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Allergen Management regarding Contractor Tools


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astro

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Posted 24 August 2021 - 05:38 PM

Hi all. I recently got picked up on a customer audit regarding Allergen status on contractor tools, "allergen status not clear or the use of contractor tools regarding allergen contamination" Can you confirm how you manage this at your site and where you state this in the QMS. Thanks



olenazh

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Posted 24 August 2021 - 07:32 PM

What allergens could possibly be on the contractors' tools? Maintenance guys use fish-oil, butter or nut-based lubricants? Or sanitation cru use shellfish scrubs for equipment cleaning? Or scale calibration service uses weights made of walnuts? I can't come up with anything. Any examples?



Ryan M.

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Posted 24 August 2021 - 08:42 PM

Potential if they eat lunch that contains allergens and it is on their hands which can be transferred to the tools.

 

The simple way to control this is to only allow contractor work outside of production hours, or production areas.  If they do need to work in production areas, including equipment, it is segregated or sectioned off in some way to protect other areas.  The area and equipment worked on by the contractor undergoes thorough cleaning and sanitation prior to startup.  Contractor does not take their tools outside of designated area(s) during their work.

 

Then have this written up and somewhere the contractors sign off, such as signing in as part of your food defense and visitor policy.  Then you audit / inspect the work areas as work is being conducted to verify they are following policy.

 

I swear...this is such a reach, but of course it is possible.



astro

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Posted 24 August 2021 - 09:11 PM

olenazh

Don't get you!!!! Sounds like sarcasm

Contractors could of come from a nut factory, flour mill if you get me. This can then be contaminated then introduced to my factory.



olenazh

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Posted 25 August 2021 - 12:25 PM

olenazh

Don't get you!!!! Sounds like sarcasm

Contractors could of come from a nut factory, flour mill if you get me. This can then be contaminated then introduced to my factory.

No, not sarcasm at all. It's just obvious that you clean your equipment after maintenance, right? So, even if any allergen contaminates your equipment - it's going to be washed out.



TimG

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Posted 25 August 2021 - 01:30 PM

I was going to say that this is typically handled by restricting the access of outside contractors to only the area/machines they need to repair, and then doing a thorough cleaning of what they were allowed access to. 

If we were going down the rabbit hole by positing the worker could have left a flour mill, or nut factory, why not assume he was in a sewer, manure,  or septic system? The thorough sanitization of anything they worked on should, in theory, negate all of that?



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Posted 25 August 2021 - 02:16 PM

We build this into all of our service provider agreements that all chemixaks, lubricants etc require pre- ckearance with the QA manager and all items are inspected prior to work being done.

Oh! The things that a tool box can reveal!


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Posted 25 August 2021 - 03:59 PM

Post maintenance full wash down IF there is direct contact that may contaminate the finished goods

 

if you have contractors working on an HVAC unit, clearly no issue

 

I would write the program as such and add a line/check item to the sanitation log to indicated is was a post outside contractor wash down


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astro

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Posted 26 August 2021 - 07:50 AM

Thanks all






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