8 replies to this topic

[RobTO]

I am trying to communicate the high risk changing area requirements to the operations team at a company I have just started working at. We are high risk ready to eat and currently have no boot control aside from a boot washer (I know). 

 

If someone could provide photos of their changing areas with the barrier that would really help me explain my case. 

 

Also, has anyone had push back from Health & safety regarding the step over barrier due to emergency exiting and the risk of employees falling over then bench? If so, how did you tackle this? 

 

Thanks in advance!

[AltonBrownFanClub]

I did a google search for "Step over barrier cleanroom" and found lots of videos and products.

Here's one:

 

You can pause the video when it is in view and take a screenshot.

On my computer pressing Shift+Windows Key+S brings up the screenshot menu

[G M]

I've had H&S say no to rubber doormat style boot washes that had a tall colored bumper rim, which allowed it to hold more sanitizer, because the bumper was about 3x as tall as the bristles and people needed to step over the hard rubber bumper.  It was deemed a trip hazard. Instead we use some 'low profile' mats that have to be refilled more often, and aren't colored, but you can just step on it anywhere.
 
These are only used in a couple of transition locations that are relatively low traffic, and I have better things to spend my effort on.

[chrisrushworth]

We use foot bath, step through mats & a manual boot wash at the end,

We are RTE High care deserts (cream/cheese based).

 

I would create a risk assessment to determine the risks.

Then look back at micro OOS's/ complaints and see if there is a trend.

 

Listeria is always present in food processing due to the amount of water/drain use... BUT what controls can be added/ increase monitoring,

Until you find it in finished products managements will not make changes is what i have discovered, but what can speak cant lie. 

Use you results to push them through.

Have you had any feedback from FSA last visit?

 

Regard to H&S.... if you staff have mobility issues, separate risk assessments can be performed, BUT again you should have more than one emergency exit route (fire doors) so these can be utilised as sending ALL staff through a barrier/step over is also a risk......

 

 

Im unable to share video/pictures, but as someone else said have a look on youtube for examples.

[Tony-C]

Hi RobTO,

 

Bench barriers and dedicated high risk footwear are generally the accepted standard. Boot washing of footwear that is worn elsewhere on site requires stringent controls and validation, see more information below.

 

I'll have a look and see if I can find some photos on my back up hard drive. The video posted by AltonBrownFanClub gives you some idea but it is not normal to step over the bench, people sit on it and swing their legs over. Also I didn’t notice any hand washing in there - see applying clothing in a given order below.

 

This falls under BRCGS Section 8.4 Staff facilities for high-risk and high-care zones:

 

8.4.1 Where an operation includes a high-risk or high-care area, personnel shall enter via a specially designated changing facility at the entrance to the area. The changing facilities shall incorporate the following:

- dedicated site footwear that is provided by the site and which shall not be worn outside the factory

- an effective control of footwear to prevent the introduction of pathogens into the area. Control may be by segregation and a controlled change of footwear before entering the area (such as a barrier or bench system), or by the use of controlled and managed boot- wash facilities where these demonstrably provide an effective control of footwear to prevent the introduction of pathogens into the area.

A programme of environmental monitoring shall be used to assess the effectiveness of footwear controls.

 

Further from BRCGS Guidance:

 

In facilities with high-risk or high-care areas, personnel must enter these areas via a specific, designated changing facility (i.e. separate from other, lower-risk changing areas) and must follow documented instructions to:

- apply specific dedicated protective clothing which is visually distinct (e.g. a different colour or style), including clean overalls, headwear and footwear

- apply clothing in a given order; for example:

• put on hair covering

• remove shoes

• step over barrier (see below)

• put on dedicated footwear

• wash hands

• put on coat or overalls

• wash and sanitise hands

- wash hands during the changing procedure.

The footwear worn in these areas must be dedicated to the factory (i.e. factory-issued and not worn outside the factory) and captive to the area (i.e. worn only in the high-risk area). The changing area must be laid out with an effective system to differentiate areas for wearing high-risk footwear (e.g. by the use of a barrier or bench system).

