Cleanliness and Contamination question (Medical Device Component Manufacturer)

Mortalis

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Sorry for a new post on the same question but some how the title was not posted correctly.

We are a device component manufacturer not a food manufacturer.

We work with stainless steels and Nitinols in a machine shop environment (ISO 13485 certified and FDA registered) and we do not sterilize product before it is delivered to our Customers. We manufactures in job lot sizes for many different Customers. We have a very sophisticated final clean station that has just completed the IQ, OQ and PQ validations as well as in-process cleaning stations used to remove the processing fluids that are normal to a machine shop environment going from one process to another. All our product goes through the final clean and then a final inspection (In a controlled environment room, not a clean room) before leaving the facility.

We have been told by the FDA as well as a couple high level Customers that personnel eating on the production floor is not acceptable. We get the thought process that brings that about and are well aware of the sections in the CFR that pertain to contaminatio which, by the way, do not "prohibit" the consumption of food in the manufacturing areas but in our view pertain to the potential invitation of pests. Our cleaning equipment (although not specifically validated for food particles) is capable of removing manufacturing oils and such and as such should be able to address the reasonable attempt to prevent contamination from any substance that could reasonably be expected to have an adverse effect on product quality from reaching the Customer.

We are prepared to institute a no foods or drinks policy with the exception of water, on the manufacturing areas. My question to those that have instituted such a policy is,
  1. has this policy extended into the business office areas (away from the manufacturing areas) as well?
  2. If so, how have the conference areas been included into this policy especially during Customer visits with coffee and lunch (many Customers prefer a working lunch).
  3. How have hard candies and cough drops been addressed? Many operators have voiced a concern that they use these items to relieve dry throat and coughs.
 

Candi1024

Quite Involved in Discussions
Re: Cleanliness and Contamination question

Food is allowed in office areas and conference rooms. When entering the manufacturing area, hands are washed. No cough drops or hard candy allowed in manufacturing areas.
 

AgnieszkaSz

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It is a common practice, not only in medical devices manufacturing, that eating is not allowed on production floor. If your production room is not a cleanroom, you can consider drinking water station in personnel airlock, with requirement to wash and disinfect the hands before the personnel returns to controlled area. No chewing gum is also a sound requirement.
 
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