10 replies to this topic

[Spnzy_obdz]

Greetings!

 

I just want to ask if there is a defined distance between an Overhead Drain (from an Elevated Floor or Mezzanine) and a Food Contact Surface such as a Docking Table.

 

We package RTE Products in our Facility and we are currently using Screened/Solid Baskets for the Drains during production depending on how far the Product Contact Surfaces are from the Drains.

 

Thank you in advance!

[Charles.C]

Greetings!

 

I just want to ask if there is a defined distance between an Overhead Drain (from an Elevated Floor or Mezzanine) and a Food Contact Surface such as a Docking Table.

 

We package RTE Products in our Facility and we are currently using Screened/Solid Baskets for the Drains during production depending on how far the Product Contact Surfaces are from the Drains.

 

Thank you in advance!

Hi sp_ob,

 

Food contact surfaces means those surfaces that contact human food and those surfaces from which drainage, or other transfer, onto the food or onto surfaces that contact the food ordinarily occurs during the normal course of operations

 

Not sure what a docking table is but yr description sounds potentially rather scary.

I guess a Risk assessment is called for.

[Scampi]

My answer is WHAT!?!?!?

 

You package RTE  directly UNDER a drain--height actually makes this worse as drips will disperse further

[Tony-C]

Hi Spnzy_obdz,

 

I would agree with Charles and Scampi.

 

The relevant parts of BRCGS standard and guidance are posted below, it is no surprise that there is no defined distance.

 

BRCGS Global Standard for Food Safety Issue 9 Clause 4.4.3 Drainage:

Drainage, where provided, shall be sited, designed and maintained to minimise risk of product contamination and not compromise product safety.

 

BRCGS 4.4.3 Guidance:

Clause 4.2.3:

Drainage must be designed and maintained to ensure that product contamination risks are minimised. For example, drainage design might include methods to prevent flow back and pest ingress, and routeing of waste systems to prevent dripping on products, packaging or ingredients.

Drainage systems must not constitute a potential risk to product (e.g. from potential leakage) when passing through or over production areas.

 

Kind regards,

 

Tony

[G M]

Greetings!

 

I just want to ask if there is a defined distance between an Overhead Drain (from an Elevated Floor or Mezzanine) and a Food Contact Surface such as a Docking Table.

 

We package RTE Products in our Facility and we are currently using Screened/Solid Baskets for the Drains during production depending on how far the Product Contact Surfaces are from the Drains.

 

Thank you in advance!

 

Not as uncommon as it sounds.  Lots of packaging machinery has overhead scales or input hoppers on a mezzanine, wet wash areas usually have drains -- including mezzanines.  While not ideal to have the drain over contact surfaces, the entire mezzanine can pose some level of drip hazard with condensation, leaks etc.

 

The risk assessment is probably necessary to make sure things like good lighting, regular inspection etc. are being implemented to detect cracks or other material defects that could cause problems.

 

Height is kind of irrelevant beyond there being "adequate" space to see what is going on and make it possible to promptly detect problems.

[Spnzy_obdz]

My answer is WHAT!?!?!?

 

You package RTE  directly UNDER a drain--height actually makes this worse as drips will disperse further

 

Just to Clarify. These drains are used for Sanitation Purposes (I.e. Cleaning the Mezzanine Area). During production hours, these are covered with Solid Drain baskets that totally contains the drains to prevent contamination and drips. 

 

I am trying to search for a globally recognized standard that mentions something about the distance (not the specifically the height but the span) of a drain from a food contact surface.

 

Thank you,
SP

[Spnzy_obdz]

Not as uncommon as it sounds.  Lots of packaging machinery has overhead scales or input hoppers on a mezzanine, wet wash areas usually have drains -- including mezzanines.  While not ideal to have the drain over contact surfaces, the entire mezzanine can pose some level of drip hazard with condensation, leaks etc.

 

The risk assessment is probably necessary to make sure things like good lighting, regular inspection etc. are being implemented to detect cracks or other material defects that could cause problems.

