10 replies to this topic

[Baileym14]

Does anyone have any input on clause 11.3.2 of the sqf code. (listed below) 

This clause is very vague in the sense of dropped product and we are looking for more clarification on this requirement. The situation is if a packaged product were to fall on the floor, and an employee were to pick it up without touching the floor, do they need to change their gloves. And or if they were to use a designated tool to pick a package off the floor, would they need to change their gloves / wash their hands every time they picked something up? 

We also considered a risk assessment for something like this, but were advised against it. Can anyone explain why we could not use a risk assessment to change this when dealing with low risk dropped packaged product? 

 

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

i. On entering food handling or processing areas;

ii. After each visit to a toilet;

iii. After using a handkerchief;

iv. After smoking, eating, or drinking; and After sneezing or coughing.

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

 

Thank you 

[qa_maddy]

Everywhere I've worked the floor is simply a "no-go" zone. Once something hits the floor - it's trashed. Or it's something that can get cleaned.

 

If you have to pick something up from the floor then gloves need to be changed at a minimum, even if they didn't touch the floor. They touched the item that touched the floor. You still have a cross contact point. 

[Setanta]

Everywhere I've worked the floor is simply a "no-go" zone. Once something hits the floor - it's trashed. Or it's something that can get cleaned.

 

If you have to pick something up from the floor then gloves need to be changed at a minimum, even if they didn't touch the floor. They touched the item that touched the floor. You still have a cross contact point. 

 

 

AGREE! How do you demonstrate that has been cleaned enough? There is no proceudre for that, no washing length, scrubbing recommendation.

On the floor, it is trash.

[Baileym14]

What are your thoughts on a designated tool like a dustpan with a handle. would gloves need to be changed after handing a clean designated tool to remove the item from the floor? 

[Setanta]

What are your thoughts on a designated tool like a dustpan with a handle. would gloves need to be changed after handing a clean designated tool to remove the item from the floor? 

 

 

Yes, IMO. How is the handle of an item used fro trash. filth, dirt supposed to stay clean? People shouldn't be sweeping and not changing gloves.

Edited by Setanta, 16 April 2026 - 09:32 PM.

[liberator]

I'm always concerned where gloves are a requirement for food/product handling as it appears to create a false sense of cleanliness. Operators tend to think because they are wearing gloves, they are clean, and don't consider washing or replacing the gloves after the usual requirements for washing hands.

 

A strong hand cleaning and hygiene program which is well enforced to me, is much better than the requirement of wearing gloves to prevent contamination. You see this in a sandwich shop, they put on their gloves, make your sandwich take you money then make the next sandwich. Thank heavens for cashless transactions. But then the operators go to the toilet and scroll on their phone...gross.

[SQFconsultant]

you won't be able to risk assess this one away.

 

Package falls on floor, operator picks up the package from the floor - changes their gloves.

 

Package falls on floor, operator grabs a pick  up stick by the handle and picks up the package off the floor - there is no control on whether that handle is clean or not, therefore glove change is needed as well.

[GMO]

There are some industries and products where if they fell on the floor, when fully wrapped, I wouldn't have any significant concerns about someone picking it up. But it needs to be controlled.

 

So I'd put together a risk assessment for the process (but not to take away hand washing requirements) and an SOP, something like:

• What can be picked up, i.e. only fully wrapped so you may specify certain zones or areas where this does not happen.
• How to deal with the product, i.e. look for damage, what damage to look for, if damaged, discard. Wipe pack with antibacterial wipes (if not robust enough for this I'd probably discard anyway).
• Immediately remove any gloves and wash hands before replacing gloves if applicable. If in a low risk area and reusable gloves are worn, the instruction should be to remove these before the operation.

I would never advocate picking up unwrapped products irrespective of what it is or how much risk it presents. If you ever want to while away some time, look at the under cover filming which has happened in the UK particularly in poultry factories. Here is an example: Undercover inside the chicken factory – video | Food safety | The Guardian

[kfromNE]

If a fully sealed package falls on the floor - we sanitize the package. Then the person washes their hands/changes gloves.

 

I'd be asking why are the packages always falling on the floor that this came up in the first place. 

[qa_maddy]

What are your thoughts on a designated tool like a dustpan with a handle. would gloves need to be changed after handing a clean designated tool to remove the item from the floor? 

 

This still requires a glove change and/or hand wash - All our GMP's state if you handle something that isn't food or direct food contact packaging (cleaning utensils, trash cans, your PPE, doors, etc. etc.)  you're at a minimum changing gloves if not changing gloves and washing your hands. 

Hand hygiene is very important. It is one of our most direct sources of contamination control. 

[Scampi]

You have to assume everything that is NOT the food is dirty, period

 

You also cannot "risk assess" a code clause away.  Wash your hands