7 replies to this topic

[semajzemog]

Good day everyone!

 

I had a question that may have been answered before, however, not exactly to my current situation. If you have free time and some guidance I would appreciate the consideration!

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Condensation has been building up on the hood vents and the trough around the lining of the vent which is either directly or within 1.5' of our cooking vessels.  Raw ingredients are transferred into the vessels from this point as well. 

 

I noticed some dripping coming from a hole in the trough, which I found was made before my time to solve the issue of condensation pouring out of the trough in random areas. When I saw water dripping onto employees and, potentially, raw ingredients, I cleaned the hood vent trough, had the employees change their smocks, and let the maintenance manager know that we needed a permanent solution.  His solution was to patch the hole back up, which to me sounds like I'll be dealing with the issue again very soon!

 

I called attention to this through direct conversation and emails between myself (QA Manager / Asst. Production Manager), the owner, and the Production Manager, citing many of the well known cases (Delta, Whole Foods, etc.) of warning letters along with CFR 110.20 (b) (4), to which I got the following replies:

 

"Let's only escalate for persistent, bigger safety problems" and "For situations like this all that is needed...is to apply silicone" and "What is the problem with water from condensation dripping in the food that is being cooked and boiled?"- Owner

"Cover the hole with...silicone solution...and have the night crew clean any accumulation of water before they start cleaning" - Production Manager

 

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I took the silicone solution as a slap, as the entire reason for that hole was condensation buildup from my investigation, and felt like there was little support for the potential of unintentional adulteration. That's another gripe for another day!

 

So!  For all of the veterans of Quality, Food Safety, Regulatory, and 3rd party auditing schemes: What is the next move? 

 

I did say very explicitly that in the event this occurs on my watch the food will be destroyed, and if there's any push back, I'll contact who I deem necessary for further guidance.  I know it's not top marks for professionalism but I didn't rise to this station by kowtowing to every business owner that demeaned my position. :-)

Edited by semajzemog, 11 May 2023 - 04:03 PM.

[Setanta]

Hello!
I need a little more detail as to what you are making and what this process is. It sounds almost like a restaurant, but not exactly. What causes the condensation? Would a different hood alleviate the problem? A tighter seal?

[semajzemog]

Hello!
I need a little more detail as to what you are making and what this process is. It sounds almost like a restaurant, but not exactly. What causes the condensation? Would a different hood alleviate the problem? A tighter seal?

Thanks for asking!

 

We manufacture RTE bean dips and spreads at this facility.

 

The general process is: raw ingredients into kettles > cook step > acid addition > product transfer through pumps and pipes > hot fill > seal > cooling > labeling > pack. 

 

It has a restaurant feel sometimes, however, this is a manufacturing plant.  Condensation comes from the continuous boiling of beans in water under medium to large restaurant style hood vents.  I worked restaurants previously to this chapter in my life but I have not seen this much condensation continuously handled by restaurant style hood venting systems.  A different hood may alleviate the issue, however It has been recommended, and I don't foresee the financing becoming available for that type of purchase unless I can demonstrate that it is truly a make-it-or-break-it situation.

 

I had a stint with a large soup manufacturer within the last couple of years that had very large hood vents and kettle capacity, however, they had much greater control of their temperatures for their operators and, although producing 100K+ pound of soup daily, did not have this much condensation.  If I could help them start over I would have recommended more capacity from the outset for best practices. 

[Scampi]

The condensation means the the hood is not large enough e.g. does not remove enough air, for your process and should be upgraded to a more powerful unit

 

You have another statute to back you up

 

4) Be constructed in such a manner that floors, walls, and ceilings may be adequately cleaned and kept clean and kept in good repair; that drip or condensate from fixtures, ducts and pipes does not contaminate food, food-contact surfaces, or food-packaging materials; and that aisles or working spaces are provided between equipment and walls and are adequately unobstructed and of adequate width to permit employees to perform their duties and to protect against contaminating food, food-contact surfaces, or food-packaging materials with clothing or personal contact.

 

TITLE 21--FOOD AND DRUGS CHAPTER I--FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF HEALTH AND HUMAN SERVICES SUBCHAPTER B - FOOD FOR HUMAN CONSUMPTION

PART 117 -- CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR HUMAN FOOD

Subpart B - Current Good Manufacturing Practice

Sec. 117.20 Plant and grounds.

