Costco Foreign Material Control - Towels

Hello everyone! 

It has been quite a few years since I have needed to pose a question. I have been quietly absorbing everyone's expertise for years and you have all been extremely helpful in bolstering my knowledge base.

I am now with a food manufacturer following SQF's standards in the United States and we are exploring the additional Costco requirements. Their expectations regarding foreign material control are clear, except for one snippet. Here's the quoted text :

"Clothes, towels, and other cleaning materials that pose a risk of contamination or adulteration shall not be used to remove dirt and debris from products."

My company does use hand towels! We also have a system in place so the towels are under limited access, are color coded for specific purposes, and are regularly laundered by a third party service. Does anyone have any experience with addressing this specific concern?

I expect that I will need to add more details, but with what I have provided above, I believe my company's practice should be a non-issue. Am I correct?

Thanks for taking the time to read and give input!

Always My First Day

We have a system that treats small hand towels for cleaning like other untethered utensils.  They are regularly accounted for, and checked in/out from the laundry room.  We haven't seen any push back or unusual scrutiny from the auditors.

Auditors will want to see the HACCP flow/safety plan from your laundry service.  How do they guarantee their process eliminates contamination concerns?  Not just how do they clean your soiled rags, but whether their process eliminates allergen, chemical, pathogens, etc.  They'll want to see a policy about how you control the hazards between accepting delivery, storing, using (you mentioned color coded separation, that's good), along with any inspections you perform to ensure the towels aren't fraying or otherwise damaged if you're using them to clean equipment.

And since you specifically mentioned "hand towels", have to ask whether employees are using them to dry their hands after mandatory hand washing?  In SQF that's a specific no-no because the towels can't stay clean/dry between users.  If you just said hand towels to describe them by size/shape, disregard lol.