Restrooms Inside a Food Warehouse Facility
Hello all,
I came across a dry storage facility that has an open warehouse. I'm doing a 2nd party audit to see if they are fit as a distribution service provider. The facility added two restrooms inside of their warehouse located right outside the original single person restroom, they look like high end portable restrooms, they are plumbed and aesthetic. What I mean by aesthetic, they appear nice within the facility with a nice plastic finish and porcelain toilet and sink. These were added after their annual food safety audit, their renewal will not take place for many months. The facility did not perform a risk assessment.
This is new to me and I feel compelled to perform a risk assessment on these restrooms. This is a learning experience for myself as this is the first time I've been in this situation. I have a few points on what to call out and wanted to ask for feedback for more. If anything I'd like to provide my assessment to the facility and see if they will consider making changes as a part of the approval process.
The restrooms are plumbed. They resemble sheds and are outside of the single person restroom.
Biological- Air exhausts to the open warehouse. There is no filter, its an open fitted pipe vent.
Correction- exhaust should be directed to the outside? I'm not expert and don't know where the vent air normally goes.
Biological and Foreign contamination - Structure can leak sewage where and can contaminate surrounding. (materials are on pallets and about 25 ft from restrooms)
Correction- Concrete post to prevent from a forklift hitting the structure
Correction- Need assistance, it is plumbed, would a containment type pan be needed?
Biological- No hot water, current faucet has one lever only with cold water.
Correction- replace faucet with an option for both hot and cold water.
Correction- install handwash stations outside restroom with hot and cold water.
What would you have done in this situation?
Ultimately I know its easy to not approve and walk away, but as an advocate for food safety I feel its important to share the risk assessment with the facility to be considered.
Thanks in advance!
Your concerns are all valid
Are they GFSI certified and if so to what standard? You mentioned audited, but didn't mention against what
They are GFSI certified, it is PrimusGFS.
You have very good points and concerns. Not sure of Primus GFS, but SQF states the toilets are separate from any processing and food handling operations. I would add in, the Bathrooms should not open directly into warehouse area. And suggest they have a wall or partition with door of some sort, with a place to store PPE close by.
it appears Primus does not require those items for a storage facility
The venting of the plumbing sounds more like a building code or personnel safety type violation.
If this was a processing plant those facilities might be inadequately segregated and violate all kinds of things, but in a facility where no product contact occurs and everything is sealed in packaging ... maybe not. Those locations typically consider any container that is breached as inedible waste.
How clean is a wooden pallet? I've dealt with some silly feedback from USDA inspectors about what shipping containers can come into contact with, but they don't blink and eye when a pallet is taken out of a stack and that container is plopped on top of it. -- with my micro background I look at that situation and think of all the filth the bottom of the pallet on top of that one had contact with before and consider every surface of every pallet no better than the floors they touch. The floor touches the bottom of pallet A, and the bottom of A touches the top of B, the top of B touches ... everything.
Actually as far as SQF, you can have restrooms open directly into the warehouse area, if they are properly vented to the outside. I helped in an audit once, where the restrooms opened directly into a warehouse and the auditor tried to ding them, I stepped in and said but they are ventilated and ventilated to the outside. He still gave a NC, we countered and won. The storage and Distribution code states 'Toilet Rooms shall be Accessed from the warehouse or food handling area via an airlock vented to the exterior or through and adjoining room'.
All valid points to bring up. I would also maybe say they should have a procedure in place if there would be a sewage backup on how they would clean and handle any potentially affected material.
Under the guidance for PrimusGFS v2 Facility module, it is considered major non-conformance if they doors open to storage area or production. Here is the link to the explanation: https://primusgfs.co...-Guidelines.pdf
In any food safety standard, toilet doors directly opening into production or storage areas is a major non-con. If I saw what you have described when conducting, I would fail the facility without hesitation.