Our ISO auditor has taken issue with TS-13.2 which states that, "Establishments shall have employee hygiene facilities that do not open directly on to production, packing or storage areas."
Full disclosure: this audit is my first experience with the ISO GFSI standard, and I'd like to understand if this year's auditor is being too harsh with her interpretation or if previous auditors simply overlooked the issue, inattention or otherwise. I did my best to mock up an example of the layout (attached). Understanding that this specific layout wouldn't be ideal for the design of a new plant, I don't get the impression that our restrooms open directly into production areas, and it seems unnecessary to spend the significant amount of capital required to create another vestibule separating plant restrooms from the rest of the plant when EMP trends and internal audits prove that the risk is being managed effectively. Are there other options, or is the requirement as cut-and-dry as the auditor has made it out to be?
Some relevant info:
- Hot-fill-hold renders product sterile
- Product is filled and sterilized in orange rooms which contain zones 1, 2, and 3. There are no physical doors into these rooms; rather, each room has a large opening measuring ~10ft leading to the main corridor.
- A vestibule separates the production and green office area
- Restrooms for plant associates are blue
- Smock hangers are outside the restrooms to prevent cross contamination
- After using the restroom or upon entering the plant through the vestibule, employees are required to use foot baths located along the wall between the vestibule and restrooms
- The red line is approximately 15 feet. If an employee had not used a foot bath after leaving the restroom, this is the shortest distance they could walk (in full view of their co-workers) before entering a production room.
Any insight would be greatly appreciated!