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Water Hoses in Food Manufacturing Facility

Non conformance hoses

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scrater

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Posted 17 April 2018 - 10:42 AM

We work in a facility that produces dry beverage mixes, dry baking mixes and spices.  Water is not part of our processes.  It is strictly used for cleaning.

 

We just finished our 2018 SQF Audit and one of the minors that we had is because of the type of hose that we have in one of our open food areas to clean the room and some equipment. 

 

Here is the description:

“Equipment and utensils shall be designed, constructed, installed, operated and maintained so as to meet any applicable regulatory requirements and not to pose a contamination threat to products.”

 

Here is the Evidence:

“Site is using garden hoses that do not meet 3-A, USDA or FDA standards.”

 

We have been using this type of hose for years with no issue before.  We can't find anything in the code that specifies that we need to use a certain type of wash down hose, nor do we see anything in the FDA guidelines.     We are thinking of disputing the minor non conformance.  Can anyone help and advise if there are certain regulations regarding the type of wash down hoses that must be used?

 

 

Any help will be highly appreciated.

 

Thanks

 



Ryan H.

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Posted 17 April 2018 - 12:14 PM

Interesting. We have a snack food/ bakery plant and only use water from hoses for cleaning activities. We do NOT use the hoses for ingredients (If we did then we were told me must have the FDA/USDA hoses). We just had a routine state inspection in which the inspector told us that we should "consider" changing our hoses out to a FDA/ USDA standard hose if though their used only for cleaning.

 

I think the auditor you had is probably overreaching a little bit if your not using the hoses as a source for ingredients (water), but it seems like the industry is pushing in this direction anyways. 

 

Good Luck!


All the best, 

 

Ryan Heavner 


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FurFarmandFork

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Posted 17 April 2018 - 03:29 PM

I disagree with Ryan, and note that just because a previous auditor doesn't note something as a finding, does not mean that it isn't.

 

Hoses conveying water to be used for sanitation purposes are food contact surfaces, even if they aren't used solely to add water to the product. They represent a potential point of contamination. It is on you to prove that the materials used in the hose are appropriate for use in food. Typically, if there isn't an NSF or other indicator of the material on the hose, it will get rejected by an astute inspector.

 

Here are the applicable portions of the code:

11.2.1.1 Product contact surfaces and those surfaces not in direct contact with food in food handling areas, raw material storage, packaging material storage, and cold storage areas shall be constructed of materials that will not contribute a food safety risk.

 

11.2.9.2 Equipment and utensils shall be designed, constructed, installed, operated and maintained to meet any applicable regulatory requirements and not to pose a contamination threat to products.

 

 

Here are the FDA requirements:

 

 

21 CFR 117.37

(a) Water supply. The water supply must be adequate for the operations intended and must be derived from an adequate source. Any water that contacts food, food-contact surfaces, or food-packaging materials must be safe and of adequate sanitary quality.

 

(b) Plumbing. Plumbing must be of adequate size and design and adequately installed and maintained to:

(3) Avoid constituting a source of contamination to food, water supplies, equipment, or utensils or creating an unsanitary condition.

 

 

21 CFR 117.40

 

(a)(1) All plant equipment and utensils used in manufacturing, processing, packing, or holding food must be so designed and of such material and workmanship as to be adequately cleanable, and must be adequately maintained to protect against allergen cross-contact and contamination.

(2) Equipment and utensils must be designed, constructed, and used appropriately to avoid the adulteration of food with lubricants, fuel, metal fragments, contaminated water, or any other contaminants.

(5) Food-contact surfaces must be made of nontoxic materials and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds, sanitizing agents, and cleaning procedures.

 

 

 

Prove it's made of nontoxic materials appropriate for use in food, otherwise get a different hose.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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changk

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Posted 17 April 2018 - 03:35 PM

I think the Auditor is looking for best practice for the above....I would look into if the garden hose is food grade material and have the chemical migration analysis to back it up. other than that Im not sure where he could be coming from! hope it helps



SQFconsultant

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Posted 17 April 2018 - 05:13 PM

Garden hose?

 

Seriously, you've been using a garden hose?

 

Very simply - you need a commercial hose.


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FurFarmandFork

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Posted 17 April 2018 - 05:22 PM

Example of hazards:

 

https://www.huffingt..._n_1615774.html

 

Regulatory precedent:

 

FDA warning letter: https://www.fda.gov/...s/ucm350499.htm

a)    On October 12, 2012, at your 7 Gear Avenue, Lindenhurst, New York facility, an employee was observed filling brine barrels with a garden hose (not food grade) connected directly to the potable water supply with no backflow protection device or air gap installed.
 
This is a repeat observation from the June 2010 inspection. Your November 13, 2012 response indicates new food grade hoses were purchased and being used. This will be confirmed on our next inspection.

 

 

 

 

 

Restaurant: http://www.pennlive....rden_hoses.html

Mobile food facility is using garden hoses rather than approved food-grade hoses to connect to the public water source.

 

 

 

Idaho public health guidance for mobile units:https://www.siphidah...equirements.pdf

Potable Water:U Hoses used to replenish the potable water supply must be approved for use with food. This hose shall be stored on the cart or mobile with the ends fastened together. UA garden hose is not approved.U The water source must be approved by the inspector.

 


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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Ryan H.

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Posted 17 April 2018 - 05:24 PM

Sorry all I was not very specific in my original response. Our facility uses industrial grade/ commercial style hoses, but I have not seen a requirement that says your hose has to be "FDA grade" per say (except for when uses hose to source water as an ingredient). I would not think a garden hose specifically would be the ideal type to use, even if its just for cleaning. Like someone said in an earlier response if you can prove that your hoses are maintained and are not posing a threat to food safety i think your OK. Your not going to be able to prove that with a garden style hose though. I like SQFconsultants response. That would be the best way to correct their minor non-conformance. Good Luck.


All the best, 

 

Ryan Heavner 


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Parkz58

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Posted 18 April 2018 - 08:53 PM

Bottom line - the interior of the hose is a de-facto food contact surface, because it's conveying water that is being applied to food contact surfaces.

 

Therefore, it should be food grade.



tharinduth

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Posted 19 April 2018 - 02:57 AM

I think this is correct answer. 

 

I disagree with Ryan, and note that just because a previous auditor doesn't note something as a finding, does not mean that it isn't.

 

Hoses conveying water to be used for sanitation purposes are food contact surfaces, even if they aren't used solely to add water to the product. They represent a potential point of contamination. It is on you to prove that the materials used in the hose are appropriate for use in food. Typically, if there isn't an NSF or other indicator of the material on the hose, it will get rejected by an astute inspector.

 

Here are the applicable portions of the code:

 

Here are the FDA requirements:

 

 

 

Prove it's made of nontoxic materials appropriate for use in food, otherwise get a different hose.







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