I think I know the kind of thing. I've certainly seen in a low risk facility a drain pipe which leads from a mezzanine or higher level down to low level to take away wash water.
Firstly this all falls into the areas over plant areas clause to my mind rather than 4.4.3
4.4.6:
Where elevated walkways, access steps or mezzanine floors are adjacent to or pass over production lines which have open products, they shall be:
• designed to prevent contamination of products and production lines
• easy to clean
• correctly maintained.
So to my mind, the typical solutions I would see for these mezzanines are, they'd have kickplates so would have a large lip at the edge of the floor surface and the drain from that surface would not be directly over the production line. If it is you may want to look at the fabrication of it and consider the risk of leaks etc. Even if wet cleaning only occurs during downtime, you should still be trying to avoid cross contact and the unexpected sometimes occurs. If you're happy there is no risk, document your risk assessment. If there is, document it, change it then document the change.
When this clause came in with v8 we had a lot of walk over areas as I was in low risk at the time. We did a systematic risk assessment of every set of steps and platforms. It was worth it not just to evidence it to an auditor but we also found about four points where we made the protection more robust.
Edited by GMO, 30 May 2023 - 03:48 PM.