 

(4) Be constructed in such a manner that floors, walls, and ceilings may be adequately cleaned and kept clean and kept in good repair; that drip or condensate from fixtures, ducts and pipes does not contaminate food, food-contact surfaces, or food-packaging materials; and that aisles or working spaces are provided between equipment and walls and are adequately unobstructed and of adequate width to permit employees to perform their duties and to protect against contaminating food, food-contact surfaces, or food-packaging materials with clothing or personal contact.

Edited by Scampi, 11 May 2023 - 06:39 PM.

[semajzemog]

The condensation means the the hood is not large enough e.g. does not remove enough air, for your process and should be upgraded to a more powerful unit

 

You have another statute to back you up

 

4) Be constructed in such a manner that floors, walls, and ceilings may be adequately cleaned and kept clean and kept in good repair; that drip or condensate from fixtures, ducts and pipes does not contaminate food, food-contact surfaces, or food-packaging materials; and that aisles or working spaces are provided between equipment and walls and are adequately unobstructed and of adequate width to permit employees to perform their duties and to protect against contaminating food, food-contact surfaces, or food-packaging materials with clothing or personal contact.

 

TITLE 21--FOOD AND DRUGS CHAPTER I--FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF HEALTH AND HUMAN SERVICES SUBCHAPTER B - FOOD FOR HUMAN CONSUMPTION

PART 117 -- CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR HUMAN FOOD

Subpart B - Current Good Manufacturing Practice

Sec. 117.20 Plant and grounds.

 

(4) Be constructed in such a manner that floors, walls, and ceilings may be adequately cleaned and kept clean and kept in good repair; that drip or condensate from fixtures, ducts and pipes does not contaminate food, food-contact surfaces, or food-packaging materials; and that aisles or working spaces are provided between equipment and walls and are adequately unobstructed and of adequate width to permit employees to perform their duties and to protect against contaminating food, food-contact surfaces, or food-packaging materials with clothing or personal contact.

Thanks for the response!

 

I feel that this should really be the only thing I need to show as well.  

 

As far as the hood vents are concerned, I did recommend that we may need new hoods to capture the volume of steam and direct it elsewhere.  I can double down on this because, as you stated and Satanta asked, a larger & more powerful hood vent would most likely solve the issue. Unfortunately, this means I'll need to find a way to convince ownership that the investment is worthwhile, i.e. no warning letters from our pals at the FDA, which may take an instance of loss to really illustrate the issue and prove that the solution of silicone will not suffice. 

 

I appreciate your input!

[kingstudruler1]

You mention that the condensation collects in a trough and they put a hole in the trough to allow it to drain.   Until you can upgrade hoods/fans, could you add a drain line to remove the condensation to drain or other "safe" area?   Have you increased sanitation and monitoring of the hood?  testing could provide more data to support the replacement.   

[Brothbro]

If it helps, I can tell you from experience that FDA inspectors are very keen on issues like this. Dripping condensation from vents, AC units, condensers, etc is something they -always- look for. It's a 100% certainty that it will be called out, and at that point a solution will need to be found. Obviously a new hood is the best solution, but for companies without a lot of capital solutions like what kingstrudler1 have suggested can work.

 

1. Upgrade condensation collection system to ensure safe drainage

2. Ensure sanitation program of hoods is sufficient, do they get cleaned? How often?

3. Environmental monitoring of hoods to determine what hazards exist in the condensate.

 

All three of these options combined are definitely cheaper than a new hood.

[jfrey123]

Scampi nailed it with the regs, which should help prove your case to the ownership here.  Hoods get dirty with environmental contaminants during production, so it's not "clean" water dripping back down onto the product you're cooking.  You're risking dust/dirt/grease getting into your cooked food, so the idea that "it's boiling, it would cook off any micro that could be present" is a poor defense.

 

I agree that a better long term solution is needed, as some have suggested possibly a redesign of the hoods or a better vent system to prevent the condensation in the first place.  Such a capital investment is likely to be a hard sell in this case from your statements though, so if you think you can get away with a drip catch of some type that drains away, that's a cheaper intermediate solution you could present as a short-term compromise.  Shortcomings from such a fix will mean increased sanitation time to keep that drip catch clean, disposing of the drainage in a safe manner (depending on what comes out of the drain catch, it might not be permissible to simply dump it down a drain).  And such a drain catch will be eyed by all of your inspectors, so having good sanitation records of it and keeping it swabbed in yoru environmental program will be a must.