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Hand Washing requirements under FSMA for Animal Feed


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Parkz58

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Posted 17 December 2019 - 05:46 PM

Hello All,

 

We have a unique situation, and combined with the FDA's notorious use of very ambiguous language, I find myself in a situation that I can't clearly see my way to the best solution.

 

PART 507 -- CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR FOOD FOR ANIMALS

Subpart B--Current Good Manufacturing Practice

Sec. 507.14 Personnel.

(a) The management of the establishment must take reasonable measures and precautions to ensure that all persons working in direct contact with animal food, animal food-contact surfaces, and animal food-packaging materials conform to hygienic practices to the extent necessary to protect against the contamination of animal food.

(b) The methods for conforming to hygienic practices and maintaining cleanliness include:

(1) Maintaining adequate personal cleanliness;

(2) Washing hands thoroughly in an adequate hand-washing facility as necessary and appropriate to protect against contamination;

Subpart B--Current Good Manufacturing Practice

Sec. 507.20 Water supply and plumbing.

(a) The following apply to the water supply:

(1) Water must be adequate for the operations and must be derived from an adequate source;

(2) Running water at a suitable temperature, and under suitable pressure as needed, must be provided in all areas where required for the manufacturing, processing, packing, or holding of animal food, for the cleaning of equipment, utensils, and animal food-packaging materials, or for employee hand-washing facilities;

 

As you can see above, there's a lot left to interpretation.

 

We have a dry grain processing facility, making livestock feed ingredients only.  There is no cause for employees to directly contact the feed, or even feed contact surfaces, at any time in processing, outside of extenuating circumstances.

 

The question is - are we required to have hand-washing facilities inside the processing facility itself?  The building is NOT heated or cooled - our restrooms, lunch room, offices, etc. are all located in another building just across the parking lot (about 50 yards away).  To put water/sewer plumbing into the facility here in MN means dealing with potential frozen/broken pipes...which, needless to say, is a serious problem in a dry facility.

 

Are we OK just having hand-washing facilities in the other building?  I realize that employees will be touching door knobs after washing their hands...but I struggle to find significant risk that would warrant installing a hand-washing station in the facility.  Heck, I'm struggling to even come up with enough risk to mandate us to put in hand sanitizer in the facility.

 

I realize that the situation would be vastly different if this were for human food, or even pet food...but this is livestock feed.  The product is going to get thrown into feed bunks at the farms that are FAR dirtier than anything in our processing facility.

 

Thoughts?



SQFconsultant

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Posted 17 December 2019 - 06:14 PM

"Are we OK just having hand-washing facilities in the other building?"

 

YES!


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Parkz58

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Posted 17 December 2019 - 06:47 PM

Thanks, SQFconsultant!

 

Out of curiosity - what factors lead you to answer that with a resounding yes?  I'm just trying to make sure I can wage a solid argument with an auditor/inspector if the issue comes up.



TimG

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Posted 17 December 2019 - 07:14 PM

Hey Parkz, one of the lines I manage is a feed grade only product. I've noticed the audits involving the feed grade product have key differences compared to the food grade audits I'm used to. I struggled with a similar issue, as I was originally considering putting hand washing in the packaging area of the feed grade line. Fortunately, after learning the product hazards a little better, I found that this would be MORE OF A HAZARD (specifically promoting mold growth) than if we kept the sink where it was. In my HACCP plan I document the increased risk of adding water to this environment as an explanation as to why we haven't.  I have never been questioned as to why I haven't put a sink in that area. In fact, the only thing the feed auditor seemed to be concerned with was if the employees had access to livestock or other avenues of spreading livestock related disease and where they would wash up prior to touching feed grade product if that was the case.

 

When it comes to feed, I am still very much in the learning phase. I recently found that you can store finished product outside as long as you take certain precautions. 

21 CFR 507.17-Plant and Grounds

© The plant must protect animal food stored outdoors in bulk from contamination by any effective means, including:
  • (1) Using protective coverings where necessary and appropriate;
  • (2) Controlling areas over and around the bulk animal food to eliminate harborages for pests; and
  • (3) Checking on a regular basis for pests, pest infestation, and product condition related to safety of the animal food.

 

That was a shock to a long time food guy. So take anything I say in the feed grade arena with a huge grain of salt.



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Parkz58

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Posted 17 December 2019 - 07:45 PM

tgoss11, thank you!!  That's right along the same lines of thinking that I was already having, but I wanted to run it by wiser heads to see if I was tracking correctly, or if I was way off in left field.

 

I certainly agree that the potential introduction of water (especially accidental) to our dry facility would pose FAR more risk.  I also am very familiar with the BSE (and other livestock disease) risks, and so for us, it's far more important to have a captive boot policy and personal hygiene policies that address situations where people may be in contact with livestock, farms, feed yards, etc.

 

I like your thoughts on writing up an explanation of my risk assessment, and the rationale for doing what we do, and not doing what we don't do.

 

I came from a livestock feed manufacturer in my early days in food/feed safety, then went to food manufacturing, so it's sometimes hard for me to get my thinking on food/feed safety to "regress" to the feed level...so, I can relate to the initial shock sometimes when you're confronted with something that would be absolutely taboo in food, but may be OK in feed in the right circumstances!






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