Warehouse Wall Clearance Debate

Hello,

I've always been preached to have an 18" clearance between walls and pallets/rows/equipment/racks/etc for pest control service and maintenance. I'm at a new company that put in racking anywhere from 2-8" from the wall.

Does anyone have GFSI, SQF, FDA, or USDA guidance that is specific to this? Know where the 18" clearance came from? I'm going to need support to ask this small company to move all of their racking... especially since it will require retrofitting the racking...

Thanks!

I recently found out the 18" rule is implemented by our Pest Control company, not our food safety program. We were unable to maintain the 18" in some areas of our distribution center, so we worked with the pest control guys and painted sections that weren't 18" white so he could see bugs easier, along with keeping spots empty on the floor every couple of locations so he could squeeze in and look left/right against the wall.

Hello,

 

I've always been preached to have an 18" clearance between walls and pallets/rows/equipment/racks/etc for pest control service and maintenance. I'm at a new company that put in racking anywhere from 2-8" from the wall.

 

Does anyone have GFSI, SQF, FDA, or USDA guidance that is specific to this? Know where the 18" clearance came from? I'm going to need support to ask this small company to move all of their racking... especially since it will require retrofitting the racking...

 

Thanks!

Dear jswenpdx,

There is a lengthy discussion (prob. within 2013-4) on an almost, I think, identical query elsewhere on this forum. This included  references/attachments to a (few) specific suggestions.

Maybe try searching a little unless someone can find it.?

Rgds / Charles.C

I looked for a previous topic but haven't found it... maybe I'm using the wrong search terms... would appreciate if anyone can point me in the right direction!

Thanks, I see that post including the AIB standard.

But... does anyone know about GFSI-land or Regulatory-land? Seems like they aren't specifying the clearance of the perimeter.

http://www.ifsqn.com...in-a-warehouse/ This doesn't seem too extensive, but it came up quickly

Dear Setanta,

Thks for effort but there should be at least 1 more which contained some "published" data.

Rgds / Charles.C

PS -added

Was probably thinking of this more recent thread -

http://www.ifsqn.com...gap/#entry65563

But the result appears to be maybe "Niet"

Thanks, I see that post including the AIB standard.

 

But... does anyone know about GFSI-land or Regulatory-land? Seems like they aren't specifying the clearance of the perimeter.

I've always assumed it was GMP rather than regulatory?

 IMEX quite a few of the larger food companies make it a requirement for their supply chain eg Campbells  & Kelloggs

Maybe if you did want your company to implement it- that might be a usefull angle to approach it from (£££££££!!!)

Mike

Iv'e been through countless audits both regulatory (USDC and FDA), GMP/GFSI 3rd party, and retail (EverClean, State Health) and it's never been a non-conforming issue. Just keep a readily  "respectable distance" for ease of inspection and cleaning and you'll be fine. 

Rigid policy or not, most auditors are very lenient in this "mystery wall gap standard" unless it's fixed equipment/machinery or cold storage procedures.  Even then it's simple enough to talk down the "code" with PRP monitoring schedules.

I had a similar issue before our last audit from AIB when my boss asked if he could have maintenance put a new set of racks against a wall in the warehouse due to lack of space. First, there is no inherent risk associated with not having an 18" white strip as long as you have it addressed in your MCS or master cleaning schedule. That is, a new SOP for cleaning and inspecting may need to be developed depending on what is stored on the racks (potential to attract pests and or allergens). Just go ahead and remove the old white line and bolt down the feet. Then, caulk around the feet to prevent pest harborage. So, to make a long story longer, I okayed the racks being next to the wall and not a word was mentioned during the audit. I think the 18" rule should still apply to the ceiling and at least 6" off the floor for food safety concerns. I hope this helps.

Taste Maker

Memphis, TN

I had a similar issue before our last audit from AIB when my boss asked if he could have maintenance put a new set of racks against a wall in the warehouse due to lack of space. First, there is no inherent risk associated with not having an 18" white strip as long as you have it addressed in your MCS or master cleaning schedule. That is, a new SOP for cleaning and inspecting may need to be developed depending on what is stored on the racks (potential to attract pests and or allergens). Just go ahead and remove the old white line and bolt down the feet. Then, caulk around the feet to prevent pest harborage. So, to make a long story longer, I okayed the racks being next to the wall and not a word was mentioned during the audit. I think the 18" rule should still apply to the ceiling and at least 6" off the floor for food safety concerns. I hope this helps.

 

Taste Maker

Memphis, TN

I'll agree with others in that there is no GFSI recognized standard that lists a specific perimeter length, but the inherent risk is that a rat or mouse will feel whatever is stored there and run over to it instead of along the wall.  Rats feel with their adorable lil whiskers, so if *stuff* is in their pathway, they crawl over to it and hide rather than scurrying along the wall and running into a trap.  You don't need 18 inches for that - but you might need 18 inches to access the traps - unless you want to put a weight limit on people who can  check them.  Maybe people can safely and comfortably walk the perimeter with less than 18, but if you're larger it becomes an issue. 

Space is an issue in my factory as well.  For the walls which are "shared"/internal within the company we don't require it because we are controlling all of the walls around it.  In areas where we can not get 18 in we put a piece of the racking across the bottom to stop pallets from going in and it's cheaper than angle iron. 

Here's some references but none actually state 18" but that is industry standard to have that clearance. 11.6.1.1ii, 11.6.2.2, 11.6.3.1

In the Guidance it mentions:

The tops of refrigerated rooms are to be covered with a rodent-proof material. Inaccessible cavities need to be sealed to prevent the access of rodents or other pests. Storage racks and shelving need to be constructed of a non-corrosive material and easily cleanable. The product on these racks or shelves should be at least 30 cm (twelve inches) from walls and 150 mm (6 inches) off the floor to prevent contamination and allow for adequate air circulation around the product (refer 11.2.3).

The racks provided for the storage of packaging shall be constructed of impervious materials and designed to be easy to clean. The supplier must limit the use of wooden racks for storage of packaging and packing materials to dry areas only. Stands and the lower shelves of stands should be at least 150 mm (6 inches), or as required by applicable regulation above floor level to facilitate proper cleaning.

There is no real standard .A space sufficient for inspection is a normal standard ( and access for pest control traps)

Will you please explain Dr. Vu what should be the standard?

TITLE 21--FOOD AND DRUGS
CHAPTER I--FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF HEALTH AND HUMAN SERVICES
SUBCHAPTER B--FOOD FOR HUMAN

Sec. 117.20 Plant and grounds.

(4) Be constructed in such a manner that floors, walls, and ceilings may be adequately cleaned and kept clean and kept in good repair;

Sec. 117.35 Sanitary operations.

© Pest control. Pests must not be allowed in any area of a food plant. Guard, guide, or pest-detecting dogs may be allowed in some areas of a plant if the presence of the dogs is unlikely to result in contamination of food, food-contact surfaces, or food-packaging materials. Effective measures must be taken to exclude pests from the manufacturing, processing, packing, and holding areas and to protect against the contamination of food on the premises by pests. The use of pesticides to control pests in the plant is permitted only under precautions and restrictions that will protect against the contamination of food, food-contact surfaces, and food-packaging materials.

Would PROBABLY be what your FDA inspector would reference. For pest control you need to be able to walk the walls for inspection (to ensure no pests have exploited a means of ingress). If you can't walk the interior, (some of us fat folks need more then 18 inches) then you can't (unless you can reasonably prove otherwise) adhere to that FDA standard.