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Is Your Plant FSMA Compliant? 5 Considerations for Proactive Plant Maintenance



The FDA Food Safety Modernization Act (FSMA) is a law that requires food processing facilities to analyze potential hazards and implement risk-based preventive controls. Part of the legislation includes the definition of current Good Manufacturing Practices (cGMPs) intended to reduce the risk of foodborne illness caused by contamination in food processing facilities.     

This requirement to be proactive includes provisions such as:

  • Having a food safety plan in place.
  • Ensuring that all employees are qualified.
  • Providing training on hygiene and food safety.
  • Addressing allergen cross-contact.

Facilities are required to have a written plan in place for preventive controls that address the potential hazards that were identified. Depending on the food being processed, these might include:

  • Process controls such as cooking, refrigerating, and acidifying foods.
  • Food allergen controls to eliminate cross-contact and ensure proper labeling.
  • Sanitation controls to prevent hazards such as pathogens and food allergens.

In addition to having a written plan and providing ongoing training, proactive plant maintenance can help reduce the risk of contamination from environmental pathogens and prevent the growth of biofilms. When creating your preventive maintenance plan, take these five considerations into account.

1. Understand the difference between cleaning and sanitation

Daily cleaning protocols are common in the industry, but cleaning is not the same as sanitation. Cleaning is intended to remove visible dirt, food, debris, and residue from surfaces and equipment. Although this is a good practice that is important to maintain, cleaning does not reduce or eliminate bacteria. Sanitation uses chemicals to reduce the number of bacteria on a surface to safe levels. Although they are different, cleaning and sanitation go hand in hand. Surfaces must first be cleaned with a detergent before they can be sanitized. The detergent should then be completely removed through rinsing because any remaining residue could impact the efficacy of the sanitizer. Follow the manufacturer’s recommendations for dilution of the sanitizer and whether it should be rinsed with potable water or left to air dry.  

2. Use regular sanitation procedures and practices

When it comes to preventing the growth of pathogens, monthly deep cleaning is not sufficient. In the time between sanitation procedures, bacteria will be allowed to grow and spread. Daily sanitation protocols will help prevent the growth of environmental pathogens and the formation of biofilms. By regularly reducing bacteria to safe levels, facilities reduce both short- and long-term risks of contamination and food recalls.

3. Train employees on proper sanitation procedures and practices

The FDA estimates that about one-third of food recalls related to GMPs are because of inadequate training. This is perhaps one reason that documented training and education is a requirement under the FSMA. In addition to personal cleanliness and hygiene, training should also cover sanitation procedures and practices designed to prevent outbreaks. To ensure compliance, training should be documented with the date and time, a description of the material covered, the name and signature of each employee present, and the trainer’s name and qualifications.  

4. Test for pathogens to prevent outbreaks

Monitoring is a critical practice for ensuring that sanitation procedures and practices are effective. This includes ATP testing before and after sanitation to confirm that the targeted bacteria were reduced to a safe level. Document each test and maintain a record for future reference and compliance.

5. Perform corrective actions

When sanitation targets are not achieved, document the details and take the necessary steps to bring pathogen counts to a safe level. This might include repeating a daily sanitation procedure, scheduling a deep clean, or following a disinfection protocol to eliminate the bacteria that are present.

Using the sanitizer D7 on a daily basis helps reduce the risk of an outbreak because bacteria are consistently brought to a safe level. Effective against the most common foodborne pathogens, D7 enables efficient sanitation through the application of foam that adheres to ceilings and vertical surfaces. This provides maximum surface contact time to allow the solution to work.

The Busy FSQA Manager's Guide to Proactive Plant Sanitation