Industry experts detail how to get plant sanitation in line with Food Safety Modernization Act standards.

Candy and Snack Today | January/February, 2015 | Interview with Darin Zehr.


The Food Safety Modernization Act is revolutionizing manufacturing practices and sanitation is a key component. Discover four considerations for getting a plant up to snuff ahead of the FDA deadlines.

As the biggest change in food safety regulations in the past 75 years, the FDA’s Food Safety Modernization Act (FSMA), aims to limit risks by requiring sanitary production facilities and safe products through preventive controls, detailed plans and record keeping.
Although plant sanitation is an important provision of compliance, FSMA does not directly cover it, explains David Dixon, president of infrastructure planning consultancy David Dixon, LLC. “Basically FSMA deals with the paperwork of quality assurance (QA) tests and how it is handled and responded to,” Dixon tells Candy & Snack TODAY. “Directly, FSMA impacts certain processes; indirectly, it affects the entire operation.” To get a candy or snack plant up to FSMA sanitation standards, sources say developing a strong plan, employee training, using hygienic principles in equipment design and reducing risks through smart facility layout are paramount.


Hazard analysis and critical control point (HACCP) is a cornerstone in complying with FSMA, Dixon reports. “That’s the core analysis to know where your risks are. From that you can get an action plan.” (See sidebar Assessing, Handling Risks) He says the second thing to consider is following procedures that are already laid out, such as BRC, SQF and other standards set up by the Global Food Safety Initiative. “About 80 percent of the food industry is regulated by the Good Manufacturing Practices (cGMP) standard,” says PMMI Consultant Jeff Barach. “If a manufacturer is just following cGMP, the first step could be to go with a HACCP plan and then on to FSMA.”

Setting up this plan can require significant effort, and just as every plant’s equipment and processes are different, so is its food safety plan. Included in the overall plan must be a master sanitation schedule and program, according to Darin Zehr, general manager of Commercial Food Sanitation LLC. “FSMA is saying an assessment must be done and preventive controls put in place,” he says, explaining these controls are defined as procedures, practices and processes aimed at eliminating risks.
The plan should detail how equipment and the facility are cleaned and with what frequency to address the risks identified by the assessment.
“It’s important to follow solid cleaning schedules and make sure they are validated. Reviewing sanitation programs for effectiveness is prudent for companies to be successful with the expectations in FSMA,” Zehr tells Candy & Snack TODAY.
Routine cleaning is just the tip of a master plan, which should address possible allergen, microbe and pest risks, and periodic cleaning procedures must also be included. These provisions were often overlooked in the past, according to Zehr. “You might perform routine cleaning on a
monthly, weekly or daily basis based on the product being made and type of processes, but periodic cleaning is when you tear down a piece of equipment further than you normally would,”he explains. “A manufacturer might do this on an annual, six-month or quarterly basis, again depending on the risk assessment.” With the responsibility for food safety being on manufacturers, the FDA is in an inspector role. “It’s more than going around the plant trying to find a leaky pipe,” he says. “As the inspector comes in he is going to want to see records and the food safety plan and verify it is working.”


As with any process in a plant, training is essential, sources agree. An important aspect of this is verifying all sanitation employees understand standard operating procedures. “Ideally, this would include visual observation of completion and a sign off that they know the procedures and can follow them,” Zehr says.“It has to start with training for sanitation knowledge throughout the company, not just sanitation and QA personnel,” he explains. This becomes critical as engineering and maintenance departments, as well as heads of operations, might have goals that conflict with the sanitation and quality assurance teams, yet are making the final choices for design and layout.
“Engineering might want to get an operation up as quickly as possible, but they might not be getting into food safety, pest control and hazard controls,” he explains. “On the flip side, you might have sanitation or QA people who don’t work with the maintenance or engineering groups  enough to help them understand the risks.”


A top consideration should be sanitary design for equipment, Zehr reports. “Poor design can put you in a hole and add a lot of burden to the sanitation and food safety programs.” When it comes to equipment design, sanitation considerations include the types of materials used and how joints and welding are handled. Flat surfaces and places where water can collect are big design flaws, according to Barach. In addition, the necessary wash down method can impact material selection for equipment fabrication.
“You need to have rounded or minimized surfaces so product and water can’t collect,” he says. “The other part is inspection of equipment and training to clean and visually verify that. If you have blind spots on equipment, you can’t really tell if it is clean, which is why it is important that nothing is hidden by the design, and if it must be, that it can be taken apart.” “The opportunity for OEMs is to get really smart in sanitary design and implement good principles where they don’t have them now,” says Zehr. Machinery suppliers can leverage sanitary design as a point of differentiation and offer a value-added piece of equipment, he explains, adding: “It not only gives companies buying the equipment an advantage from a sanitation and food safety standpoint, but also better efficiency
through more up time. Savings are on both ends.”
An important step is making sure CPG companies and OEMs are on the same page concerning the basics of sanitary design, according to Steve Perry, co-managing director for The Alliance of Innovation & Operational Excellence (AIOE), a PMMI working group charged with encouraging food manufacturers and equipment suppliers to collaborate. “Manufacturers were talking to equipment suppliers individually and asking for different
things,” Perry tells Candy & Snack TODAY . “So we got them all together and said, ‘Can’t we agree on 80 percent of the features that should go on standard equipment to further food safety?’” Resulting from this is the One Voice document, available at pmmi.org/AIOE, which details basic design components that should be included.


Just as equipment design should be mindful of sanitation, so should the plant layout. While all facilities have unique hazard risks, AIOE has worked collaboratively with manufacturers and OEMs to establish basics for hygienic zones specifically for low-moisture food production. The alliance has broken the fundamentals down into basic- and high-hygiene zones, although some plants can have four or more specific hygienic designations, depending on the risks present. Not only do these zones dictate the type of cleaning required — dry or wet — but also the materials used in equipment fabrication. (See sidebar, Defining Hygienic Zones)
Perry notes when determining these areas the plant environment factors in. This might lead to the need to seal off certain parts of a facility or prohibit access unless personnel take proper hygienic steps.
“If you go into any food plant, you’ll see diagrams for heightened sanitary concerns, and then there are other areas with no contact surfaces to worry about,” he explains. For large companies with the staff and resources, implementing these plans isn’t much of a burden, according to Perry.
Getting small- and medium-sized manufacturers on board is the real challenge, he says, adding: “The larger CPG companies tend to have the resources — human and financial — and can have microbiological experts on staff to do the lab work.”
Regardless of size, Barach says companies should get engaged as soon as possible, cautioning: “some of these practices aren’t that easy to implement.”
Read the full article in the digital publication of Candy and Snack Today – Page 64