Maximise Global Food Safety Scheme compliance

Cleaning is a critical step in the management of food safety and quality.

Cleaning tools have been identified as a major source of contamination - 47% of the cleaning tools sampled as part of a major, UK Government funded study were found to be contaminated with Listeria monocytogenes (CampdenBRI, 1990).

Whether this result was due to the poor hygienic design or poor hygienic maintenance of the cleaning tools is unknown but GFSI food safety and quality schemes now recognise that both of these are essential in order to minimise the risk of product contamination.

Our Global Hygiene Specialist, Deb Smith, has reviewed the most current versions of each of the top four GFSI food safety schemes, summarised key information related to cleaning tool selection, use and maintenance, and offers some top tips on how to optimise cleaning tool audit compliance.

Optimising audit compliance through good cleaning tool selection, use and maintenance

Introduction

Many food producers are subject to regular audit to ensure food safety and quality. These audits can be conducted by internal quality personnel, or by external retailer or standard and scheme auditors. The requirements of each audit will vary. 

Internal audits tend to be very site or process specific. External audits tend to be more generic and focus on application of best practice. Business to business, e.g. retailer to manufacturer, audits are more prescriptive, detailing specific requirements across all sites that produce for them. However, all stress the importance of implementing controls based on risk assessment. 

GFSI food safety and quality scheme requirements

With regard to external food safety and quality audits many of these are now conducted by, or on behalf of, one of the four main Global Food Safety Initiative (GFSI) approved food safety schemes, these being the

• British Retail Consortium (BRC)
• International Standards Organisations’ Food Safety System Certification (ISO, FSSC 22000)
• Safe Quality Foods Program (SQF), and
• International Featured Standards (IFS)

Between them these four GFSI approved schemes cover over 25,000 certified suppliers in over 140 countries. Food manufacturers who hold GFSI scheme certification are able to demonstrate their compliance with food safety and quality standards more easily and thus protect and improve the reputation and income of their business.

Each GFSI scheme details comprehensive requirements with regard to the maintenance of food safety and quality.

Below is a summary of the current requirements related to the selection, use and maintenance of cleaning tools.

BRC v.7 (2015)

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 hygienic manner to prevent contamination.
• Equipment used for cleaning high care and high risk areas shall be visually distinctive and    dedicated for use in that area.

FSSC 22000 (2005) 

ISO/TS 22002-1:2009 (2013) Prerequisite programmes
on food safety - Part 1: Food manufacturing

Clause 11.2

• Cleaning and sanitising agents and tools:
  Tools and equipment shall be of hygienic design and maintained in a condition which does not present a potential source of extraneous matter

Clause 11.3

• Cleaning and sanitizing programmes:

Cleaning and sanitising programmes shall be established and validated by the organisation to ensure that all parts of the establishment and equipment are cleaned and/or sanitised to a defined schedule, including the cleaning of cleaning equipment

Clause 11.5

• Monitoring sanitation effectiveness:

Cleaning & sanitation programmes shall be monitored at frequencies specified by the organisation to ensure their continuing suitability and effectiveness

SQF code 8^th Ed.

Section 10.2.9.2 & 10.2.9.8

• Equipment and utensils shall be designed, constructed, installed, operated, and maintained so as to meet any applicable regulatory requirements and not pose a contamination threat to product
• All equipment, utensils & protective clothing shall be 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

IFS v.6 (2014)

• No guidance

How to optimise cleaning tool audit compliance

Hygienic design

Vikan are Company Members of the European Hygienic Engineering Design Group (EHEDG) and I am a Committee Member of the UK:IE Regional Section.

EHEDG are an independent, not-for-profit organisation populated by academic and    industry volunteers who seek to ‘..promote safe food by improving hygienic engineering & design in all aspects of food manufacture.’. This is achieved through the development and provision of hygienic design related guidance, training and certification.

Making something that is ‘hygienically designed’ means that it has been designed to be easy to clean. It also means that it will be fit for purpose with regard to its durability and its materials of construction. EHEDG Guideline 8  "Hygienic Equipment Design Criteria" defines some fundamental principles with regard to the hygienic design and construction of food industry equipment.

