Jump to content

  • Quick Navigation
Photo

Hand Sanitizer in Manufacturing Plants


  • You cannot start a new topic
  • Please log in to reply
9 replies to this topic

Weebus90

    Grade - MIFSQN

  • IFSQN Member
  • 76 posts
  • 3 thanks
2
Neutral

  • United States
    United States

Posted 11 December 2019 - 06:10 PM

HI Everyone, 

I have a health department inspector requiring hand sanitizer in my manufacturing plant. 
We produce bakery type products that are Ready to eat. 

 

I know GFSI codes require this in the RTE high risk areas but as far as the food code, i am unable to find this requirement. 

 

Is anyone able to assist or point me to the code?

 

Thanks!

Weebus



pHruit

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,760 posts
  • 708 thanks
417
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 11 December 2019 - 06:29 PM

Someone on your side of the pond may be able to give another reference that is clearer, but it's certainly mentioned in 21CFR 110.10(b) and 110.37(e), albeit in a "where appropriate" capacity. I'd have thought that the "and sanitizing if necessary to protect against contamination with undesirable microorganisms" part in 110.10(b) would apply for RTE, but again I'm not in the US so not intricately familiar with the interpretation of these requirement. Nonetheless I hope it helps as a start!



kfromNE

    Grade - PIFSQN

  • IFSQN Principal
  • 601 posts
  • 186 thanks
152
Excellent

  • United States
    United States
  • Gender:Female
  • Interests:Bicycling, reading, nutrition, trivia

Posted 11 December 2019 - 06:49 PM

We recently had a health inspector from the FDA tell us the same thing and almost wrote it up as a 483 - we fought her on it. She let it go. She cited 117.10 (b) (3) - Washing hands thoroughly (and sanitizing if necessary to protect against contamination with undesirable microorganisms) in an adequate hand-washing facility before starting work......

 

It's a corporate policy for us not to have hand sanitizers. We did a risk analysis to why we don't use them (employees would skip washing their hands and only use the hand sanitizer even though they were educated multiple times not to do that)

 

We'll have to see what happens at the next inspection.



The Food Scientist

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,034 posts
  • 262 thanks
199
Excellent

  • United States
    United States
  • Gender:Female
  • Interests:Food Science, Nature, SQF, Learning, Trying out new foods, Sarcasm.

Posted 11 December 2019 - 06:52 PM

It would probably fall under "FDA 8 KEY SANITATION AREAS".

 

CFR-21 

 

https://www.accessda...h.cfm?fr=123.11

 

You would need to develop a form where you need to check sanitizing and washing areas are adequate. I had a health inspector ask for that form and referenced this part to me. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


QAGB

    Grade - PIFSQN

  • IFSQN Principal
  • 671 posts
  • 255 thanks
107
Excellent

  • Earth
    Earth

Posted 11 December 2019 - 07:20 PM

It would probably fall under "FDA 8 KEY SANITATION AREAS".

 

CFR-21 

 

https://www.accessda...h.cfm?fr=123.11

 

You would need to develop a form where you need to check sanitizing and washing areas are adequate. I had a health inspector ask for that form and referenced this part to me. 

 

 

Hey Food Scientist,

 

Not trying to nit-pick, but this might be the better link for general sanitation (below). The link you provided is more for fisheries and so forth. As to the sanitizer, I would certainly have to argue the "where necessary" point. We provided hand sanitizers, but didn't consider them to be necessary. Never had an auditor or inspector from the FDA bring it up.

 

To the OP - If you have a risk assessment created to show why sanitizers are not needed, I don't see why that wouldn't satisfy the "where necessary" statement in the FDA regs.

 

https://www.ecfr.gov...10_137&rgn=div8


Edited by QAGB, 11 December 2019 - 07:20 PM.


Thanked by 1 Member:

The Food Scientist

    Grade - FIFSQN

  • IFSQN Fellow
  • 1,034 posts
  • 262 thanks
199
Excellent

  • United States
    United States
  • Gender:Female
  • Interests:Food Science, Nature, SQF, Learning, Trying out new foods, Sarcasm.

Posted 11 December 2019 - 07:32 PM

Hey Food Scientist,

 

Not trying to nit-pick, but this might be the better link for general sanitation (below). The link you provided is more for fisheries and so forth. As to the sanitizer, I would certainly have to argue the "where necessary" point. We provided hand sanitizers, but didn't consider them to be necessary. Never had an auditor or inspector from the FDA bring it up.

 

To the OP - If you have a risk assessment created to show why sanitizers are not needed, I don't see why that wouldn't satisfy the "where necessary" statement in the FDA regs.

 

https://www.ecfr.gov...10_137&rgn=div8

 

Oops! Thank you! 

 

The thing is every inspector is different which is why we should always ask them why they said this and that and ask them where in the code it shows that? 

 

I worked in a RTE snack manufacturer and we had no hand sanitizers and never was an issue. Now I work in a RTE spice/snack/seasoning and we have them but never had a form to monitor them and the inspector asked for that! Strange.


Edited by The Food Scientist, 11 December 2019 - 07:34 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


Thanked by 1 Member:

QAGB

    Grade - PIFSQN

  • IFSQN Principal
  • 671 posts
  • 255 thanks
107
Excellent

  • Earth
    Earth

Posted 11 December 2019 - 07:44 PM

Oops! Thank you! 

 

The thing is every inspector is different which is why we should always ask them why they said this and that and ask them where in the code it shows that? 

 

I worked in a RTE snack manufacturer and we had no hand sanitizers and never was an issue. Now I work in a RTE spice/snack/seasoning and we have them but never had a form to monitor them and the inspector asked for that! Strange.

 

 

Yep! I became very adept at asking auditors/inspectors where a standard or code stated what they were questioning. I grew tired of auditors/inspectors trying to throw their own interpretations & suggestions in where they didn't belong. I also learned that risk assessments were my best friends.



Thanked by 1 Member:

Weebus90

    Grade - MIFSQN

  • IFSQN Member
  • 76 posts
  • 3 thanks
2
Neutral

  • United States
    United States

Posted 11 December 2019 - 08:22 PM

Thank you everyone for your quick responses, they were all very helpful!



SQFconsultant

    SQFconsultant

  • IFSQN Fellow
  • 3,746 posts
  • 943 thanks
829
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:American Patriot
    WWG1WGA
    Never give up, never give in - always win!
    Martha's Vineyard Island, Massachusetts

Posted 12 December 2019 - 01:36 AM

I was doing an SQF Audit one day at a coffee company and they had a small restaurant, more like a silver New Jersey diner out front and the BOH showed up to do an inspection.

 

The funny thing was the company wanted the restaurant included in the scope.

 

So, there I was inspecting the diner and in walks the BOH - we chatted, he did his inspection first and I sat down and had a cup of coffee while he was doing that.

 

He looks at me and says, under SQF is this a violation?... pointing to the hand-washing sink not having soap, but only having sanitizer and I said, yes --- he said, no it's not in my book, I told them to get sanitizer and pull the soap!

 

to which I had to open my mouth up and say, can you show me the code on that?

 

He could not answer, gave them an A rating and left.

 

Strange world!


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant Retainer Subscriptions - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday
 
 

FurFarmandFork

    Food Safety Consultant, Production Supervisor

  • IFSQN Fellow
  • 1,264 posts
  • 584 thanks
191
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Oregon, USA

Posted 12 December 2019 - 04:58 PM

Weebus90, what state/county are you being inspected in? That way we can look at or point you in the direction of the code they're auditing against.


Edited by FurFarmandFork, 12 December 2019 - 04:58 PM.

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.




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users