Limited equipment spacing around floor drain

Greetings,

 Our organization just installed a new processing line, which the installation was mostly successful. That said, due to space constraints a portion of the supporting equipment (closed piping and vessel) were installed on a somewhat elevated SS platform that sits directly over a couple of feet of a floor trench drain. 

We would rather have placed the equipment elsewhere, but it just wasn't possible.  

A food safety plan has been drafted for the line, but we are debating how best to address the equipment placement within said plan. 

Thanks in advance for feedback.

Hi SMT,

Hopefully you did a risk assessment beforehand and determined that there wasn't any risk of product contamination from the drain. Two areas spring to mind that need to be addressed:

How this equipment and the drain are going to be cleaned.

Including this in your environmental monitoring schedule.

Kind regards,

Tony

Tony,

Thank you for the feedback.

We have assessed the risk, sanitation methods are drafted, and the line has been included in our EMP prior to commissioning the line. 

To be blunt the area just spooks me given drains can pose a problem, that said in the back of my mind I feel like there is something I haven't thought of or that I am missing. Thanks again for your time. 

Kind regards,

St

Perhaps your environmental monitoring could keep tabs on the situation by monitoring the cleanliness of the drain, equipment points of interest close to (above) the drain, and equipment points far from the drain. Using this data you may be able to better understand how the drain's placement is playing into your equipment sanitation. It may tell you that increased cleaning frequency is needed for this line because of the drain placement, or in extreme situations the configuration needs to be changed (either the drain gets moved or the line).

All solid advise above, and if I'm interpreting OP correctly it appears the line/equipment running above is all sealed.  I likely find the risk to product is low given that the product is protected physically from the drain.

Now, if this vessel you describe somehow drains down to that drain for any reason, now you have to consider splash back potential from the floor/drain back up into the valve.  I would also ensure the footings and legs for equipment near the drain are on your EMP monitoring schedule just as a protective step.  Drains are bad and scary, but they're a fact of our industries and can be maintained safely with proper monitoring.

It's difficult to know without seeing the layout but things which can impact the risk when over drains would include (please add people if I've missed anything!)
 

• What your product is.  If it's high Aw and a product which Listeria can grow in and it's post heat processing, this will be a higher risk to your line.
• Inability or not easy access to clean - even if it's accessible but difficult, this will almost certainly mean that drain isn't cleaned from time to time.  That can increase debris accumulation and, hence, growth.
• Clearance from the drain.  Common sense really.  The closer your line equipment is to the drain, the higher the risk.  Also consider which parts of your equipment are (or could become) food contact.  Make sure cleaning utensils particularly are not close to the drain.
• Is the equipment open or sealed near the drain?  Even if not food contact, you don't want a pathogen like Listeria setting up home in your kit.  
• How well are the drains controlled?  Do you have traps in them so air flows can't form aerosols which travel through the system.
• Cleaning methods (I'll share what I consider to be best practice below) but absolutely you do not want to be using hoses to clean that drain.  And you need to train that well out to your teams with an explanation on why.

Best practice (according to me) on drain cleaning:

• Drain cleaning should be a specific activity not just the wash off from floor cleaning.
• Have a dedicated colour for utensils for drain cleaning.  We used to use brown because it was easy to explain that was a colour not to use elsewhere.
• Ensure that disposable over PPE is worn or clothing put to wash afterwards ideally and hands washed.
• Remove grid and put in dedicated trough.
• Use brushes and small hand pans to remove debris from gulley.
• Remove drain basket and bung and put in dedicated trough.
• If rinsing is required, tip from a bucket (not bucket and chuck it!) gently, NO HOSES.
• Scrub using detergent, allow contact time.
• Gentle rinse from bucket.
• Wash grid, bung and basket in trough following the normal 5 stage clean.  Be careful about how you dispose of the water.  Assume it has Listeria in it.  You can get portable plastic colour coded troughs with taps to release the contents.  
• Reassemble the drain bung, basket and grid.
• Disinfect again in situ, consider leaving disinfectant tablets in the drain basket if safe to do so.

All of that would take time.  So the last tip would be make sure that your planners are allowing the time to clean!