14 replies to this topic

[Craig L.]

During a recent inspection it was pointed out that hands could become recontaminated by disposing of hand towels through a lidded receptacle. 

I have replaced with a uncovered, wire framed, trash liner holders.

These stations are located before entry into production areas.

 

I was asked to check the FDA guidelines for a requirement stating they must be covered.

I have found conflicting information.

SQF code only states "A means of containing used paper towels" is to be provided.

 

I feel that the open container at this location does not pose a risk to our product and reduces the potential for recontaminating washed hands.

 

 

Please give your thoughts.

 

[Charles.C]

Hi Craig.L,

 

Perhaps foot-operated lids are a solution.

 

Normally IMEX  any open garbage containers will be auditor-criticised. It's considered anti-GMP.

[Watanka]

Hi Craig,

We like covered waste receptacles for hand towels that have a plastic bag liner and are hands-free, typically by means of a foot pedal.  The cost is negligible as compared to open trash bins; and this method is more sanitary if for no other reason than the fact that the used, potentially dirty, paper towels are less likely to escape and there is no direct personnel contact with the receptacle.  It is neater and tidier too!

 

I did a quick check of SQF code and 21 CFR Part 110.

 

SQF 11.3.2 Hand Washing says, "Paper towels in a hands free cleanable dispenser; and; A means of containing used paper towels."

 

The relevant implementation guidance says, "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)."

 

The relevant auditing guidance says: " There are paper towels available at hand wash stations; There are containers for used paper towels at hand wash stations;"

 

SQF 11.3.9 Sanitary Facilities refers the reader to the above section when discussing hand washing and paper towels.

 

SQF 11.4.1 Staff Engaged in Food Handling and Processing Operations says, "Waste shall be contained in the bins identified for this purpose and removed from the processing area on a regular basis and not left to accumulate;"

 

There is more about waste removal in SQF 11.9.1 Dry and Liquid Waster Removal, but nothing that addresses your concern.

 

21 CFR Part 110 § 110.37 Sanitary facilities and controls (e) Hand Washing Facilities says:

 

(e) Hand-washing    facilities.   Hand-washing facilities shall be adequate and convenient and be furnished with running water at a suitable temperature.  Compliance with this requirement may be accomplished by providing:

(3) Sanitary towel service or suitable drying devices.

 

All that said, being right about the FDA and SQF code may not help you much with a determined auditor or an uncomfortable potential customer. 

 

 

 

[Craig L.]

Hi Craig.L,

 

Perhaps foot-operated lids are a solution.

 

Normally IMEX  any open garbage containers will be auditor-criticised. It's considered anti-GMP.

Thank You Charles. I will consider this in moving forward.

[Craig L.]

Hi Craig,

We like covered waste receptacles for hand towels that have a plastic bag liner and are hands-free, typically by means of a foot pedal.  The cost is negligible as compared to open trash bins; and this method is more sanitary if for no other reason than the fact that the used, potentially dirty, paper towels are less likely to escape and there is no direct personnel contact with the receptacle.  It is neater and tidier too!

 

I did a quick check of SQF code and 21 CFR Part 110.

 

SQF 11.3.2 Hand Washing says, "Paper towels in a hands free cleanable dispenser; and; A means of containing used paper towels."

 

The relevant implementation guidance says, "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)."

 

The relevant auditing guidance says: " There are paper towels available at hand wash stations; There are containers for used paper towels at hand wash stations;"

 

SQF 11.3.9 Sanitary Facilities refers the reader to the above section when discussing hand washing and paper towels.

 

SQF 11.4.1 Staff Engaged in Food Handling and Processing Operations says, "Waste shall be contained in the bins identified for this purpose and removed from the processing area on a regular basis and not left to accumulate;"

 

There is more about waste removal in SQF 11.9.1 Dry and Liquid Waster Removal, but nothing that addresses your concern.

 

21 CFR Part 110 § 110.37 Sanitary facilities and controls (e) Hand Washing Facilities says:

 

(e) Hand-washing    facilities.   Hand-washing facilities shall be adequate and convenient and be furnished with running water at a suitable temperature.  Compliance with this requirement may be accomplished by providing:

(3) Sanitary towel service or suitable drying devices.

 

All that said, being right about the FDA and SQF code may not help you much with a determined auditor or an uncomfortable potential customer. 