 

Height is kind of irrelevant beyond there being "adequate" space to see what is going on and make it possible to promptly detect problems.

 

That is exactly what the mezzanine are used for in our facility

 

we don't have any problem with the Height as we are in compliance with the Mezzanine Height requirements. it is actually the Span from the Food Contact Surface and the Drain Drop I am worried about. currently, I am pushing to propose at least 1-2 feet distance from drain to the Food Contact Surface to completely eliminate possible contamination from splash/drips but I need to find something solid to support my idea.

 

Thank you 

SP

[G M]

The main concern is likely the potential for a small slow drip from a crack in a seal or fitting.  It may be sufficient to attaching a drip pan, like the ones common under HVAC/cooling units, to divert any theoretical leak away to a secondary drain.

 

As for justification to leave space, operational sanitation inspection requires good visibility.  Having adequate lighting between the surfaces and a wide enough field of view for inspectors of varying heights to see into the space is a good starting point.

[GMO]

I think I know the kind of thing.  I've certainly seen in a low risk facility a drain pipe which leads from a mezzanine or higher level down to low level to take away wash water.

 

Firstly this all falls into the areas over plant areas clause to my mind rather than 4.4.3

 

4.4.6:

Where elevated walkways, access steps or mezzanine floors are adjacent to or pass over production lines which have open products, they shall be:

• designed to prevent contamination of products and production lines

• easy to clean

• correctly maintained.

So to my mind, the typical solutions I would see for these mezzanines are, they'd have kickplates so would have a large lip at the edge of the floor surface and the drain from that surface would not be directly over the production line.  If it is you may want to look at the fabrication of it and consider the risk of leaks etc.  Even if wet cleaning only occurs during downtime, you should still be trying to avoid cross contact and the unexpected sometimes occurs.  If you're happy there is no risk, document your risk assessment.  If there is, document it, change it then document the change.

 

When this clause came in with v8 we had a lot of walk over areas as I was in low risk at the time.  We did a systematic risk assessment of every set of steps and platforms.  It was worth it not just to evidence it to an auditor but we also found about four points where we made the protection more robust.  

Edited by GMO, 30 May 2023 - 03:48 PM.

[Charles.C]

I think I know the kind of thing.  I've certainly seen in a low risk facility a drain pipe which leads from a mezzanine or higher level down to low level to take away wash water.

 

Firstly this all falls into the areas over plant areas clause to my mind rather than 4.4.3

 

4.4.6:

Where elevated walkways, access steps or mezzanine floors are adjacent to or pass over production lines which have open products, they shall be:

• designed to prevent contamination of products and production lines

• easy to clean

• correctly maintained.

So to my mind, the typical solutions I would see for these mezzanines are, they'd have kickplates so would have a large lip at the edge of the floor surface and the drain from that surface would not be directly over the production line.  If it is you may want to look at the fabrication of it and consider the risk of leaks etc.  Even if wet cleaning only occurs during downtime, you should still be trying to avoid cross contact and the unexpected sometimes occurs.  If you're happy there is no risk, document your risk assessment.  If there is, document it, change it then document the change.

 

When this clause came in with v8 we had a lot of walk over areas as I was in low risk at the time.  We did a systematic risk assessment of every set of steps and platforms.  It was worth it not just to evidence it to an auditor but we also found about four points where we made the protection more robust.  

Hi GMO,

 

I note that this OP is not Low Risk which presumably, implicitly or explicitly, immediately  boosts the Risk sensitivity.

 

Regardless of "Protection" ?

[GMO]

I note that this OP is not Low Risk which presumably, implicitly or explicitly, immediately  boosts the Risk sensitivity.

 

Regardless of "Protection" ?

 

Hi Charles, I'm not sure they've said it's not high risk, only that they produce RTE which doesn't automatically mean high risk / high care.  I was thinking of snacks facilities I've visited where this kind of arrangement is common in the uncooked end but there is no barrier to cooked.  Apologies if I've misunderstood.  Perhaps the OP could clarify?