BRC clause 4.8.7 Toilet facilities

Hi guys,

I'm having difficulty with determining what my business need to do in order for us to achieve BRC compliance with the following clause. We are not BRC accredited at the moment and it's a long road before we get to a stage where we will be conducting the pre audit. The part of the clause I'm conflicted with is:

"Toilets shall be adequately segregated and shall not open directly into production or packing areas. "

​Now from a gmp/basic hygiene point of view we shouldn't have a toilet block next to a raw material storage area - potential risk of blockages etc results in a high risk to raw materials. The clause states "not open directly", in our case we have 3 separate toilet cubicles each with handwash facilities that then open into a small corridor (no handwash) and that in turn opens into a processing area. In my mind that is not "directly into production or packing areas". But with the added risk due to the raw materials store next door I am pushing to get the toilets relocated to an area removed completely from production/packing.

​I would basically just like your thoughts on this, the wording kind of makes us already compliant but from a risk basis I don't think we should be, if that makes sense?

Hello Neviller, SQF has a very similar code. They are both similar to FDA's §CFR 110.37   Sanitary facilities and controls . There it states:

(d) Toilet facilities. Each plant shall provide its employees with adequate, readily accessible toilet facilities. Compliance with this requirement may be accomplished by:

(1) Maintaining the facilities in a sanitary condition.

(2) Keeping the facilities in good repair at all times.

(3) Providing self-closing doors.

(4) Providing doors that do not open into areas where food is exposed to airborne contamination, except where alternate means have been taken to protect against such contamination (such as double doors or positive air-flow systems).

If you are an FDA processor, you are already required to follow this regulation. A secondary door with a small hallway, where both doors have self closing mechanisms (so that neither allows substantial time where both are open to processing) should be compliant in each case.

If you already have a covered hallway after the first self closing door (stall doors do not count) then installing another self closing door before processing floor would be your best bet. Anything to get the "double door" so you aren't directly opening lavatory facilities into exposed food areas.

Moving toilets is not an easy plumbing job, it requires a lot of changes, possibly involves building permits, and is expensive. But, you may have more success looking for ways to protect your raw materials and getting those changes approved.

Martha

I believe the primary reason why BRC states restroom facilities are not to be opened directly into production is the potential risk for contamination is elevated. Restrooms  present a higher risk for cross contamination by being directly connected to areas where food is processed for a few reasons. Restroom are a reservoir for water issues. Wherever there is water, you have a great habitat for germs. Traffic flow is high in these areas which increases the potential for cross contamination especially when touching the door handle when leaving. And third, the type of micros found in restrooms - Ecoli, norovirus, staph, etc. can be potentially dangerous and communicable if hygiene is not practiced. That's why hand wash stations are in restrooms as well as generally somewhere before working on the line.