Thanks Watanka. Your last statement is so true.

[Charles.C]

Thank You Charles. I will consider this in moving forward.

 

Hi Craig,

 

Frankly i think this one is self-explanative. It's a generic requirement to minimise potential for cross- contamination.

You might consider the specific issue as a locational corollary to hands-free handwashing equipment.

 

A few examples -

 

AIB Consolidated Standards
1.16  Waste Material Disposal
Waste materials and their removal are managed to avoid contamination.
       Critical Requirements
1.16.1.1        Trash or inedible waste is stored in properly covered, labeled containers.
1.16.1.2        Waste containers are emptied at least daily.
1.16.1.3        Trash or inedible waste does not come in contact with raw materials, work-in-process, or finished product at any time.
1.16.1.4        Licensed contractors remove waste, where required.
1.16.1.5        Waste disposal meets regulatory requirements.

 

 

SQF Guidance 11.9.1

Waste handling, storage and disposal procedures include how waste is contained in appropriate, covered and labeled containers; frequency of disposal; how it is disposed of; and who is responsible for waste handling and disposal


Exterior waste containers need coverage or lids to prevent attracting flies or vermin.  It is also advisable to secure waste containers in regards to site security requirements.

[Craig L.]

Hi Craig,

 

Frankly i think this one is self-explanative. It's a generic requirement to minimise potential for cross- contamination.

You might consider the specific issue as a locational corollary to hands-free handwashing equipment.

 

A few examples -

Thank You Charles,

 

Looks like we will go back to covered containers at our sinks. I should have asked the group before making this change.

Always learning.

 

Regards,

Craig

[Ryan M.]

Thank You Charles,

 

Looks like we will go back to covered containers at our sinks. I should have asked the group before making this change.

Always learning.

 

Regards,

Craig

First I heard of an auditor or inspector bring up the potential to recontaminate your hand(s) by throwing away towels.  Maybe you can put together a specific procedure where the persons use the towel and not the hand to push open the lidded container?  Then an easy verify/validation with ATP or micro swabbing of hands before and after.

 

Interesting nonetheless...

[Mulan1010]

We are not FDA Regulated but we are SQF Certified for Level 3 and have been for 7 years now.  We have had the type of trash container you described and use them all over our plant in Raw and RTE areas as they are easy to clean and maintain.  We just do not allow the containers to get full above the wire rim.  We do have designated employees who are responsible for picking up items from floor and handling the trash bags and it has worked very well for us and we have never had an issue with the SQF Auditor.  Personally I think the design is much more sanitary than an enclosed container that you have to clean and maintain in a working manner as the concept is the same.  If the enclosed container gets too full the trash will overflow, lid or no lid or someone will have to cram the trash down for the lid to close.

[Charles.C]

We are not FDA Regulated but we are SQF Certified for Level 3 and have been for 7 years now.  We have had the type of trash container you described and use them all over our plant in Raw and RTE areas as they are easy to clean and maintain.  We just do not allow the containers to get full above the wire rim.  We do have designated employees who are responsible for picking up items from floor and handling the trash bags and it has worked very well for us and we have never had an issue with the SQF Auditor.  Personally I think the design is much more sanitary than an enclosed container that you have to clean and maintain in a working manner as the concept is the same.  If the enclosed container gets too full the trash will overflow, lid or no lid or someone will have to cram the trash down for the lid to close.

 

Hi Mulan,

 

I suggest for yr next audit you can ask the opinion of the auditor. Should be interesting.

 

How about yr waste containers outside ? Same Principle and approval by SQF?

 

It is possible that this is a distinction in Custom rather than Sanitation ?.

 

@rmills - How about hands-free taps ? Another superfluous requirement ? At least they haven't stretched to the door knobs yet.

[Mulan1010]

The waste containers outside are and should be covered per the SQF Code.  The SQF Auditor does tour the grounds and checks on the trash and debris storage area.  We used to have containers for trash inside the plant but it is just another item to keep up and ensure it is cleaned properly and not damaged so it was a much better opportunity, sanitary and monetary, for us to use very simple wire frames and place a plastic bag for containing trash inside the facility.  We have had 4 different auditors during our audits with SQF and all have been okay with it. 

[Craig L.]

