8 replies to this topic

[coffeeQA]

We have 5 dock doors that are connected to a loading dock. All storage and material handling/processing is done in separate rooms within the same building. 

 

Last year's audit we had a non-conformance for "11.1.5.2 - External doors, including overhead dock doors in food handling areas used for product, pedestrian, or truck access, shall be designed and maintained to prevent pest ingress by at least one or a combination of the following methods: i. A self-closing device; ii. An effective air curtain; iii. A pest-proof screen; iv. A pest-proof annex;

and v. Adequate sealing around trucks in docking areas." -- this was because we have box trucks pull up and there isn't a full seal around the truck. As a corrective action we added an air curtain, which was costly. However, I'd now argue that the loading dock is not a "food handling area". Additionally, we've had no pest issues on or near the loading dock. 

 

We want to add a trash compactor to one of the dock doors. This requires a door to be open for a short period of time while an employee puts the trash in the compactor and come back inside to shut the door, roughly 2 minutes tops. We've added additional pest control traps on both the inside and outside of the building and wrote a risk assessment. I'd assume this would fall under 11.4.1.1 - "...ii. All doors are to be kept closed. Doors shall not be open for extended periods when access is required for waste removal or receiving of product/ingredient/packaging;" 

 

My question here -- 

1. is there any timeline to "extended period"? I'd say < 2 min to throw out trash is not extended. 

2. does the logic of a risk assessment and additional pest control work, or would we need to add another air curtain (or other options listed in 11.1.5.2) 

3. There is a definitely possibility of material being unloaded or loaded at the same time as the door being open and trash going out. All incoming material is wrapped in 3 different layers - never opened. Any concern we'd need to address there? 

 

Thanks for taking the time to read, appreciate any advice! 

[TimG]

1. is there any timeline to "extended period"? I'd say < 2 min to throw out trash is not extended. 
   • ​ If unattended rodent/if attended birds/flying pests could get in in that time. Whether or not an auditor would consider this 'extended' could come down to a few factors (they might check your PCO's catch log or they might just say 'I feel it's extended'). Any work that regularly gets done with an open door is pushing it. That's not even touching on the risk the door would be left open and unattended during trash gathering from time to time. One of those times being when your auditor is there.​
2. does the logic of a risk assessment and additional pest control work, or would we need to add another air curtain (or other options listed in 11.1.5.2)
   • The logic is not bad, but you still have bird/flying pest entrance as an issue. Salmonella poops on product is a risk here, along with a bird dying somewhere.
3. There is a definitely possibility of material being unloaded or loaded at the same time as the door being open and trash going out. All incoming material is wrapped in 3 different layers - never opened. Any concern we'd need to address there?
   • Trying to wrap my head around this one. How do you load trucks while they are taking garbage out to the compactor?

They had a similar issue here and had to install a cutout in the wall with a chute that goes right down into the compactor. That chute has a lockable door that is supposed to remain closed unless ACTIVELY throwing trash down the chute. I absolutely would (and should) get a point on an audit if that door was open and someone wasn't actively throwing out trash, even if it only opens into a chute into the trash compactor. I also on occasion find the chute left open while workers are rounding up the rest of the trash and have to page them to come close it (oh, sorry, we got a new guy, and no one told him!).

[LostInTheWoods]

 

They had a similar issue here and had to install a cutout in the wall with a chute that goes right down into the compactor. That chute has a lockable door that is supposed to remain closed unless ACTIVELY throwing trash down the chute. I absolutely would (and should) get a point on an audit if that door was open and someone wasn't actively throwing out trash, even if it only opens into a chute into the trash compactor. I also on occasion find the chute left open while workers are rounding up the rest of the trash and have to page them to come close it (oh, sorry, we got a new guy, and no one told him!).

 

Alarm it! As loud and annoying as possible

[GMO]

Alarm it! As loud and annoying as possible

 

I guarantee that the operators will find a way to isolate that alarm within days.

 

 

 

Additionally, we've had no pest issues on or near the loading dock. 

 

We want to add a trash compactor to one of the dock doors. This requires a door to be open for a short period of time while an employee puts the trash in the compactor and come back inside to shut the door, roughly 2 minutes tops. 

 

No pest issues does not equal no risk. Or might equal you have really bad pest inspection.

 

A compactor on the door is an increased pest risk depending on what kind of trash. Most people do not have it directly on a door but have trash moving outside to the compactors containers cleaned and then returned with the large bins moving out and back in via a rapid rise door.

 

It will depend what kind of compactor you're talking about as to what the risk is and how the door opening is controlled. If it can be locked off and left open for long periods, call be cynical but you can bet it will be...

