Hanging tools on hooks NOT Food Contact Surface SQF?

Question:  How can I validate and verify that tools we are hanging on hooks on our walls (which touch the wall and obviously the hook) are "clean" and meet the requirements of SQF, i.e. NO microbial contamination on the tool, the hook, and the food surface (mixer, extruder, etc.).  Basically, how can I hang tools that will be contact with a food surface, and have our operators use the tools multiple times during the day w/o "sanitizing" each and every tool after each and every use?

We are a pet food manufacturer seeking SQF certification and we are stumped on this one.

Thanks for your help.

John Ramuno

Hi John 

More information is needed to be helpful.  For example what are the tools being used with, bloody meat, flour, some explanation of how your process works and what the tools are being used for is needed.  It may be that sanitation is necessary but there can be simple ways to do that as well. 

Yes, Meat.  Yes Powder. Yes processed (cooked) food.  We have shovels and scoops used to scoop food from bags into mixera.  We have wrenches, pliers, allen wrenches, etc. used to adjust and set up machines.  All our tools are hung on tool boards (metal or plastic peg boards) and we have a sanitizer spray bottle at each board, and policies demanding our people put tools back CLEAN by spraying them before placed on the board... BUT who know if they are doing so ALl THE TIME.  My QA director says we must verify that ANY surface our tools come in contact with (hoos, walls, tool boards, etc.,  and which the tool will then be used on a food contact surface must be CLEAN.  What do other folks do regarding "hanging tools>"

Thanks,

John

You can verify they are clean by ATP.  I would think that frequent checks at least initially would show you what the pattern is.  Once you see that they are regularly clean, you can adjust frequency accordingly.   That they are clean will validate the process. 

OK regarding ATP, but we have over 300 "tools" at over 25 tool boards and some 50 "hooks" or "shelves" with about 55 employees times three shifts.  If our SQF auditor sees a "clean" shovel hanging on a hook and the shovel is touching the hopefully "clean" wall, but has been used six times since the last ATP inspection, how can we verify that the tool is indeed clean...if asked by the inspector/auditor?  It seems that you would have to have CONSTANT verification by QC/QA during every process where tools are used, hung up, used again, etc.  OR are we overreacting regarding the wall (surface) touching?

Oh, our tools don't touch the walls, the pegs are at an angle to the tool hangs slightly off of them

If the tool touches  only the HOOK there is still the potential for contamination (if the hook is not ATP tested).  And there is no way that you can verify that who ever put the tool on the peg, etc. didn't "accidently" touch the tool to the wall.

Over reacting--I'm not sure, but it is a good thought process and something you want to know is right and a fair question from an auditor.  If an object is touching meat is spraying enough or does it need have "stuff" removed before the sanitizing spray is applied?  You need to validate the process you set up is working.  You do that by verifying.  The frequency may be high at first but then that data will demonstrate that the frequency of checking can be pushed out.  Eventually perhaps all you will need to do is  randomly check a few tools everyday at startup.  Your looking for clean not sterile and that there is a reasonable assurance that the tools once hung up are clean.

We process sauces--no meat, dairy, not high risk, so I am not sure how relevant. But still, it is food.

Our tools that are not used so much are kept in toolboxes. Boxes are cleaned and kept closed. Tools not in often use are kept clean there, inspected to be free of rust. Auditors have not had an issue with this.

Where tools are used often and need to be close at hand, which is a filler/washdown area, our maintenance guy came up with an excellent solution. Small PVC pipes with bottom cap but ventilated with holes. Mounted close at hand but easy in and out. This has solved the problem of tools left out to grab when needed and allows washdown sanitizer spray to clean tools, holders, & all. Air dry.

Set aside a test set of tools and test product. Simulate real world interaction of the test sets. Do ATP/micro on the test sets. Is there a problem? If yes..rethink the process. If no..do the test again. If the answer is still no, fully document and have results ready for the auditor. 

Marshall

In a perfect world, every food contact surface or tool would  necessarily be washed and sanitized after each use, or so many QA people would have you believe. In the real world, if you can show that your systems for hygiene won't kill or sicken people, you are good to go.

Marshall

Thank you all for your comments.  

"Real" world, "Perfect" world and the "Auditor's" world seem to be miles apart.  In talking with our QA/HACCP team, it looks like we are going to go with our (current) "Clean it after every use" policy and demonstrate to the auditor that we have a "reasonable" expectation that our cleaning and sanitizing SOPs are meeting requirements.   

Thanks again!

John

Dear johnramuno,

IM(haccp)O prevention is better than cure. Where possible.

Not a meat person but am a cooked food one. I personally find it rather surprising that all these tools need to be stored within a High Risk area. Seems basically unsound hygiene logic.

I presume the tools used for cooked food aspects are physically segregated from non-cooked area ? This at least  minimizes the cross-contamination risk albeit not totally removing it. And are the tools actually applied where a possible direct/indirect contact to food can actually occur ? This is risk assessment.

I would have not expected workers to have to be continually having to use wrenches, spanners etc to routinely maintain a standard process line. Particularly up to 300 of them.!

Sound like a case for a process re-design somewhere perhaps. But perhaps this is not possible for some reason.

Rgds / Charles.C

We did have a similar situation.  We tested the wall's surface of where tools may touch at random times for APC over a period of 60 days.  Wrote a risk assessment and then we periodically sample the surfaces for verification.  ATP would be ok after pre-op, but once the tools are used then ATP could pick up any organic materials so we found APC to be a better test in our situation.

Could a picture be posted showing a tool board?

We have a kill step after mixing the product. our tools to load the mixer don't need to be cleaned because the product goes into a retort.

For our growing rooms we hang the squeegees on the wall but have a sanitizing solution that the squeegee sits in. Would that be possible for the shovels? Could scoops be cleaned off and placed in a tote full of sanitizer. You would need to rinse the tool before use again. Between crops and on breaks we dip our knives in a sanitizer solution. If there is a kill step after the mixing portion then generally clean should be ok.

There are sanitizing agents that don't need to be rinsed post dip. However, none are effective if the item has gross material on it going into the solution. So yes, you could do the same for shovels, but they should be rinsed clean prior to being placed in the solution

Just because your retorting does not mean you can skip basic GMP's............the tool should still be visibly clean between batches

...."don't need to be cleaned because the product goes into a retort."

Huh???

 

Get wall mounted holders that are extended out from the wall so that CLEAN hung tools do not come into contact with the wall.

Our process is completely different than others. We grow gourmet mushrooms not white button mushrooms- completely different process. Raw materials come in, like sawdust and peat moss. They load the mixers and the bags are filled with substrate. Then they are sterilized in the retort. Once the bags are cooled in a HEPA filtered room they are moved to the lab by conveyor. Once in the lab the bags are inoculated with spawn and are sealed.

The raw materials and mixer are pretty much in a separate facility. The retort connects to the rest of the plant that is under GMP.

The shovels that scoop the material into the mixer are not cleaned between batches and are not required to. Shovels are not on a cleaning schedule either. They are replaced if they break. No issues with our third party audits or the FDA.

We use no rinse sanitizer wipes on all tools or thermometers before and after we use them on any food contact surface.  

Forgive me if someone else has already asked this question or given this idea, but could you:

A. have a common sanitizer "bath" or "dip" that each tool gets quickly dunked in before being hung back up on the wall? If the tools have visible gross contamination, could they be sprayed off first, then dunked before being hung? 

B. add the wall behind the tools to your daily sanitation schedule? 

Raw processing areas may not need as stringent of a control on tools as your cooked area tools. Are your raw and cooked production areas/tools separated?