7 replies to this topic

[tdunkley]

Hi All,
Wondering if there is any industry standard that prescribes that sanitation gear (rainsuits / tools / supplies) used for cleaning in raw vs rte areas of the same plant must be stored in separate physical locations. It seems intuitive to me that that this is best practice to help minimize the risk of cross contamination from employee practices, but this does not seem to be a mandatory requirement for new builds.

The question relates to a new build and unfortunately there was no consideration for this. So, if a plant is not designed for such storage space in the rte area I presume operational controls must be acceptable.

I would also welcome any examples of recalls that traced back to sanitation practices from Raw to RTE, we will need to work on rigorous training and control programs...

Regards,

Theresa

[Scampi]

What are you making Theresa?

 

My thinking would be since space is an issue (isn't it always) that you colour code the gear and even if you have to use the same space, you try and have 2 different walls for the rainsuits

 

I know you can get gear in orange and yellow.....then you could use the same coding for scrub brushes etc

 

Not aware of any recalls that specifically link movement of sanitation equipment from raw to RTE, and your swabbing post clean pre sanitizing should show if you have any sanitation issues

[itreatpets]

Like Scampi mentioned color code and separate storage on the wall. A key point I missed early on was, are you cleaning your sanitation gear after use? this would help keep the storage area clean and lower the risk of cross contamination. I also have never heard of a recall linked to sanitation gear.

[tdunkley]

Thanks for the feedback.

The products are raw and RTE (smoked) salmonids. Very sensitive to cross-contamination of Listeria. Finding it hard to reconcile having different GMP rules for nighttime sanitation staff vs. daytime production staff. This will be a point of contention...

 

Regards,

 

Theresa

[Charles.C]

IMEX for RTE, FS standards always demand a physical separation between raw/cooked RTE + the RTE colour coded uniforms,etc stored on the RTE side. Pretty much RTE101 I think.

 

Nighttime is usually where the problems come from.

[Scampi]

The only other option you have is disposable gear for sanitation with heavy aprons that could live in sanitizer when not in use.  The sanitation crew ideally would start on the RTE side, but chances are that shift isn't the same schedule as raw and that may not work

 

Have you contracted it out or is in-house?  A lot of the time, having it contracted to a reputable company (and there are a hand full of good ones in Ontario) eliminates alot of the problems, they are specialists at what they do

 

IMEX Charles, sanitation very rarely gets even 1/2 of what they actually need and they are supposed to get it super shiny clean in 2 hours---a lot is demanded and very little is given

[tdunkley]

Thank you all for the feedback.

I also feel like this is RTE 101 from a risk standpoint, but it seems there are different schools of thought on this. In addition to the above feedback, further discussion indicates that physical segregation has been accepted by BRC in the UK, so it will be interesting to see what our inspectors think of the written plan.

 

Physical segregation is unfortunately not an option as built, although it's painful to implement managerial controls when proper design could have eliminated the need for them altogether. Deep breath ... smile ... and carry on...

 

T.

[012117]

Normally, while it is not explicitly written, the cleaning implements for raw must be physically segregated from implements use for RTE to avoid risk of cross contamination. With this being said and understood, is the current practice have swab analysis and showing negative results? 

It is also with the assumption that these implements are regularly cleaned as no point to have segregation without proper implement management.