10 replies to this topic

[ChristinaK]

Our big seasonal production is winding down, and I have been walking around and looking at some of our equipment. We assemble gift sets that include food; all food is pre-packaged at the original manufacturer so there is no exposed food at our site (unless a bag or jar breaks open).

 

We use simple wood work tables for assembling the boxes, inner package supports, placing the items, etc., then they're slid down to a conveyor for boxing, then palletized. The tables end up covered with a ton of tape and glue dots over the season, and after many seasons the tables are looking a bit rough (see photo). There aren't any loose bits that would cause a splinter, but I wanted to try covering the tops with some kind of plastic, contact paper, or vinyl. I'm thinking they will be easier to keep clean, too.

 

What concerns me under 11.1.7 is 11.1.7.5 specifically. 

 

11.1.7.5 Benches, tables, conveyors, mixers, mincers, graders, and other mechanical processing equipment shall be hygienically designed and located for appropriate cleaning. Equipment surfaces shall be smooth, impervious, and free from cracks or crevices.

 

Our manufacturing process is very low-risk, so would my contact paper/vinyl solution raise a NC? We have about 100 or so of these wood tables, so replacing them all is not an option. While there aren't splinters or large cracks or crevices, there are little dings and nicks so as they currently are, the tables are not completely smooth or impervious. 

 

 

[ChristinaK]

Ah nuts. Forgot to attach the picture of the table. Here it is.  20241010_135159.jpg   104.28KB   0 downloads

[kconf]

Since you are a very low risk facility, I don't see a problem with plastic covers. They can be wiped down and sanitized when necessary too. Are you talking about covering when not in use (end of season) or all the time? 

 

100 is a huge number to replace, otherwise I was going to suggest another option. 

 

Do you have a risk assessment done for them to be used in this condition already?  

[jfrey123]

Man, what a question lol.  If you're already certified, the tables themselves are obviously good-to-go.  To quell any concerns about the table condition, I would suggest an SOP that all of the pre-packaged food items are to either remain in their original boxes or that you use plastic bins if you need to split out the cases between employees.  If you go with bins, probably need to have a dry cleaning schedule for them (daily at end of shift or something, just have whomever was using it wipe it out.  Any concerns about the table should be negated by the fact the product is all sealed, and then doubly so if you never remove it from it's case except to place it in the basket.  If it's not a room you're wet cleaning to begin with, then I have a hard time believing an auditor would be auspicious enough to write an NC for harborage in those tables.

 

I would have almost more concern that if you add a washable surface to the tops of these tables, then an auditor is going to ask why you're not washing it?  Also, I think the paper idea invites more questions than solutions as well:  What if it tears?  What about paper waste falling on the floor?  Etc.

[ChristinaK]

Since you are a very low risk facility, I don't see a problem with plastic covers. They can be wiped down and sanitized when necessary too. Are you talking about covering when not in use (end of season) or all the time? 

 

100 is a huge number to replace, otherwise I was going to suggest another option. 

 

Do you have a risk assessment done for them to be used in this condition already?  

 

I was thinking of applying the covers so they would be on during seasonal production. That way the table surface would have an impermeable and easy-to-sanitize surface.

Even with almost 100 tables we still use flat-top utility carts as additional work surfaces because some finished product items are just massive or incredibly intricate.

 

Because no food is manufactured here and it's all pre-packaged RTE, shelf-stable products from GFSI suppliers, the GMP audits that we've had in the past have classified us as "Warehouse/Distribution GMP." The tables have never been brought up as an issue. Most of the audits were spent looking at our supplier approval and monitoring, since that's what is the biggest risk.

[ChristinaK]

Man, what a question lol.  If you're already certified, the tables themselves are obviously good-to-go.  To quell any concerns about the table condition, I would suggest an SOP that all of the pre-packaged food items are to either remain in their original boxes or that you use plastic bins if you need to split out the cases between employees.  If you go with bins, probably need to have a dry cleaning schedule for them (daily at end of shift or something, just have whomever was using it wipe it out.  Any concerns about the table should be negated by the fact the product is all sealed, and then doubly so if you never remove it from it's case except to place it in the basket.  If it's not a room you're wet cleaning to begin with, then I have a hard time believing an auditor would be auspicious enough to write an NC for harborage in those tables.

