How can we address potential non-compliance for infrequent equipment cleaning?

WE have a few areas in the factory processing areas (tortilla lines) that that may run 1-2 days a week. Sanitation, at the end of the last  night of operation, will do a quick rinse off of the equipment, then do a full clean at the end of the week, as we will likely run those lines on Monday. My QA Manager is concerned that an SQF auditor may write this up as a non compliance based on the following element of the code:   SQF:  11.1.7.7 All equipment and utensils shall be cleaned after use (refer to 11.2.5.1) or at a set and validated frequency to control contamination and be stored in a clean and serviceable condition to prevent microbiological or cross-contact allergen contamination.

My  thoughts are, if it is down for the rest of the week, the concern is moot, as it is fully cleaned and sanitized before startup. And the equipment is not being stored for use a a later time. 

Any input will be  appreciated

Welcome to the forum, Chuckzerbe!  :welcome:

I think I would suggest doing a full clean soon after production has finished for the day and if it hasn't run since then, a quick wash/rinse and sanitation at the end of the week. There could be sources of dirt that you aren't considering. Is it near forklift traffic, for instance, or close to outside doors?

That way whatever may be on the equipment doesn't get a chance to set in and possibly be a starting point for bacteria.

I was in Tortilla production for several years, and I had a policy that a line could not be left unclean for more than 24 hours, and this was a with a pre-scrape and sanitation step.  As @Sentata stated there are micro concerns here that you would be allowing to proliferate.  The years I spent were working through challenges like yours, however if you put some validation toward your process you will start to see results that are unfavorable.  You will also be contributing to mold growth with a quick rinse step.  Clean it when it goes down and cover areas after they are clean to prevent further contamination.  

So yes listen to your QA they are on the right track, and not just from a certification standpoint.  

Eh, while not best practice, the temporary water "wash" let's call it could be defended if you do some inhouse validation.  Run some swabs for micro throughout the week after your sanitation hoses everything off to determine if the equipment becomes a breeding ground for micro.  If you do this over some weeks and can demonstrate the step is sufficient to control while waiting for a full wash/sanitizing cycle, then it is defendable.  If you find spiking micro while the equipment has been idled for a few days, then you really don't have a leg to stand on.

Keep in mind SQF allows us to validate our own sanitation practices.  While I or even an auditor might balk at the idea of hosing equipment off and leaving it, so long as there isn't any leftover food residue visible and the swabs don't indicate a micro problem, you can state it's under control.  At my old spice plant, dry cleans were a validated method for us due to the nature of the product, and wet cleans had their own frequency established (all supported by various swab tests we had done).  Here's the kicker:  they'd been doing this long before SQF certification was a thing, and because they were terrified of costs of organic approved detergents, the wet clean process for us was water only wash/scrub, water rinse, and an alcohol-based sanitizer.  Organic inspectors were good with it, first SQF auditor refused to believe water only was sufficient, but we had ATP and equipment swabs to back up that we could effectively clean our equipment this way, so it passed every year.

Well, we have not validated after we do the rinse off, but we do validate, on a monthly basis, with APC swabs, after a full cleaning with detergent and no rinse sanitizer. Our spec for APC is <100 cfu. Historically, 99%+ of these swabs come back <10 cfu. Very rarely will it exceed 100, and I think the max has been 140/150.   This is over a 10+ year period. These swabs are taken post kill step (baking at 650F for 25 seconds and frying at 360F for 1 minute)

Two separate things here, first you can validate your own process and simply tag equipment as "Wash Before Use" to acknowledge its condition. However ...

The second point, I would not introduce water to the food residues and let them serve as a microbial breeding ground for a few days before finishing the cleaning process -- do it the other way around as others have described, clean it completely then do a quick wipe down with some sanitizer a few days later before you use it again.