Is your food facility as clean as you think it is? The link between cleaning and compliance.
But what about the things that don’t have direct contact with food, like the floors and the walls. Since these areas lie outside of the “danger zone,” they often don’t get the attention they require. This neglect can have disastrous consequences. The 2011 listeriosis outbreak in cantaloupe that killed 33 people was caused, in part, by workers tracking Listeria-contaminated water across the floor of the plant.
That’s why when FDA inspectors arrive to conduct their infamous “swabathons,” they aren’t swabbing just the equipment, but also the surrounding areas, including the floors, the walls, and the outsides of equipment.
And the FDA isn’t the only agency that’s interested in the cleanliness of your facility as a whole. The USDA, OSHA, state and local agencies, and even insurance companies will all be checking out the floor and more when they visit your plant.
Let’s take a quick look at how proper cleaning helps you comply with a variety of regulatory standards.
FDA – Food Safety Modernization Act
As you no doubt know, FSMA requires food companies to take a proactive, rather than a reactive, approach to food safety. This means doing everything you can to prevent contamination from happening in the first place.
Cleaning the floor using appropriate methods plays a major role in this effort. In fact, the FDA focuses on the floor in the “Sampling” chapter of its Investigations Operations Manual. In the section on environmental sampling, the manual provides three examples, two of which relate to the floor:
- A potential Salmonella harborage niche beneath a piece of food handling/processing equipment – does the firm periodically wet clean the floor (which could cause the organism to be sprayed onto exposed food)?
- On the floor in a corner of the production room – Did you observe activity that could cause the organism to be picked up by employee’s shoes, pallet mover wheels, forklift wheels, or could get onto the hands of employees who handle the equipment?
To learn more about the importance of floor cleaning, read our recent article: “How a clean floor prevents cross-contamination and boosts worker safety in food plants.”
USDA – Sanitation Performance Standards
The USDA’s Sanitation Performance Standards, based on the 1999 Food Code, provides guidelines for maintaining sanitary conditions in meat and poultry establishments. Section 6-501.13 addresses floor cleaning, specifying that only dustless methods must be used:
- Except as specified in (B) of this section, only dustless methods of cleaning shall be used, such as wet cleaning, vacuum cleaning, mopping with treated dust mops, or sweeping using a broom and dust-arresting compounds.
- Spills or drippage on floors that occur between normal floor cleaning times may be cleaned:
- Without the use of dust-arresting compounds; and
- In the case of liquid spills or drippage, with the use of a small amount of absorbent compound such as sawdust or diatomaceous earth applied immediately before spot cleaning.
Other sections address issues that can arise when walls aren’t properly cleaned and sanitized. For example, condensation on the wall of a processing area that could lead to product adulteration is identified as a “situation in which inspection program personnel must take action.”
OSHA – Walking-Working Surfaces
According to the National Floor Safety Institute, 85% of workers’ compensation claims are attributed to employees slipping on slick floors. 85%! That’s a huge number of workers’ comp claims that can be avoided by keeping the floors from becoming slippery.
OSHA’s Walking-Working Surfaces requirements are straightforward:
- The employer must ensure:
- (1) All places of employment, passageways, storerooms, service rooms, and walking-working surfaces are kept in a clean, orderly, and sanitary condition.
- (2) The floor of each workroom is maintained in a clean and, to the extent feasible, in a dry condition. When wet processes are used, drainage must be maintained and, to the extent feasible, dry standing places, such as false floors, platforms, and mats must be provided.
- (3) Walking-working surfaces are maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice.
OSHA – Combustible Dust National Emphasis Program
Slippery floors aren’t the only potential problems associated with improper cleaning. Courts have ruled that the general requirements above can also be used to issue citations under OSHA’s Combustible Dust NEP.
- If the facility being inspected under this NEP is not a grain handling facility, and the surface dust accumulations (i.e., dust accumulations outside the dust collection system or other containers, such as mixers) can create an explosion, deflagration or other fire hazard, then citations for violations of 29 CFR 1910.22 (housekeeping) shall be issued.
These are the main cleaning-related regulations most food facilities across the United States need to comply with. But, they’re not the only ones. Depending on your jurisdiction, you may also have state or local agencies as well as your insurance company imposing cleaning requirements. Read more about combustible dust compliance in A Food Manufacturer’s Guide to Fire Prevention Through Housekeeping: NFPA Codes & Standards You Need to Know.
What equipment do you need for cleaning compliance?
Every food plant and application is different. While OSHA regulations apply to all workplaces, food facilities may be subject to FDA or USDA regulation (or both), depending on the products they manufacture. But, ultimately, all of the regulations require the same thing: a high level of cleanliness to ensure food and worker safety.
There are four main categories of equipment that comprise a complete cleaning solution for food facilities:
- High pressure washers — for cleaning equipment, walls, etc. to prevent bacterial buildup and cross-contamination
- Industrial sweepers — for removing dust and other dry debris from the floors to prevent cross-contamination and slip-and-fall incidents
- Industrial scrubbers — for wet cleaning of floors with water and detergent to prevent bacterial buildup and cross-contamination
- Industrial vacuums — for removing dust from the floors, as well as overhead pipes and surfaces, to prevent cross-contamination, slip-and-fall incidents, and combustible dust buildup
To learn more about how cleaning can help you meet regulatory requirements, download our new eBook, 3 steps to cleaning compliance for your entire facility.
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