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.
Subpart B--Current Good Manufacturing PracticeSec. 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 PracticeSec. 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.