Sanitation Controls

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Listeria Control Program

Sanitation Controls

Among the most significant efforts to periodically eliminate the repeated introduction of Listeria in frozen food facilities is the application of sound and robust cleaning and sanitation programs. This section includes guidelines to address drain cleaning, use of high pressured water, facility maintenance and construction and other adjacent activities that have the potential to threaten Listeria monocytogenes (Lm) control programs.

Sanitation Controls Recommendations

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A WELL-ROUNDED SANITATION TEAM

Roles and responsibilities for sanitation management and support are defined. Sanitation leadership and support groups are aligned; cross-functional communication is routine and frequent.

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ADJACENT PROCESSING LINE CLEANING

Adequate steps must be taken when cleaning equipment/areas that are in close proximity to other operational processing lines. A validated adjacent line cleaning process is documented and executed as designed and monitored.

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AUTOMATED CLEANING TECHNOLOGIES

Sanitation technologies are sufficient to effectively and efficiently clean equipment and the facility. Adequate systems (spray bars, COP, ACS, CIP) are provided to facilitate proper cleaning and sanitizing practices.

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BASICS OF CLEANING AND SANITATION

Employees receive GMP, sanitation and safety, HACCP, and other required training as well as job specific knowledge. Sanitors understand basics of food safety, sanitation and task requirements. Proficiencies are confirmed through testing or supervisory evaluation and qualification.

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BASICS OF CLEANING CHEMISTRY

Cleaning chemistry should be appropriate for soil, environment, water, surface, and method of application. Cleaning chemicals should be optimized and validated for effectiveness.

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BASICS OF MAINTAINING A DRY PRODUCTION ENVIRONMENT

If areas are dry, keep them dry during operation and sanitation. Sequenced dry cleaning processes (using necessary tools and methodology) are defined and stringently followed. Areas are monitored and maintained to ensure dry conditions in the environment. Zone barriers and operational and dry sanitation processes are maintained on a continuous basis and monitored appropriately

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BASICS OF SANITATION CHEMISTRY

Sanitizing chemistry should be appropriate for level of microbial lethality, method of application, type of microorganism and properties of the sanitizer. Sanitizers are optimized and validated for effectiveness.

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CLEAN-IN-PLACE CLEANING AND SANITATION

CIP systems are designed to control TACT parameters. System(s) are adequately monitored and managed. Raw and post lethality/high hygiene systems are separate. CIP circuits are interlocked to ensure compliance with TACT parameters and support cleaning requirements in a timely manner to support production needs. Facility expertise is sufficient to diagnose and troubleshoot performance as necessary. Systems are verified and validated on a routine basis.

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CONTROLLED USE OF WATER

Water pressures are controlled so that atomization is minimized. High pressure hoses are not utilized during equipment or drain cleaning. Sanitors are trained and monitored to control direction and quantity of rinsing in unison with sequential cleaning process requirements.

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ENSURING ROOF AND DRAIN SANITATION

Roof and drains are in good condition and good processes are established, readily available and deployed as necessary to address potential food safety risks arising from special circumstances.

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FLOOR AND DRAIN CLEANING

Documented drain cleaning programs are available. Properly labeled, stored, and restricted supplies and PPE are used. Cleaning drains in production areas during production should be avoided and always completed before cleaning equipment to avoid potential cross-contamination. All drains are mapped, adequately designed and maintained.

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INTRODUCTION TO ROUTINE CLEANING PROGRAMS

Sanitation programs are developed with cross-functional input based on experience with facility’s product and finished product. Sanitation processes consider product sensitivity/risk, hygienic design of equipment and facility, resources, industry/customer expectations and success criteria.

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MASTER SANITATION SCHEDULE

A comprehensive master sanitation program exists that references an SSOP for each task. Periodic equipment and infrastructure cleaning tasks are specified within the program. Master sanitation program is used to monitor schedule and resourcing, regularly measured for scheduled completion and evaluated for effectiveness.

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PERIODIC EQUIPMENT CLEANING

High risk equipment is disassembled, cleaned and assessed on a routine basis. Reviews are planned, documented and cross-functionally executed.

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PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS DURING SANITATION

Proper PPE is utilized and controlled to ensure employee safety and minimize potential cross-contamination.

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PRE-OPERATIONAL INSPECTIONS

All food contact equipment is inspected for cleanliness prior to starting production. Inspections are documented with corrective actions taken for non-conformance to standards. Results of ATP and APC swabs are trended and adjustments to sanitation procedures, training programs, or the facility/equipment are made based on data.

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SANITATION AND CONSTRUCTION

Construction processes are evaluated prior to project inception. Personnel (internal and external) involved in construction activities are trained and monitored to comply with GMP requirements. Areas under construction are isolated. Dedicated foot traffic patterns are established. Increased swabbing for pathogens is carried out during and after construction and equipment installation processes.

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SANITATION DURING TEMPORARY OR EMERGENCY REPAIRS

Maintenance responsibilities governing sanitation support, communications and compliance to food safety practices are identified and followed. Maintenance employees are trained in tool accountability and sanitation. Food safety preventive maintenance tasks are executed, lubrication is controlled, red-tag processes are deployed as needed Temporary repairs are followed by permanent solutions. Frequent communication and planning between maintenance, sanitation, QA and operations is a cultural expectation.

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SANITATION METHODS AND SUPPLIES

COP tanks and automated cleaning systems are sufficiently sized and monitored to support timely and effective cleaning. CIP circuits are interlocked to ensure compliance with TACT parameters and support cleaning requirements in a timely manner to support production needs. Systems are verified and validated on a routine basis.

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SANITATION TOOLS AND SUPPLIES

Sanitation tools and supplies are appropriately designed, stored, cleaned, monitored for condition and replaced when necessary. Evaluation conducted on a defined basis.

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SEQUENTIAL CLEANING AND SANITATION STEPS

A sequential approach to sanitation is employed to facilitate effective and efficient cleaning of the facility (equipment and infrastructure). SSOPs are defined for each routine cleaning task. SSOPs are current, sequenced through defined (i.e. 7-step or 4×4) methodology and readily available. Procedures provide step-by-step instructions for efficient and repeatable sanitation. Procedures describe tools, chemicals and concentrations, safety requirements and training needed are defined for each process. Photographs with appropriate detail are used to aid in training.

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SPECIAL CAUSE CLEANING

Procedures addressing special cause cleaning events such as roof leaks, drain overflow, zone breaches, and environmental positives are developed to mitigate and control potential food safety risks. All employees are trained and well-versed to execute these protocols as needed. Investigative cleaning processes arising from uncertain food safety risk situations.

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USING KEY PERFORMANCE INDICATORS FOR MEASURING SANITATION EFFECTIVENESS

Sanitation related metrics (KPIs) detail effectiveness and efficiency of sanitation controls and are used to track gaps as well as continuous improvement efforts.

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UTILIZING RED TAG PROCESS FOR REPAIRS

Food safety preventive maintenance tasks are executed and red-tag processes are deployed as needed. Temporary repairs are followed by implementation of permanent solutions.

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VALIDATION OF CLEANING AND SANITATION PROCESSES

Sanitation is monitored to provide timely feedback. Sanitation is verified to ensure consistent processes. Sanitation is validated to ensure the process is capable of delivering the desired level of cleanliness.

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