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Applications with Food Processing:


Why?

The Food Safety Modernization Act (FSMA) in section 117.37(e) provides: Each plant must be equipped with adequate sanitary facilities and accommodations including: (e) Hand-washing facilities. Each plant must provide hand-washing facilities designed to ensure that an employee's hands are not a source of contamination of food, food-contact surfaces, or food-packaging materials, by providing facilities that are adequate, convenient, and furnish running water at a suitable temperature.  The act further now permits the FDA to order food recalls in the event of contamination.

The requirement for hand sanitation at all levels of the food chain is not a new feature of the food processing industry which has provided such facilities for many years and is very conscious of its responsibilities.  The monitoring of compliance with company policies is a problem which has not often been addressed.  Supervisor reporting is subject to proximity to the wash station, bias and continuous attention.  Sanit-Eyes addresses the need for management audit of hand sanitation by:

  • Individual hand washings can be examined in a sped-up view available until erased allowing fast, consistent evaluation over locations and shifts.
  • The Hawthorne effect, increased compliance while under observation, will increase proper hand washing due to the impression that every hand washing will be evaluated.
  • Statistics on the hand washing events are automatically accumulated over time.
  • This is the only system that detects other non-compliant uses of a wash station.
  • When improper hand washing techniques are found the employees can be counseled by showing them what is wrong.
  • The Sanit-Eyes system is economical, easily installed and easily moved.

FDA Food Code requirements

In the 2013 FDA Food Code note the following requirements:

  • 2-103.11 Person in Charge:The PERSON IN CHARGE shall ensure that:
  • (D) EMPLOYEES are effectively cleaning their hands, by routinely monitoring the EMPLOYEES' handwashing;
  • 2-301.12 Cleaning Procedure
  • (A) Except as specified in ¶ (D) of this section, FOOD EMPLOYEES shall clean their hands and exposed portions of their arms, including surrogate prosthetic devices for hands or arms for at least 20 seconds, using a cleaning compound in a HAND WASHING SINK that is equipped as specified under § 5-202.12 and Subpart 6-301
  • (B) FOOD EMPLOYEES shall use the following cleaning procedure in the order stated to clean their hands and exposed portions of their arms, including surrogate prosthetic devices for hands and arms:
  • (1) Rinse under clean, running warm water;
  • (2) Apply an amount of cleaning compound recommended by the cleaning compound manufacturer;
  • (3) Rub together vigorously for at least 10 to 15 seconds while:
  • (a) Paying particular attention to removing soil from underneath the fingernails during the cleaning procedure, and
  • (b) Creating friction on the surfaces of the hands and arms or surrogate prosthetic devices for hands and arms, finger tips, and areas between the fingers;
  • (4) Thoroughly rinse under clean, running warm water; and
  • (5) Immediately follow the cleaning procedure with thorough drying using a method as specified under § 6-301.12.
  • 2-301.15 Where to Wash.
  • FOOD EMPLOYEES shall clean their hands in a HAND WASHING SINK or APPROVED automatic handwashing facility and may not clean their hands in a sink used for FOOD preparation or WAREWASHING, or in a service sink or a curbed cleaning facility used for the disposal of mop water and similar liquid waste.
  • 5-205.11 Using a Handwashing Sink.
  • (A) A HAND WASHING SINK shall be maintained so that it is accessible at all times for EMPLOYEE use.
  • (B) A HAND WASHING SINK may not be used for purposes other than handwashing.
  • Annex 3 – Public Health Reasons/Administrative Guidelines
  • 2-301.12 Cleaning Procedure
  • Every stage in handwashing is equally important and has an additive effect in transient microbial reduction. Therefore, effective handwashing must include scrubbing, rinsing, and drying the hands. When done properly, each stage of handwashing further decreases the transient microbial load on the hands. It is equally important to avoid recontaminating hands by avoiding direct hand contact with heavily contaminated environmental sources, such as manually operated handwashing sink faucets, paper towel dispensers, and rest room door handles after the handwashing procedure. This can be accomplished by obtaining a paper towel from its dispenser before the handwashing procedure, then, after handwashing, using the paper towel to operate the hand sink faucet handles and restroom door handles.
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