Risk assessment where no drains in high-risk facilities?

Hello

Would anyone be able to advise if they have experience of not having any drains in high-risk facilities and how they managed to risk assess it to comply with BRC?

It would be good if anyone could let me know their experience of satisfying their BRC auditor when drains are not present in a high-risk area.. The only water that would be present would be waste following cleaning and that will be minimal, moreover clean downs will only be carried out during in gaps in production.

Any advice would be appreciated!

Thanks

How does your EMP look? Depends on how you're cleaning/sanitizing and if whatever you're doing is doing the same job drains would do? 

Hello

 

Would anyone be able to advise if they have experience of not having any drains in high-risk facilities and how they managed to risk assess it to comply with BRC?

 

It would be good if anyone could let me know their experience of satisfying their BRC auditor when drains are not present in a high-risk area.. The only water that would be present would be waste following cleaning and that will be minimal, moreover clean downs will only be carried out during in gaps in production.

 

Any advice would be appreciated!

Thanks

Hi dzabhi,

Product/Process ?

I would imagine the auditor's first query will be "why no drains ?"

Is there a reason ?

Hi

Thanks for your comments.

The process is quite simple and just involves the de-bagging, weighing and packaging of ready to eat protein - that is already undergone a 6 log reduction cook step (hence high risk) in another facility.

The reason for there being no drains is quite simply there aren't any in the facility and I'm trying to find out if I can justify their exclusion through a valid risk assessment or if a BRC auditor will insist on their presence. I think it will be the former but I wanted to get other opinions. And if anyone has worked in a facility with no drains, then how they managed to risk assess.

Thanks

Danny

Hi

Thanks for your comments.

 

The process is quite simple and just involves the de-bagging, weighing and packaging of ready to eat protein - that is already undergone a 6 log reduction cook step (hence high risk) in another facility.

 

The reason for there being no drains is quite simply there aren't any in the facility and I'm trying to find out if I can justify their exclusion through a valid risk assessment or if a BRC auditor will insist on their presence. I think it will be the former but I wanted to get other opinions. And if anyone has worked in a facility with no drains, then how they managed to risk assess.

Thanks

Danny

Hi Danny,

Thks reply.

I deduce an essentially dry process/RTE.

Bagged into retail packs or ?

Mainly manual operation or the opposite ?

Reason for queries is that I anticipate an auditor will judge, as usual, the situation on a RA/contamination basis.

(High Risk scenarios tend to be BRC viewed with a microscope regardless of the Process "simplicity".")

There certainly have been similar processes noted here before  but mostly for non-RTE situations.

Hi Danny,

 The only water that would be present would be waste following cleaning and that will be minimal, moreover clean downs will only be carried out during in gaps in production.

What happens to this waste water? Does it pool?

Reviewing clause 4.4.3 the wording suggests to me that it is possible to have a scenario where drains are not present, but only if there is no contamination risk i.e. splash hazard. From I.G for 4.4.3:

Drainage systems must not constitute a potential risk to product (e.g. from potential leakage) when passing through or over production areas. Where feasible, the design of equipment must ensure that process waste water(e.g. condensate drainage from refrigeration or temperature-controlled areas, or sink waste water) goes directly to a drain to minimise contamination risk.

Where significant amounts of water are used (e.g. where wet cleaning is carried out) and direct piping to a drain is not possible, floors must have adequate falls to cope with the flow of effluent (i.e. pooling of water should not occur) as this constitutes a splash hazard and, therefore, a contamination risk

I haven't experienced a facility without drains, but I anticipate a key part of the RA would regard the EMP and any contamination hazard from pooling fluid. Important not just to potentially satisfy the auditor but of course to protect the product if there is indeed a contamination issue already occurring. 

So I've worked (not high care) in facilities where areas didn't have floor drains........it can be a plus.....no harbourage point to worry about

The SSOP for the area should include either dry mopping or squeegeeing with a clean tool to the closest drain.............as long as no pooling water you should be ok 

Hi

Thanks for your comments.

 

The process is quite simple and just involves the de-bagging, weighing and packaging of ready to eat protein - that is already undergone a 6 log reduction cook step (hence high risk) in another facility.

 

The reason for there being no drains is quite simply there aren't any in the facility and I'm trying to find out if I can justify their exclusion through a valid risk assessment or if a BRC auditor will insist on their presence. I think it will be the former but I wanted to get other opinions. And if anyone has worked in a facility with no drains, then how they managed to risk assess.

Thanks

Danny

I've worked in the same facility type (Not SQF though), and we didn't have drains either. What we did was put buckets at the end of the machines so that is where all the water goes into. And simply mopping the floor. But then again it depends on how your machines are designed. 

So I've worked (not high care) in facilities where areas didn't have floor drains........it can be a plus.....no harbourage point to worry about

 

The SSOP for the area should include either dry mopping or squeegeeing with a clean tool to the closest drain.............as long as no pooling water you should be ok 

Yes, IMO Low and High are not "quite" the same thing.

Product may be meat of course.

Hello Everyone

Thank you very much for your input, each response has been useful.

I think you are reinforcing my original thoughts; it can be done but with valid risk assessment that will take into account what is done with water from machinery and any hygiene operation. And then this needs to backed up with adequate environmental monitoring.

We must also be thinking about how the pooling of water can be minimised and controlled. The machines that use water will have re circulatory systems.

Most probably we will use a wet vacuum and then have this cleaned and swabbed for listeria either outside of high risk (we then have to deal with barrier breaches) or just away from the main production and control it.

Thanks again!

Danny