[jfrey123]

1. is there any timeline to "extended period"? I'd say < 2 min to throw out trash is not extended.

How do you guarantee the <2 minutes is upheld?  What control is in place to prevent that door being left open for 3 minutes? (before you nitpick, keep in mind you're the one who put 2 minutes on it, so now it's up to you to uphold that control).

 

2. does the logic of a risk assessment and additional pest control work, or would we need to add another air curtain (or other options listed in 11.1.5.2) 

I've defended SQF facilities who have to open dock doors to the outside, specifically to forklift material from one separate warehouse to another.  The control was an air curtain, and the monitoring was achieved by adding additional ILT's with increase checks combined with the monthly trending.  We could consistently prove the practice was not increasing the frequency of insects near the door, showing the risk of constant opening/closing was negligible.  It's not ideal and you're going to get auditors always pushing back against it, so you better have your ducks in a row.

 

3. There is a definitely possibility of material being unloaded or loaded at the same time as the door being open and trash going out. All incoming material is wrapped in 3 different layers - never opened. Any concern we'd need to address there?

Not ideal.  A trash door should remain a trash door, go find another way to bring material in and out.  If you do have to use the same door for trash and product, make daaaaaaaaaaaaang sure you've got some solid written procedures to keep it clean and ensure employees are following the SOP.

[MDaleDDF]

Honestly sometimes when code is vague, I'm vague as well.   Just write up your training sheets for the folks that do the job 'do not leave doors open for an extended periods of time'.   If they don't define what that is, why should we?  If an auditor asks 'what's an extended period of time', I'd say you tell me....it's not defined in the code...   just make sure the employees are serious about that and keep the doors closed as much as possible.   Move everything out at once, shut door and do what you need to do, then reopen door and enter, etc.

 

We have just good old fashioned curtains over our shipping dock doors, no complaints ever from inspectors.   But there's one of those hydraulic  ramp things, so basically our fork truck goes through the curtains, and they close behind him before he even enters the truck.    On one of our docks we just acquired the big padding seal thing that sucks right up to the trucks, that thing is awesome and creates quite a seal.

 

I would definitely chute to your trash like others have said.   We have that here and I honestly can't imagine if we didn't, how we would deal with it.  It makes life way easier, and it isn't hugely expensive to put together.   

Edited by MDaleDDF, 31 March 2026 - 12:21 PM.

[Jersey Cows]

The code really is quite vague. The FDA food code states "If no people or product are actively moving through the door, it should be closed" There is no specified time limit, but it does say once material movement has ceased doors must be closed. Here is a something found that may be helpful in a Shipping/Receiving SOP to help support the requirements of the N.C.  “Dock doors shall remain closed at all times except during active loading or unloading. Doors must be closed immediately once movement of materials has ceased. Any door left open without active use is considered non‑compliant.”

[GMO]

I agree with the above post and I don't think that's all that vague. Not chucking stuff into the compactor? Door is shut.

 

I think the problem here isn't defining how long is too long, it's the inevitable fact that when something is a manual control, which I suspect this will be, it will be left open longer than how ever long you think "reasonable" is. Why? Because it will make the team's life easier.

 

So to my mind, this is where I'd be pushing it up the hierarchy of control. You will not persuade people into closing the door more often and there will be a "oh it will be alright" attitude about it all. 

 

Different options, I think all suggested already. I'd just risk assess them and decide what you think is best.

• Put your compactor outside and manually take out large bins via a rapid roller door. This is the solution most people I've visited use.
• A waste chute with automatic hatch which closes behind waste (albeit that chute will need cleaning to prevent pest issues too). I've seen one in use in one factory. It was well maintained so worked ok. Better for dry waste.
• Put a rapid roller door in front of the dock you're using, although, honestly? I think there are two problems with this. Firstly the H&S risk when the door comes down as people will be operating under it a lot and secondly (possibly because of that) there's always a way of locking them off and open.
• Use a manual door to your waste compactor but this will be open pretty much all the time in my view and the pest risk will be large.

[Lynx42]

We don't have a time but distance. If they need to go past a certain area the door needs to be closed.  

They gather everything near the door, open it to walk back and forth for multiple trips, but if they go past the first seam in the floor or in front of the next dock door, they need to close the door.  They close it as they enter after dumping the last bag.

We got a finding not because the door was open for several minutes, but the auditor saw our sanitation guy walk 3 doors down to get another trash can leaving it open.  He had all the other bags and cans gathered except that one because he felt it was close enough not to matter. We also ask them not to open the door all the way, but to pull it down so it's no more than a foot over their heads, they are hit and miss on that one depending on who is dumping and if it's a quick toss of one bag.