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Do processed food facilities require a sink solely for handwashing in production area?

BRC cdph handwashing sink

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#1 Kristen123

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Posted 15 September 2020 - 05:11 PM

Hi All, 

 

I have seen many mixed-answer regulations involving the requirements of handwashing sinks in the production area of a food facility. 

 

The FDA said this is required but was unclear on the actual location. I believe it has to be near a outside door in the production area and if not placed there, you can use signage to direct employees. 

 

When I asked the CDPH (California Department of Public Health), they said it must be accessible and not in the restroom, but nothing else. 

 

I will be doing a BRC audit in the future and just need clarification on this requirement.

 

Can anyone clear up this issue? 

 

Thank you in advance!



#2 SQFconsultant

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Posted 15 September 2020 - 06:40 PM

Normal placement is at  ingress areas to production and then in readily accessible to employees.

 

All of our clients for SQF, BRC and IFS have a hand-washing sink at ingress point to production with some having additional locations in production that are readily accessible - it depends on the size of production.  I've got an SQF facility that has 500,000 square feet of production - 1 big square block and they have at ingress and then other locations so that employees do not have to walk too far to get to a designated hand wash sink.


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Glenn Oster
 
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#3 Kristen123

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Posted 15 September 2020 - 07:26 PM

Hi Glenn, 

 

Thank you for your very helpful response, I really appreciate it.

 

Are you aware of any regulatory codes or regulations, whether it be CDPH or FDA, that will state this as well?



#4 rewel

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Posted 15 September 2020 - 10:06 PM

Hi Kristen,

 

We had this issue when we moved facilities, the only place we could put the wash basin was in the middle of production where there was actually plumbing to do so as they did not want to pay for getting plumbing to the entry door. I did a risk assessment, created a map with the the direction to take to the wash basin and put this at the entry to production and in our GMP SOP. Finally i conducted training on it. The BRC auditor had no issue with it.

 

We produce a low risk product through.

 

Regards,

Rob



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#5 Charles.C

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Posted 16 September 2020 - 07:44 AM

Hi All, 

 

I have seen many mixed-answer regulations involving the requirements of handwashing sinks in the production area of a food facility. 

 

The FDA said this is required but was unclear on the actual location. I believe it has to be near a outside door in the production area and if not placed there, you can use signage to direct employees. 

 

When I asked the CDPH (California Department of Public Health), they said it must be accessible and not in the restroom, but nothing else. 

 

I will be doing a BRC audit in the future and just need clarification on this requirement.

 

Can anyone clear up this issue? 

 

Thank you in advance!

Hi Kristen,

 

It may depend on what yr business is and the specific location.

 

IMEX (seafood, not USA) similar to Glenn. Main handwashing points are typically within main line leading to entry to Production area(s) and in vicinity of Restrooms. An additional, isolated, handwash station after/close to entrance to Production area  was acceptable to BRC.

 

Hand/Glove-dipping stations are located at appropriate points within the Production area.


Kind Regards,

 

Charles.C


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#6 kingstudruler1

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Posted 16 September 2020 - 01:44 PM

I agree with others. Where employees enter and then readily available. I did receive a minor once for not readily available.
it was in a facility that had probably 3 times as many handwashing sinks as much larger facilities that I managed.
IMO the larger facilities had inadequate handwashing locations and got by.

As far as I know, there is no stated distance for "readily available" Its up to the auditor and your ability to justify the distance.



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#7 Ryan M.

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Posted 16 September 2020 - 05:17 PM

There is no specific guidance or regulation concerning specific locations.  Simply, "they have to be conveniently accessible."  Good judgement as to what this means must be used and be able to defend it during audits / inspections.

 

Hi Glenn, 

 

Thank you for your very helpful response, I really appreciate it.

 

Are you aware of any regulatory codes or regulations, whether it be CDPH or FDA, that will state this as well?



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#8 Kristen123

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Posted 16 September 2020 - 11:04 PM

Thank you all for your help, I greatly appreciate it!



#9 Charles.C

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Posted 17 September 2020 - 12:55 AM

There is no specific guidance or regulation concerning specific locations.  Simply, "they have to be conveniently accessible."  Good judgement as to what this means must be used and be able to defend it during audits / inspections.

 

Hi Ryan,

 

Hard to believe although I seem to recall a similar text in Codex Process Guidelines.

 

How about USDA ? They usually seem to have rules for all Process-related items ?

(Product remains unknown)


Kind Regards,

 

Charles.C


#10 Ryan M.

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Posted 17 September 2020 - 12:53 PM

No sir, USDA does not have prescriptive requirements for hand wash sinks.  They leave it to the operator, facility, with oversight from inspectors.  Inspectors will tell you if the hand wash sink is in proper location or not.

 

Only they be placed in or near toilet and urinal rooms, and be placed at any other places in the establishment necessary to ensure cleanliness of all persons handling any product.

 

That's the beauty of US Regulation....lots of gray areas...good or bad.

 

Hi Ryan,

 

Hard to believe although I seem to recall a similar text in Codex Process Guidelines.

 

How about USDA ? They usually seem to have rules for all Process-related items ?

(Product remains unknown)







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