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Amit M. Kheradia
Amit M. Kheradia
Environmental Health and Sanitation Manager

ABC’s of Manual Cleaning Part VI: Regulatory and Standards Expectations Regarding Manual Cleaning

In part five of our manual cleaning Blog series, we focused on the allocation of various manual cleaning responsibilities, and on how to create a robust hygiene and sanitation culture within an organisation. In this, our final Blog in the series, we’ll look at the EU and U.S. food safety and hygiene regulatory requirements, key industry and global standard requirements, and the best sanitation practices that support a manual cleaning operation.

Understanding the Regulatory requirements 

Cleaning and sanitation are key regulatory requirements in the food industry. Many food recalls happen because of poor sanitary practices, and a significant proportion of these relate to Salmonella and Listeria monocytogenes cross-contamination incidents within a food plant.

In the US, 21CFR 117 FDA regulations are clear about the importance of regular cleaning to prevent allergen cross-contact and cross-contamination of food products. Section 117.35 on “Sanitary Operations” clarifies that the food-contact surfaces of equipment must be cleaned and sanitised as necessary, and that non-food contact surfaces must be cleaned regularly.

Additionally, FSIS legislation based on Federal Meat Inspection Act, Poultry Products Inspection Act, and Egg Products Inspection Act also emphasises proper cleaning and sanitation to ensure the sanitary conditions necessary to produce safe food. Cleaning surfaces in these establishments will need some efficient and effective form of mechanical agitation using manual cleaning tools to remove rigid soils, e.g., surface biofilms.

In Europe, the General Food Law (Regulation (EC) No 178/2002) imposes general obligations to provide safe food. And according to Regulation (EC) No 852/2004 on the hygiene of foodstuffs, food businesses are required to implement procedures to prevent unsafe foods.

Under these laws, food manufacturers, caterers and other businesses in the food chain are responsible for and obliged to:

  • Provide safe foods
  • Implement procedures to prevent unsafe foods (including appropriate sanitation controls)
  • Be able to trace their food one step back and one step forward,
  • Withdraw and recall unsafe foods
  • Cooperate with competent authorities


Industry and Global Standard Expectations

GFSI-based certification standards have provided a series of benchmarks for harmonising global food safety programs to an agreed level of industrial expectation. The common standards focus greatly on using the right types of cleaning tools, as stated:

  • According to BRC Global Food Standard – Food Safety, Section 4.11.6, “Cleaning equipment shall be hygienically designed and fit for purpose, suitably identified for intended use (e.g., colour-coded or labelled), cleaned and stored in a manner to prevent contamination.”
  • SQF Code, Section states: “All equipment cleaned after use or at a frequency to control contamination and stored in a clean and serviceable condition to prevent microbiological or cross-contact allergen contamination.”
  • FSSC 22000 – ISO 22002 Prerequisite Programs on Food Safety – Part 1: Food Manufacturing, Section 11.2 on ‘Cleaning and Sanitizing agents and tools’ states: “tools and equipment shall be of hygienic design and maintained in a condition which does not present a potential source of extraneous matter.”


Sanitation best practice

As explained in part one of our blog series, during the sanitation process, manual cleaning of surfaces and equipment becomes inevitable. This is because not all the equipment and facilities within a food production environment are designed for CIP or other automated methods of cleaning, and it is these that need to be cleaned and disinfected manually.

Sanitation is not just about the cleaning and disinfection of surfaces and equipment but should be a holistic, risk-based methodology, aimed at significantly minimising or preventing product cross contamination (by allergen, microbes, and foreign material) within a facility. Illustrated below are the components of an integrated sanitation approach:

Below you’ll find a good list of industry best practices that may be useful when developing your integrated sanitation program:

  • Colour-coding – Use total-colour tools to differentiate between hygienic zones, or allergen zones, or to distinguish between tools used for cleaning food-contact and non -food contact surfaces.
  • Hygienic Zoning – Implement a good zoning approach that separates raw and finished products, allergen products from non-allergen products, and thus prevent, or significantly minimise, cross-contamination incidents. Proper zoning standards also support environmental monitoring and control programs.
  • Hygienic Design – Facility surfaces, equipment, utensils, and tools of a hygienic design and construction are more quickly and easily cleaned after use and pose less risk of contaminant harbourage and transfer.
  • Process Flow Management – Manual cleaning and tools streamline processes because, in part, proper selection, storage, cleaning, and care of tools prevent contamination incidents in a food plant.
  • 5S – Workplace organisation methods that incorporate elements of Sort, Straighten, Shine, Standardise, and Sustain into a manual cleaning program will also be of benefit.


Manual cleaning, as an inevitable part of regulatory requirements; and global and industry standard expectations, provides a proactive measure that should not only prevent or minimise food recalls, but also go a long way towards avoiding or reducing site inspection violations and foodborne illnesses.

Selected References: