BY: Stacey Pisani
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Every food supply company has an obligation to its customers to provide safe and quality food. In addition, a growing number of retailers and wholesalers require their producers and suppliers to implement compliance and certification programs. Food Safety Modernization Act (FSMA) compliance presents an even greater benefit to food-safe building and equipment programs, as it complements and aligns with GFSI-certified standard requirements (e.g., SQF, IFS, BRC, FSSC 22000) and demonstrates that a company is working actively to manage its food safety risks.
In today’s food safety-focused and competitive climate, it is challenging for companies to devote the resources required to maintain compliance activities at a sustained and satisfactory level—but it is essential.
The following solutions can help keep companies who work with food-related materials on track when it comes to managing food safety and certification requirements and achieving compliance with FSMA’s Preventive Control requirements.
- What are the issues that food and food industry sites must address to meet general plant control requirements for legal compliance and/or industry certification?
To comply with both regulatory requirements under FDA/FSMA and GFSI industry requirements, food companies must establish control of food safe premises, plants, and food risk zones. With recent changes, compliance is not limited to just companies that manufacture and distribute food product, but also to those that provide food chemicals, packaging, and logistics. The requirements apply to all companies distributing food or food ingredients to the U.S. market.
Food Plant Zoning
- Locks and access controls
- Pipe and utility marking
- Floor and area marking and coding
- PPI and PPE stations
- Waste and water control
- Color coding/tools/utensils/maps
- How do the regulatory and certification requirements for food safety impact controls for facilities and equipment?
The regulatory and certification requirements include elements to ensure all aspects of food safety. This includes “Food Safety and Security,” which requires the protection of food against the potential for deliberate or accidental contamination. This is in addition to the site and general security.
Equipment and Facility Controls
- Lockout/Tagout systems
- Seals and tags
- Security gates/fences/areas
- Emergency and response kits
- What are the food safety requirements for controlling food, non-food, and food contact materials?
A key focus for compliance includes the control of food and contact materials. This includes direct control, evidence of communication, and direction of employees to avoid the misuse or contamination/cross-contamination of the food product. Control of utensils and tools used in the food processing areas represents a major area of inspection as part of the audit process.
- Locked and rated cabinets
- Floor markings
- Message boards
- HMIS/NFPA programs
- HazMat labels, inventory tags, and forms
- How is foodplant building maintenance addressed in food safety compliance?
The first requirement of a food industry plant is to ensure the proper building elements of construction and design. Once commissioned for food products or distribution, the facility must be maintained to its original level commissioned as fit for use.
- Access and premise food maintenance
- Exterior building envelope
- Internal building envelope
- Doors and locks
- Process areas and critical maintenance (lubrication, PM, etc.)
- Sanitary, employee areas, break rooms
- Water drains, and waste control
- What security requirements do food industry sites need to consider to meet regulations or GFSI industry certifications?
Food plants are included under the Department of Homeland Security (DHS) as requiring developed and implemented security programs. The registration of food plants under the FDA certification required by DHS is a key aspect of being approved and registered to operate for food sites.
Security (Food Safety and Security)
- Premises security fences, gates, locks
- Passkey and key control systems
- Badges and badge readers
- Video security and alarms
- Building and equipment locks and access controls
- Equipment and storage seals and programs
- Security cabinets and storage
- Tamper-evident seals
- Signage – warning and informational
- How are hazard warnings dealt with in a food operation both to communicate with employees and visitors and to show evidence of compliance?
Compliance with food safety requirements provides that companies communicate with employees and visitors on the conditions for access to the food operation. To do so, it is expected that communication is established through various means to ensure notification of all related parties, including employees, visitors, truck drivers, service providers, contract employees, and contractors.
- Signage (building, equipment) – warning, hazard, directional, stop
- Labels and marking equipment and utilities
- Floor markings
- Conformities and allergens
- Inspection and approval directions
- Information boards
- Location control
- How are warnings provided within a food plant for activities and people?
Compliance with food safety requirements provides that higher risk direction is maintained to ensure the protection of food operations. This includes both documented and posted warnings to achieve communication at this level.
- Premise directional signs
- Food safety signage (GMPs, receipt, processing, release, shipping)
- High-risk equipment labeling, process warning signs and directions
- Emergency response
- Food safety mapping and locations
- Employee sanitation
- Employee rules
- Employee hazard communication
- What requirements do food operations need to maintain to ensure the understanding of food safety throughout the organization?
Food safety requirements provide that management must ensure that food safety compliance is established throughout the organization and related parties. This can be accomplished through various means, including postings, signage, marking, mapping to enhance traditional methods of training, and meetings.
- Visual workplace
- Information boards
- Employee communication
- Hazard communication
- Food plant zoning
- Directional location information
- Preventive controls
- Process requirements
- What are specific controls necessary for safe food operation based on the identification of key infrastructure elements of a food operation?
Food operations are expected to maintain up-to-date engineering information, drawings and schematics, and related identification. This requirement is to ensure that all aspects of commissioning for food operation are maintained, with the assurance that physical identification and inspection of all related areas and fixtures is also demonstrated and maintained. Specific marking, labeling, identification, storage locations, tagging, and seals provide a means of meeting these requirements.
- Truck and transport container tagging and sealing
- Pipe and utility marking (engineering and plumbing drawings)
- Shadow boards/tool and parts storage
- Identification and warning labels
- Process equipment identification
- Key program tagging (pest control, waste, etc.)
- Service ID tagging (inspections)
- PM tagging for food compliance (critical equipment)
- What provisions are there for asset management within a food operation?
Food safety regulations and standards require that all assets determined to be critical or to be maintained to achieve food safety be managed and maintained. To accomplish this program, means of achieving control over these assets must be developed, implemented, maintained, and evident.
- Critical equipment management
- Building maintenance management
- Project equipment and building materials management
- Asset inventory and verification management
- Active versus inactive assets (in-service, out-of-service management)
- Asset disposal management
- Inventory status management – available, on-hold, disposition
- Storage location management