from a scientific standpoint here are some arguments you could use to try and make them understand the difference between hand sanitizing and hand washing:

1. most bacteria of concern are not part of your normal flora on your hands, therefore they are easily washed away with soap and water. They may not all be killed by sanitizer though. 

2. if you have any debris on your hands, sanitizer can only kill what it comes into direct contact with, so it will not kill every bacteria found within the debris

3. there are some bacteria and viruses (someone already mentioned norovirus) that are not killed by sanitizer

What really surprised people here was swabbing hands that had been washed and those that had been sanitized. The sanitized hands still had bacteria so everything wasn't killed. The difference is that washed hands should mainly have bacteria that are part of your normal flora which are harmless (some exceptions like Staph aureus of course), whereas the sanitized hands could have pathogenic bacteria that were picked up from the environment that just weren't killed (listeria in a piece of soil on your hand for example).