We are not FDA Regulated but we are SQF Certified for Level 3 and have been for 7 years now.  We have had the type of trash container you described and use them all over our plant in Raw and RTE areas as they are easy to clean and maintain.  We just do not allow the containers to get full above the wire rim.  We do have designated employees who are responsible for picking up items from floor and handling the trash bags and it has worked very well for us and we have never had an issue with the SQF Auditor.  Personally I think the design is much more sanitary than an enclosed container that you have to clean and maintain in a working manner as the concept is the same.  If the enclosed container gets too full the trash will overflow, lid or no lid or someone will have to cram the trash down for the lid to close.

Mulan1010,

 

This was my line of thinking initially. We are preparing for our first unscheduled SQF audit advancing to level 3.

I appreciate your comments.

I was trying to reduce the need to wash the containers as you stated.

Also, I stay away from foot operated containers because they can be tough to clean fully.

This has caused such an unexpected stir in the plant and I have replaced them with lidded containers to persue other challenges.

 

Craig L.

[Charles.C]

Hi Craig/Mulan,

 

I think this subject is a good example of the difficulties involved in attempting to set uniform GMP guidelines  based on risk assessment.

 

I assume (a) yr environment has no particular vectors, eg flies, offering significant risks of cross-contamination, (b) the container/liner pose no risk of user cross-contamination in a half-full condition, © half-full liners are speedily removed in a hygienic fashion. If so I rather agree with yr opinion that such a procedure should not pose a significant risk although my own experience is that close control is always tricky around lunch breaks. It’s also my experience that having an opaque lid can promote a latent disinterest in workers to speedily dispose of half to two-thirds full liners.

 

However, based on some of my own external audit experiences, some operations are  substantially inferior to yr own scenario, notably overflowing, uncovered, trash containers (one may debate whether  a cover would improve such determined lacks of hygienic interest).

 

I predict that faced with such possibilities, the proponents of FS Standards like BRC, SQF are obliged  to assume a worst-case scenario and act accordingly. In this respect, use of a cover does IMO enhance an overall Principle to minimize opportunities for exposure to contamination.

 

PS – I don’t quite understand why using a foot-operated bin/inner liner causes increased difficulty in maintaining a clean trash bin. I haven’t really noticed much operational difference.

In one HACCP audit, a cracked cover on a trash bin in our dry store was immediately pounced on by one  auditor although the previous one had just ignored it. Such is an auditee’s lot.

[Craig L.]

Hi Craig/Mulan,

 

I think this subject is a good example of the difficulties involved in attempting to set uniform GMP guidelines  based on risk assessment.

 

I assume (a) yr environment has no particular vectors, eg flies, offering significant risks of cross-contamination, (b) the container/liner pose no risk of user cross-contamination in a half-full condition, © half-full liners are speedily removed in a hygienic fashion. If so I rather agree with yr opinion that such a procedure should not pose a significant risk although my own experience is that close control is always tricky around lunch breaks. It’s also my experience that having an opaque lid can promote a latent disinterest in workers to speedily dispose of half to two-thirds full liners.

 

However, based on some of my own external audit experiences, some operations are  substantially inferior to yr own scenario, notably overflowing, uncovered, trash containers (one may debate whether  a cover would improve such determined lacks of hygienic interest).

 

I predict that faced with such possibilities, the proponents of FS Standards like BRC, SQF are obliged  to assume a worst-case scenario and act accordingly. In this respect, use of a cover does IMO enhance an overall Principle to minimize opportunities for exposure to contamination.

 

PS – I don’t quite understand why using a foot-operated bin/inner liner causes increased difficulty in maintaining a clean trash bin. I haven’t really noticed much operational difference.

In one HACCP audit, a cracked cover on a trash bin in our dry store was immediately pounced on by one  auditor although the previous one had just ignored it. Such is an auditee’s lot.

Thank You Charles,

Very informative!

FYI, since I have replaced the container back to covered it is now overfull. Not typical here, yet the timing is ironic.

 

Regards,

 

Craig L.

[Hoffeecraw]

Craig,

  You mentioned that the stations are near an entrance.  I didn't catch whether these entrances had a door with a handle.  If so, I'd probably have a foot pedal operated can next to the door.  They can nail you for re-contamination of the hands by handling the door handle if people aren't using the towel to operate the handle or push the door.