10 replies to this topic

[TAW]

Recently we had a floor company come in and do some recoating work on our dilapidated floors.  They were working over the weekend and when production staff came in, they noticed a lot more dust than usual from grinding up the old floor.  The floor company uses a suction system for their grinder and apparently after discussion with them, the grinding was more difficult than usual creating an excess of dust.  This dust got all over everything including exposed food product (that we had removed from the direct area but not an adjacent area to air dry from production that day).  Reading through the SDS sheets for all of the 3 ingredients in the epoxy coating, I am confused on the acute toxicity levels for these ingredients.  They are all at a 4.  The three epoxy ingredients are approved for indirect food contact, so what should I do?

[SnaxAuditor]

If there is a known contaminant (dust), especially originating from the floor, this should result in disposal of that food that has been contaminated. There is all sorts of nasty stuff on the floor from footwear, cracks, etc. that became airborne when the dust went in the air. 

[TAW]

Well, I agree, I am just getting undue pressure from my ownership to try and salvage some of it.  The food product in question is a hard confectionery where the water activity is negligible and they are trying to get me to justify salvaging any of it.  

[SnaxAuditor]

Well, I agree, I am just getting undue pressure from my ownership to try and salvage some of it.  The food product in question is a hard confectionery where the water activity is negligible and they are trying to get me to justify salvaging any of it.  

This would be one of those circumstances to put your foot down and say no. The water activity is irrelevant when you've got Listeria dust on it, if that's what they're trying to argue. Water activity really only matters when it comes to micro-organism growth in food, not being exposed by a known contaminant. 

[TAW]

Thanks much for the help.  I greatly appreciate it.

[G M]

If the product had been dropped on the floor and kicked around you wouldn't try to sell it would you?  Dust from floor repair is just as bad microbiologically, plus all the physical contaminants.

[SQFconsultant]

There are several types of epoxy that can be used for flooring, but only 1 or 2 are intended for food production and storage facilities.

 

Based on past experienced in spec'ing a lot of flooring it dies not sound like the epoxy used was intended for a food facility or the company did the job wrong.

 

Regardless, you now have a big task in dumping ALL food product and contact packaging and of course vac'ing the dust out of all nooks and crannies. 

 

Your flooring company has liability here. 

[TAW]

Looking at the SDS sheets and the relevant food legislation, these particular epoxy coatings are approved for use in food facilities.  From what I was told they said they had to grind the floor for coating much deeper than they have in the past causing the excess dust.  They do have a ventilation system on their grinder, but looking at the camera footage they didn't care about their own safety not using ventilation masks until the dust got to be excessive.  

[G M]

... but looking at the camera footage they didn't care about their own safety not using ventilation masks until the dust got to be excessive.  

 

I'm pretty sure most of the flooring installers we've had in recent years were all brain damaged from breathing those fumes all day without wearing their breathing apparatus properly.  Not a one of them wore their masks or ventilators remotely correctly, and they all seemed ... a little "odd".

[jfrey123]

Being an approved epoxy for use in a food facility does not make it edible.  Nor is the concrete they ground up and into the product.  I hate that some production teams even consider that the product is salvageable when exposed to random contaminations such as this.  The product is 100% adulterated and trying to salvage it would be a violation of federal law at this point (because nothing I'm aware of in the world would be able to clean this product).

 

Go grab a couple pieces of bread and your food safe grease from maintenance.  Make them some sandwiches and ask if they'd like to eat them.  While they're all immobilized and stunned by the audacity of your stunt, go have production denature the product and discard it.

[TAW]

Update (and thanks for all the help and encouragement):  I was able to convince the owner through a simple analogy that product wasn't salvageable.  Sometimes he (and many other food company owners) get so worked up about the logistics and trying to save money that maybe I need to dumb it down even further which is what I did.

 

I basically explained as others easily pointed out above as follows: "I'm gonna take all of this and put it all directly on the floor for the whole weekend, rinse it with some water afterward, and call it good and you get to eat the first piece. You okay with that? No? Cool.  So, what then if I grind up the floor into dust and then just start throwing that dust directly all over the product, let it sit for two days and then rinse it with water. You get to eat the first piece of product after that?  No?  Cool.  Then if you're not willing to do it, then why would you ever think of doing that to a customer?"

 

Case closed.