They include:

• No sharp internal angles
• All areas accessible for easy cleaning and disinfection – avoid deep recesses, nooks and crannies
• Of one piece construction, or quickly and easily dismantled / re-assembled
• Smooth surface finish
• Made of food contact compliant materials, as appropriate.
• Rule of thumb – if you can see it you can clean it.

EHEDG

Cleaning tools that come into contact with food directly or indirectly should be made of materials that are compliant with the following Regulations (and subsequent amendments and updates):

• Regulation EC 1935/2004 - Framework Regulation on materials and articles intended to come into contact with food.
• Regulation EC 2023/2006 - GMP for materials and articles intended to come in contact with food.
• Regulation EU 10/2011 - Plastic materials and articles intended to come into contact with food.
• The FDA Regulation CFR21 - Subject to change due to the introduction of the Food Safety Modernisation Act (FSMA)

There is a legal requirement for manufacturers of cleaning tools to the food industry to provide on request,

• Migration test certificates, and
• Declarations of Compliance that contain information as defined in Article 16 of Regulation EC 1935/2004, containing the information set out in Annex IV of Regulation EC 10/2011

Equipment that is EU food contact compliant can display the ‘Glass & Fork’ mark.

It is important to note that:

• Not all cleaning tools supplied to the food industry are food contact compliant
• FDA compliance alone is NOT sufficient within the EU

Always ask your cleaning tool supplier for evidence of EU compliance.

Cleaned, maintained and stored in a hygienic manner

Cleaned

To optimise GFSI scheme audit compliance cleaning tools should be managed in the following way:

1. Develop validated tool cleaning and disinfection methods
2. Clean and disinfect tools to a defined frequency/schedule
3. Regularly monitor and verify cleaning efficacy
4. Store tools appropriately
5. Regularly inspect and replace cleaning tools
6. Keep up to date records and documentation on cleaning tool management for audit inspection.

A generalised cleaning tool cleaning decision tree is provided below.

The methods and frequencies of cleaning will depend on many things. Consequently, the key to determining an effective decontamination program is to base it on risk assessment.

Ask yourself,

• What *Hazards are present
• What is the Likelihood that they will occur?
• How Severe will the consequences be if they do?

*Hazard - a biological, chemical or physical agent that has the potential to cause harm.

Prioritise control of the high risk scenarios identified.

Maintained

Cleaning tools should be:

• regularly inspected for damage and wear and tear
• replaced as appropriate, based on risk assessment

It is recommended that descriptions/images of what is acceptable and what is not, and records of tool inspection and replacement be kept for auditing/due diligence purposes.

Do not make poor quality repairs to damaged equipment as this can increase the safety risk to the food product.

Stored

Cleaning tools can be stored on colour-coded wall racks or shadow boards. These;

• minimise equipment damage and cross-contamination
• improve efficiency - provide a place for tools to be stored and found quickly when needed
• aids compliance with HACCP prerequisite programs and provides auditors with evidence of equipment control.
• Use of colour-coded cleaning tool storage provides a visual check that the right-coloured tools  are being used and stored in the right area
• Shadow boards provide a quick visual check as to whether something is missing from a cleaning station

Visually distinctive

The use of colour-coded cleaning equipment and area segregation plans can provide a visual check that only equipment colour-coded for use in that area is used.

Top 5 tips to aid audit compliance

1. Remember that cleaning equipment can be a major source and vector of contamination
2. The appropriate selection and maintenance of cleaning equipment is a requirement of GFSI schemes – BRC v7, FSSC 22000 and SQF
3. Cleaning equipment and utensils likely to come into contact with food or food contact surfaces must be EU food contact compliant. FDA compliance alone is NOT sufficient
4. Choose equipment that is fit for purpose (based on risk assessment) – food contact compliant, hygienically designed, colour-coded, distinctive
5. To minimise the risk of cross-contamination and maximise audit compliance cleaning equipment should regularly be cleaned, inspected and replaced, and stored appropriately. 

To help you further meet your audit requirements Vikan can supply a comprehensive range of hygienically designed, durable, EU (and FDA) food contact compliant, visually distinctive cleaning tools and tool storage solutions, in a wide range of colours. We also offer a free service to provide colour-coded site plans and a series of White Papers that provide further details on various audit compliance issues.

Declarations of Compliance and White Papers are available to download from our website:

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