Allergen Management regarding Contractor Tools

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

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?

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.

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

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.

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?

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!

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

Thanks all

Good morning all, I know that this is an older thread but I came upon it by way of a search for contractor training due to an audit finding from our largest customer, we co-manufacture for this large multinational corporation. The finding was that our contractor sign in/training is not sufficient to cover allergen control and possible product contamination due to work being conducted. I know that some on this thread have suggested an issue with contractor contamination from outside sources of allergens but we have multiple production lines which may be running dissimilar allergens on the same day, we segregate our process equipment and personnel. The auditors point was that the contractors need to be made aware that their movement and activities within the facility may lead to cross contact issues. I have been looking for an example of a contractor sign in/training that would meet the requirements even if it is a reach from the standards (this is our largest customer).

Have you sent the contractor(s) your allergen training ahead of time?  Can they complete the training and return it to you?  The same or similar to what you'd give your own maintenance department?

 

We have a package we send to our contractors annually, they sign off on the package and return the completed copy to us