4 replies to this topic

[r.bub]

During our SQF audit, our auditor pointed out that we did not have screens or catch baskets in all of our production room floor drains.  We did not get a non-conformance, but he said we should have them and mentioned that pests could come up through the drains.  There is nothing in the SQF requirements that specifically says this is a requirement; it just states that drains must not present a hazard.  I also tried looking in FDA and our state's Food Plant license requirements and could not find anything that says you must have screens or catch baskets.  

 

Can anyone provide insight?  We don't want to get a non-conformance on our next audit, especially since we are supposedly having the same auditor.  Is this something that we could create a risk assessment for to justify why we don't have screens or catch baskets?

 

 

[Scampi]

You should can

 

Frequency of drain cleaning

 

Pest control trending report (absence of activity)

 

Sanitation processes that prevent gross debris from going down the drains

 

as for SQF code re: drains---the auditor has a strange interpretation of requirements, sounds like it's just talk on their part and a RA will cover you just fine

11.1.2.1 Floors shall be constructed of smooth, dense, impact-resistant material that can be effectively graded, drained, impervious to liquid, and easily cleaned. Floors shall be sloped to floor drains at gradients suitable to allow the effective removal of all overflow or wastewater under normal working conditions.
Where floor drainage is not available, plumbed options to handle overflow or wastewater shall be in place. 11.1.2.2 Drains shall be constructed and located so they can be easily cleaned and not present a hazard. 11.1.2.3 Waste trap system shall be located away from any food handling areas or entrances to the premises.

[jfrey123]

"Could come up through the drains" is different than "likely to come up through the drains," with could vs likely being a point I've had to argue with auditors on multiple topics. 

 

I would assume your drains at least have a metal grate, helping to prohibit large chunks of trash from flowing into the pipes, and those grates should be sufficient to stop any rodents.  I'd be happy to argue with an auditor on this topic, as the baskets or fine screens are not called out specifically in code.

 

We run into these auditor issues frequently.  They've probably audited someone who did have such mechanisms, and now they think everyone should up their game to that level.  That's an opinion not supported by code.  Similar case I can think of is when a customer auditor tried to tell me SQF code requires me to keep a temperature log for the breakroom refrigerator.  No, it doesn't, it requires we provide one for employees to use but doesn't specify monitoring.  My defense to this fella was that we are compliant per our SQF audits, employees can notify a supervisor if there's a problem with it, we notice it working when we clean it during master sanitation periods, and he still tried to argue it.  At that point, I thanked him for his observation and told him we need to move on.  Same approach can be taken for an auditor stating their opinion that you need to improve something already compliant.

[Hoosiersmoker]

Drain flies can crawl through any typical drain grate however, they are not an issue everywhere and typically can't breed or survive in active drains. Perform a risk assessment to determine if any insect activity is likely. It's statements like: "and not present a hazard" that create the grey area some auditors love to live in but also requires some effort to eliminate said grey area. If your floor drains are used regularly / daily for washdowns, the likelihood of insect activity is extremely low and your risk assessment will show that therefore the existing grate is sufficient for your purposes..

[Kara S.]

Screens and catch basins are to help prevent food/large materials from entering the drain pipe and clogging your system. 

 

Flies/ insects would still get through with that and an insect screen on a drain would likely cause issues with flow down the drain. I've also never heard of rodent coming up process drains - i think thats a bigger issue that screens and catch basins wouldnt be an appropriate corrective action for anyways. That same auditor can then say well - when you take the basin out to clean it, you are at risk for pests to come through the drain. 

 

I wouldn't much merit into the comment.