By exception, boot-wash facilities may be used instead of changing into captive footwear dedicated to the area; these must be located at the entrance to an area. Boot-wash facilities must be effectively controlled, managed and validated to prevent the introduction of pathogens. The site must have undertaken a risk assessment to identify the suitability of the boot-wash facilities, and have established controls to manage the effective sanitation of footwear. The controls must have been validated by microbiological swabbing of footwear, floors and drains in the high-risk or high-care area to demonstrate the absence of pathogens (e.g. Listeria species).

 

Kind regards,

 

Tony

[Sjoynesfoodsafety]

Re: captive boot program. Do you have the space/staff to store and clean the boots? 

I would suggest that you contact CFS https://www.commerci...sanitation.com/ for assistance. 

 

Re: Health and safety

 

In my past plants we has multiple trips and falls due to the boot wash, foot baths and others. Most of the cases landed with in the needed hand rails or training to use the door jam as a such. At one point we assets that multiple people were wearing larger then normal boots that caused them to not be able to clear the step. In that case we had to replace there boots.

[GMO]

I agree with a lot of the above.  A bench is, to my mind, essential to segregate RTE high risk areas from other areas.  I have put them into a plant in the past.  There were objections but the Listeria outbreak we had did prove my point.

 

Make sure the bench is stable and sealed to the floor.  It's pointless if it's not as otherwise when the floor is cleaned you will get transfer.

 

The point of the bench is as part of your barrier segregation.  This is to stop pathogenic bacteria, particularly Listeria, entering your plant.  Tony has given the very good summary from BRCGS on the requirements.  If you have BRCGS I can't see how you can't comply with these?  And if you're not detecting Listeria and don't have this level of control I'd doubt the efficacy of your swabbing to be honest.  And I wouldn't go with the "by exception" boot wash suggestion. That has all the hallmarks of "we will take this out in v10" in my opinion and as well they should.  It's not, in my view, food safe.

 

A few other tips I'd share though:

• Everything must be captive as much as possible.  Don't put in a great system for boots to find your engineers are routinely wheeling in tool boxes.
• Boot washes or troughs are not necessary and there are alternatives.  So for example you can have a "welly fairy" (yes we really call them that) who clean the boots manually on the stands overnight or on other shifts.  You could use clogs which are water proof and do machine cleaning every day.  
• IF you use a bootwash in combination with your bench on the high risk side, only use it on the way out.  That then limits the amount of water (keeping the EHS colleagues happy) but that also reduces your Listeria risk.  BUT they are notorious for being a Listeria sink if they're not looked after well.  Troughs I've not used for about 20 years.  They become a soup.  I'd advise removal for anyone still using them.
• If you must use a bootwash, beware they spew out loads of aerosols.  Only use without coats on unless the coats are going straight to wash.
• When you get all your controls in, train train train people.  They need to understand the why.

[Kara S.]

Adding onto what GMO said... my company adds these in all the time but a lot of the time, its not functioning as intended. 

 

To GMO's point, you can put in this feature and still not have the control you want if you (1) only focus on foot traffic and not wheel traffic and (2) you don't consider all entry points into high care. If your high care room has doors connecting to other rooms that are not also high care or not egress only, then you didnt fully control floor conditions. Forklifts and carts will bring in the germs from other areas you are trying to keep out. Same is true for the employees now in captive shoes utilizing the uncontrolled doors. 

 

If you want hygienic zoning then you have to go all in or else its a waste of money for only half doing it. It's a common conversation I have with clients during design meetings even with brand new buildings. And a lot of the time they choose to still have the sanitary vestibule (what we call it) and the other doors without  floor foamers or reusable tac-mat flooring to control traffic patterns. 

 

I obviously don't know what your plant layout is but just keep that in mind when trying to justify this change. you have to go all in knowing all the facts, costs, and "probable costs"/ cost of not making the change. Just listing off the food safety implications isnt enough unfortunately. 

[GMO]

Kara is spot on.

 

I once went to a site where they had "high care" of sorts and the product certainly warranted it but they still had ingress into the area with pump trucks.  I got rid of that process and improved things to the point of where we were nearly compliant but that's when we ended up with a major issue with Listeria.  It felt like such an irony when so much had improved.  But the important thing it was only luck that had kept us ok before and that last 10% was absolutely still worth doing.