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SQF Auditors - Hand Wash Temperature

Worker Hygiene Hand Washing GMP Module 11

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nlamers

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Posted 09 January 2020 - 07:43 PM

Hi All,

 

Our food manufacturing facility is in the process of sourcing some new hand wash basins. Unfortunately, our plumbing is laid out such that installation of hard-piped basins would require several thousand dollars worth of modifications, so we're leaning towards portable units with fresh and grey water reservoirs. Although portable units with built-in heaters are an option, non-heated units cost roughly half as much, and the code (11.3.2.2, part i) specifies only that water must be "an appropriate temperature." I've reached out to SQFI directly for clarification on what constitutes "appropriate," and was told that all auditors the rep had ever worked with would simply let the water run for a few seconds to make sure it reached a comfortable temperature.

 

I understand and completely support the need for comfort (after all, no one wants to wash their hands with frigid water!), but I need slightly more concrete support to justify the extra expense to upper management. So I have to ask:SQF auditors, if you were inspecting a facility and a hand wash basin was only able to supply cold or even cool water, would you cite it as a non-conformance?

 

Thanks for your input!



SQFconsultant

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Posted 09 January 2020 - 08:17 PM

I am former SQF Auditor and prior to that I did inspections for Wal-Mart, Sams, Trader Joes, Target.

 

I borrowed the Appropriate hand washing temperature and applied it to my SQF work based national boards of health (such as NY that requires 100 degrees) and the corporate QA offices for the big box stores - they were all in the 100 range, from just a little below  to just a little bit above - but the average was 100.

 

As an Auditor I did not wait a couple of seconds or more for the water to achieve 100 - the tap should give you instant 100 - many of the portable units, like the one the seafood company that I am at right now will be be installing are instant 103's and that allows the water flow out of the tap at 98-101 on average.

 

As an SQF Auditor our entire team of Auditors used instant thermometers to check the water temp.

 

Most of the portable units only have warm water and not 2 taps, they normally also have an instant hot water boost unit.

 

With all that said the only time I have ever seen an employee wait for water to become warm in a 2 pipe system was when I was standing behind them or in the area.

 

To the question - if I was inspecting a facility your facility and it only had cool or cold water it would be gig'd as an NC and I would not wait until the water temperature came up, because your employees won't wait - they will wash their hands in cold water.


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FurFarmandFork

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Posted 10 January 2020 - 01:19 AM

Yeah, it's in there so even if it's not a specific temperature, cold water only will be a minor non conformance.

 

This has always frustrated me about the code, items where, without the handwashing sinks you have a perfect score, but I add an extra one for employee convenience and suddenly I have a NC for it not being hot.

 

Management commitment is real and important, but sometimes things just work out funny that way.


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.

MsMars

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Posted 10 January 2020 - 07:57 PM

 

 

 (after all, no one wants to wash their hands with frigid water!), 

 

I am not an auditor so I don't have a perspective on how much of an audit finding this would be. But strictly from a food safety perspective, you said it all with this quote - no one likes washing their hands with cold water and many will not wash their hands properly if they have to use cold water.  Not having warm water mayhave greater implications than just an audit finding. 



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Posted 10 January 2020 - 11:52 PM

US Food Code states that hand washing water temperature should be 100F. One time when we were inspected by FDA, he didn't really cited us for not having 100F temp. Instead, he said as long it's warm then it's fine. Interestingly too, one recent study regarding water temperature when washing indicates that water temperature is not a critical factor for the removal of transient microorganisms from hands. I'm not an auditor but I would challenge it if we get a minor NC for not having 100F when there's really no scientific evidence  that washing your hands with hot water removes more bacteria than cold water. Maybe just an OIP (opportunity for improvement) but not a minor?  We  also verify our employees hand washing effectiveness by swabbing them after they wash their hands so I think that should be enough to address the issue.   

 

Here's the link for the study. Quantifying the Effects of Water Temperature, Soap Volume, Lather Time, and Antimicrobial Soap as Variables in the Removal of Escherichia coli ATCC 11229 from Hands

https://jfoodprotect...ournalCode=food



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Posted 13 January 2020 - 04:18 PM

I have had multiple auditors turn it on, wait for it to get warm, and call that appropriate, again all based around employees not washing if ONLY cold or ONLY hot is available, you need to provide comfortable temperatures for hand washing.  







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