 

I would have almost more concern that if you add a washable surface to the tops of these tables, then an auditor is going to ask why you're not washing it?  Also, I think the paper idea invites more questions than solutions as well:  What if it tears?  What about paper waste falling on the floor?  Etc.

 

We currently have a GMP "certification" through a CB, but we're switching over to SQF and will have our first certification audit around this time next year.

 

We don't dump out the food items onto the tables; usually the case will be taken directly off the pallet and placed open on the table. So there isn't usually direct contact unless there's a spill. And no wet cleaning here. Just easy breezy dusting and cleaning with lysol wipes (or whatever the generic name is for those). And goo-gone at the end of the season to remove those glue dots, haha.

 

The contact paper/vinyl I'm thinking of is more like that removeable peel-and-stick wallpaper. The stuff that has the plastic-y feel to it. Although I get what you mean, too. Maybe I can set up an experiment table for our tiny off-season production and see how it goes...

[Lynx42]

SQF may have more of a problem that they are wood tables in general, but that may depend on the auditor.

 

We are audited under Module 12 and during our gap audit it was "recommended" that we not use our wooden cleaning stations (pallet with a backdrop for a garbage can, brooms, and our spill kits that we could move to where ever the spill was).  They are nicely painted and on the cleaning schedule, but she never indicated whether it was her preference not to have wood equipment, or if it was legit SQF reasons. She did not mention the cleaning stations on the audit results, but she did mentioned "wood" in a handful of other places and we got a minor because our customer was sending us stuff on broken pallets (product that is full pallets in, full pallets out).  She didn't like our corn brooms either until I told her we were phasing them out and they would be for outdoor use only.  

 

For the record, our GMP auditor likes the cleaning stations and usually comments on how clean they are.

[cookinmaple]

11.7.3.6 Wooden pallets and other wooden utensils used in food processing and handling areas shall be dedicated for that purpose, clean, and maintained in good order. Their condition shall be subject to regular inspection.

 

 

Wood isn't the first choice but since you already have them I would say, making them cleanable with a cover and have them on the daily sanitation & monthly inspection list would cover everything required. 

[G M]

One of our distribution centers uses some wooden bins when they do secondary manufacturing processes similar to what you're describing.  The edges and surfaces are guarded or treated to leave smooth surfaces for packages and peoples hands to contact, but the back is just painted plywood.  Any kind of damaged or open packages are disposed of as inedible.

 

A smooth vinyl laminate layer on the surface should work fine for your tables.  You could even consider resurfacing them with some of the material used for treating concrete floors and it should stand up to a lot of punishment -- reapply and buff it smooth periodically.

 

The rules around wood and permeable construction materials are for environments where food is handled in "permeable" states.  If it stays inside hermetically sealed primary packaging, then a basic risk assessment should be able to get you out of worries around repacking into various secondary packaging formats.

[ChristinaK]

A smooth vinyl laminate layer on the surface should work fine for your tables.  You could even consider resurfacing them with some of the material used for treating concrete floors and it should stand up to a lot of punishment -- reapply and buff it smooth periodically.

 

It's funny that you mentioned it, because I did look into the possibility of using a porch and floor enamel latex-based paint to cover the tops, as well. I added it to the list of options I'll present. I figured if it's good enough to holdup to foot traffic or the outdoors, it should be tough enough for some assembly tables, right? 

[Hoosiersmoker]

It's funny that you mentioned it, because I did look into the possibility of using a porch and floor enamel latex-based paint to cover the tops, as well. I added it to the list of options I'll present. I figured if it's good enough to holdup to foot traffic or the outdoors, it should be tough enough for some assembly tables, right? 

 

I would be careful with paints. Unless you get nearly perfect adhesion, which isn't likely for an already used surface, you run the risk of chipping paint which creates another risk of contamination. I think you're on the right track with some sort of removeable / replaceable cover. But it might be worth checking into some type of thin (1/4" or 1/8") plastic sheet like a LDPE sheet. You could probably find 1/8" X 4' X 8' sheets for around $50 each. They would probably last for 20 years or so and they'd wear really well. Not sure how big your tables are? Or use a combination of both? Depending on the use of the table, use the plastic sheets on the heavier use tables and a film type on lighter use tables. Or you could do 25 or so tables a year or a few at a time until they're all covered. Thin film / contact paper seems like a lot of maintenance and replacing.