Sharps Control - Required inspection frequency?
It's inferred that since it's says they will be located nearby, that you would write your procedure to state that PPE must be removed and hung on the hooks provided before entering the washroom
Wearing any PPE inside the washroom is gross and can lead to cross contamination issues
Wanted inputs if the following sharps control policy is adequate for a Bottling line which produces Wine:
1. We allow cutters to remain at their given stations in the bottling line (not checked in or out); cutters are not fixed to their stations
2. The cutters are engraved with codes specific to the station that they are used which is designated by a cutters map
3. Before production, Bottling staff inspects their cutters condition, checks the cutter code (if the cutter ID is correct for their station) and records the results.
4. Cutters failing inspection are replaced by the Manager who records the replacement day, cutter location, new cutter ID, adds cutter to the cutter log, engraves the new cutter and brings to the station
5. We only require daily sanitizing of cutters used to open primary packaging materials (corks, screwcaps)
NOTES: The bottling line uses cutters constantly to open up primary and secondary packaging materials and bottling staff gets in before their Managers who would be the ones to check out cutters. Due to this and \eadcount, we've determined checking in and out cutters each morning would be very difficult, would negatively impact production, require us to change people's shifts in order to comply and be a big pain.
Thoughts ?
Our risk assessment for not checking in/out cutters was that
Did you mean to continue your post after "cutters was that"? Either way, it sounds like a pretty ironclad system to me. A common issue with knife control policies is that the number of knives may be accounted for, but they lack serial numbers so they can be shifted around without anyone knowing. For your replacement problem, is there a senior operator that you can train/designate as having authority to make cutter replacements if a blade fails inspection? That may solve your scheduling issues.
@NorCalNate, I don't see any glaring faults with what you've described, other than to ensure the cleaning and sanitation of those knives are accounted for on one of your pre-op checks.
11.7.3.8 Knives and cutting instruments used in processing and packaging operations shall be controlled, kept clean, and well maintained. Snap-off blades shall not be used in manufacturing or storage areas.
"...shall be controlled" is something to keep in mind with your program. If you find that knives are wandering too frequently to other areas, it could become a minor finding you'd want to correct. And I could see an auditor wanting you to show them the designated storage space for each knife as part of the control. Last thought: as you're taking the steps to clean and sanitize only the knives involved in cutting primary packaging, you've identified that those knives could contaminate your ingredients. When storing those knives between use, you might want to make sure they're being placed in a sanitized tray or box of some sort when not actively being used, and that no other employee not involved in cutting primary packaging is permitted to take it and use it briefly elsewhere.
Did you mean to continue your post after "cutters was that"? Either way, it sounds like a pretty ironclad system to me. A common issue with knife control policies is that the number of knives may be accounted for, but they lack serial numbers so they can be shifted around without anyone knowing. For your replacement problem, is there a senior operator that you can train/designate as having authority to make cutter replacements if a blade fails inspection? That may solve your scheduling issues.
Yes, we designate the line lead or Bottling Manager responsible for issuing a new cutter, documenting the replacement and new ID#, throwing the old cutter. Most of our cutters are fixed-safety cutters that can't be replaced.