11 replies to this topic

[TAW]

We have a situation here at our company where we make a liquid sugar based product.  Our facility is quite small and old.  As such in our manufacturing area, we have liquid sugar getting on the floor that needs to be rinsed down constantly to prevent slips and falls and also to keep it from caking up and such.

 

In the SQF code it specifically states the following:

 

Handwashing

All personnel shall have clean hands, and hands shall be washed by all staff, contractors, and visitors:

1. On entering food handling or processing areas;

2. After each visit to a toilet;

3. After using a handkerchief;

4. After smoking, eating, or drinking; and

5. After handling wash down hoses, cleaning materials, dropped product, or contaminated material

 

I was observing the manufacturing area and the hose was used approximately 5 times within a 10 minute period.  The hose hangs on the wall  about 5 feet off the ground and stretches approximately 10-15 feet and the handle never touches the floor.  The employees know not to not touch any part of the hose other than the spray handle. They always wear gloves while doing this task. Do they have to wash their hands every single time they use it?  The manufacturing supervisor and the operations manager said that it will cause the use of gloves to go up massively (which I totally agree), and employees will be washing their hands 3-10x times a day more than they already do eating into production.

 

We are a low risk facility and we even had the FDA show up unannounced about 6 weeks ago and they said nothing about it.  

 

Can I present a risk analysis for SQF that shows we have done our due diligence and that we do not incur any significant risk with our current protocol of only washing hands if the hose handle gets dropped on the floor?  While working on a better solution, of course.

 

 

 

 

[Scampi]

The answer is YES they do

 

You can try a risk assessment, but you better be washing the wash down hose on the daily or it won't hold water (pardon the pun)

[SQFconsultant]

Sounds reasonable, however - unless  you or someone else is willing to monitor this every single time it's a no go.

[TimG]

OK, well I will chime in after all because this isn't going to be popular. The code is pretty black and white on it, however..

There are instances where it is absolutely not feasible to wash hands after a worker grabs a hose and squirts the line down. In sugar/syrup/honey this has been the case since I've first got into food safety. Currently, running honey on 3 lines, each line needs to rinse warm water several times an hour. Near the filler and capper areas, that could be every 5-10 minutes. I'm not having someone wash their hands every 5-10 damn minutes. 

Now, I'm sure someone will argue 'oh, well get a x that auto squirts the line, or do get a robot dog that comes around and lifts their leg to pee clean water on the line'. 

What's the risk though? The hoses are rolled up on the wall, the water is CONSTANTLY running (we wash down CONSTANTLY, honey is sticky) and part of my GMP inspections are to make sure no hoses are touching the ground and they are clean and in tact.

[TAW]

So, we should be going through multiple boxes of gloves a day for people having to constantly wash their hands?  I am asking from a pragmatic, realistic standpoint.  We have been through 5 SQF audits since I've been the Food Safety Manager here.  It has never been cited or even mentioned by an auditor.  This isn't a deep washdown end of shift thing, its a 10-15 second usage of the hose to keep the floor free of liquid sugar for mostly safety purposes.  The water from this hose isn't nowhere near enough pressure to bounce off the floor onto food contact surfaces.  Our facility is low risk, we make rock candy from this liquid sugar and the sugar is cooked well beyond pasteurization temperature and time.  The liquid sugar on the floor isn't going into the cooking vessels and the water from this hose isn't used for cooking.  

 

The current rule we have in place is that if the hose spray handle falls onto the floor and you pick it up with your hands, wash the handle and replace your gloves and wash your hands, then resume work.  If for some reason you pick up a portion of the hose off the floor with your hands then you need to clean that part of the hose and then replace gloves and wash your hands.  Just using the hose from the spray handle from off of the holder and putting it back on the holder isn't a triggerable handwashing instance.

 

Make sense?

[GMO]

Can I suggest you think about this differently? Even if you have an old facility, you have a health and safety risk which your team are having to mitigate by use of a hose every 2 minutes.

 

EVERY 2 MINUTES!

 

Is it worth looking at containment for leaks (as a minimum) or stopping the leaks (ideally) as this isn't just about safety (although that should be enough) or food safety (where inspectors aside, I agree other risks are bigger) but imagine the wasted time and wasted product? Then the COD / BOD of your waste water? That's bonkers!

I'm not in the US but if that hose is never going on the floor I'm not especially worried about the hand washing every 2 minutes. The bigger risk will be the inevitable dermatitis they will get if they followed that instruction. However, if it's a realistic non con from a regulator it's a good idea to fix the root cause but I think there are a multitude of other reasons to fix that root cause anyway.

[Jimimacintire]

Can I suggest you think about this differently? Even if you have an old facility, you have a health and safety risk which your team are having to mitigate by use of a hose every 2 minutes.

 

EVERY 2 MINUTES!

 

Is it worth looking at containment for leaks (as a minimum) or stopping the leaks (ideally) as this isn't just about safety (although that should be enough) or food safety (where inspectors aside, I agree other risks are bigger) but imagine the wasted time and wasted product? Then the COD / BOD of your waste water? That's bonkers!

I'm not in the US but if that hose is never going on the floor I'm not especially worried about the hand washing every 2 minutes. The bigger risk will be the inevitable dermatitis they will get if they followed that instruction. However, if it's a realistic non con from a regulator it's a good idea to fix the root cause but I think there are a multitude of other reasons to fix that root cause anyway.

 

That was my thought as well, make so you don't have to wash the floor that often. Grates to walk on that would let syrup flow through if you can't stop it another way.

[MDaleDDF]

5 SQF audits and they never mentioned it.    FDA visits, they never mentioned it.

Why worry about it?   That's just me, and may be an unpopular opinion.   I wouldn't change a day-um thing....  Just understand at some point they may indeed mention it, and give you a minor NC.   I don't mind a minor NC, because they're going to find a NC anyway....    

If you feel it's truly sanitary as is, keep it as is.   If you want to, do a risk analysis to find out if it's truly a risk or not.   If it is, then worry about how to fix the issue.  If it's not:  stay golden Pony-Boy....

Edited by MDaleDDF, 24 March 2026 - 04:31 PM.

[SQFconsultant]

I like TimG's idea about the robot dog LOL

 

I've got a greenhouse consultant telling me that we should install an AI robot in the containment growth trailer that pulls the grow racks after picking is done and washes then dries them. He joked that her name is Bernadette to which I asked if she had blond hair.

 

Come ot think of it, when I was traveling around the US doing 3rd party audits I had a garmin GPS on the dashboard and her name was Bernadette - no blond hair though - that would have freaked out my wife.

 

I like MDaleDFF comment - that makes most sense to me.

Edited by SQFconsultant, 24 March 2026 - 04:35 PM.

[TimG]

I'm with MDale. If you are confident there is no risk to your product or customers, stay golden Pony-Boy.

[TAW]

Thanks for all the feedback.  I would absolutely love it if we had a grated floor or a floor that wasn't so slippery to prevent this from being an issue at all but our owner is one of the cheapest owners I have ever met.  I mentioned it to the safety manager (who is also our HR manager, like I said cheap), and she said that having a better floor would prevent this from being an issue for both of us but that the owner says that its no where near a priority to fix even bigger safety issues we have in the facility as a whole.

[G M]

Install a sink or separate hose that cannot touch the floor, and use that for intermittent cleaning.  We have a set of these 3' long hoses that are physically incapable of touching the floor, and team members use them to remove product residue from their PPE.

 

To put a bow on it, make the special clean different colored hose, or sink, part of your environmental monitoring program as a zone 1 site.