A compliance auditor arriving with a clipboard in hand could be a food and beverage facility manager’s worst nightmare. No matter how well the facility operates, the inspector is likely to find something that will need to be addressed. Then the facility will need to quickly correct any flagged deficiencies so it can maintain compliance and continue operations. If it’s not prepared to fast-track the required repairs, the facility may risk a potential shutdown.
Explore this issueOctober/November 2017
As part of the FDA Food Safety Modernization Act (FSMA), food and beverage facilities are required to implement preventive control plans that describe how they will correct any problems that arise. These plans are designed to expedite repairs so facilities can quickly return to compliance. For example, having repair specifications already in place for rehabilitating and recoating concrete structures will allow a facility to take immediate corrective actions—such as issuing a detailed bid for repairs—following a compliance issue. Being able to initiate repairs this quickly improves the likelihood that the facility will be able to restore compliance within the three- to four-week window auditors typically mandate.
To prepare a comprehensive preventive control plan, facility managers may be best served by taking a page out of the compliance auditor’s playbook and conducting a detailed facility evaluation of their own. Conducting a proactive facility evaluation, which is recommended to be performed with a reliable third-party coatings expert in tow, will allow the facility to write repair specifications for the wide array of environments found throughout its operations—and potentially correct issues prior to an official audit to avoid compliance citations.
This article focuses on compliance issues related to assets and areas of food and beverage facilities that feature industrial coatings.
Performing an Expert-Guided Facility Evaluation
Part of the FSMA directive requires facilities to perform periodic audits of their own to document and proactively address non-conformances throughout the year, not just at audit time. However, internal staff may not have the expertise to properly assess all areas of concern. That’s where an expert—like a NACE-Certified Coatings Professional—can deliver significant value by participating in a detailed facility evaluation.
A certified coatings professional will be able to identify the optimal coating systems to use for specific facility environments and applications to ensure longer service lives and reduced maintenance needs. For example, internal staff may think an epoxy-based system is the most appropriate material for patching floors in a wet processing area. But the coatings professional will know that epoxies are prone to cracking and flaking in wet environments exposed to frequent wash downs and thermal cycling. The coatings professional would therefore recommend repairing the area with a urethane concrete-based system, which will expand and contract with the concrete substrate below, offering less opportunity for cracking, less potential for bacteria to grow under loose coatings, and a longer service life.
Like an FSMA audit, a comprehensive facility evaluation with a coatings professional will cover the entire site. However, the coatings professional will only focus on those assets and areas that require industrial coatings, such as wet and dry processing areas, mechanical equipment rooms, chemical storage areas, cold storage areas, warehouses, storage silos, employee welfare zones, water and wastewater treatment structures, and other areas that require coatings solutions that are suitable for use in USDA-/FDA-inspected facilities.
The certified coatings professional will often walk the facility with representatives from the sanitation, engineering, and maintenance departments, looking for any areas of concern. These stakeholders are vital participants, as they are intimately involved in audit and repair processes. Sanitation managers often deal directly with FDA or other third-party auditors and will know what needs to be fixed and by when. Facility engineers and plant managers oversee coatings recommendations, specifications, timing, and budgets. In addition, maintenance managers are responsible for scheduling and completing the repairs.
During an evaluation, this multi-disciplined group may address deficiencies like rusty equipment, peeling or flaking paint, porous surfaces that can harbor bacteria, and improperly sloped drains. For example, a facility won’t pass inspection when peeling paint and rust are evident, so the coatings professional will be watching carefully for even early signs of corrosion. In addition, the professional will examine floors to determine if they are sloped properly to drains to eliminate standing water and reduce slip/fall hazards. It may also be noted where it would be helpful to incorporate a cove base to ensure a seamless transition from floors to walls and thereby eliminate a common harborage point for bacteria.
Preparing Facility-Wide Coatings Repair Specifications
Following an evaluation with a certified coatings professional, a facility will receive a detailed report that includes coatings repair specification recommendations for every area of the facility reviewed, based on that environment’s specific needs. As noted above, the recommended repair specification for patching a floor in a wet processing area will list urethane concrete systems as the materials of choice rather than epoxy systems, which are prone to premature failure in wet environments. Specifications for chemical storage room repairs may include impact- and chemical-resistant coatings, as these environments are prone to damage from forklifts and barrels. Specifications to repair insulated metal panel wall systems found in coolers may list different impact- and chemical-resistant coating systems rated for low temperatures.
Professionally prepared specifications may also include quotes for various levels of repairs based on service life, functionality, cost, and timing expectations, as well as a list of qualified contractors for bidding purposes. Ultimately, repair specification recommendations are intended to promote long-term solutions, not just quick fixes to pass an upcoming inspection. However, it’s helpful for a facility to have a range of good/better/best repair scenarios, along with general pricing so managers can determine the best option based on all the variables in play. For instance, they may choose to make a faster, less robust repair initially to ensure a quick return to compliance during busy times and then opt to make a longer-term repair during scheduled downtimes for maintenance.
From a relationship standpoint, a formal evaluation and specification provided by a coatings supplier can further help with expediting repairs. When a facility is already set up in the supplier’s system, it can reference the repair specification, place an order, and likely address repairs sooner than if the facility needed the supplier to first visit a site and make recommendations before ordering repair materials.
Regardless of which actions a facility takes to make repairs and return to compliance, the repair specifications provided following a professional evaluation will help the facility comply with FSMA requirements to implement preventive control plans. The specifications establish an in-house plan of action to address deficiencies and audit citations. They also enable the facility to take a proactive approach to addressing repairs as opposed to only making reactive repairs based on audit reports. In addition, a company can extend its repair specifications to other facilities to create standardized preventive control plans across multiple facilities and environments. Doing so can potentially lead to greater efficiencies, including streamlined bid preparations, consolidation of suppliers, pricing reductions, and faster repairs.
Planning for the Official Compliance Audit
Following a comprehensive facility evaluation with a certified coatings professional and the receipt of comprehensive repair specifications, a food and beverage facility will be able to take the guesswork out of which coatings are the most suitable for each environment throughout its operations. The facility will be poised to implement a preventive control plan designed to reduce repair timelines before and after audits. It will also have the benefit of standardized specifications that can be shared company-wide, enabling the parent company to streamline processes for ordering products and maintaining just-in-time deliveries, as well as for proactively identifying approved contractors to expedite repairs. Finally, the facility will have the potential to reduce long-term maintenance costs and reduce downtime by selecting the best repair options and products suited to each environment to promote longevity.
With coatings repair specifications from a qualified professional in hand, food and beverage facilities will be ready to address nearly any required repair that may arise during an audit. Better yet, they’ll be prepared to address areas of concern prior to audits to avoid citations. In fact, the coatings professional’s recommendations will include suggestions to make any necessary repairspart of the facility’s ongoing maintenance program so the repairs can be completed prior to actual FDA or other third-party audits. As a result, the audit process will be even less stressful, and the facility will have fewer compliance items to address after the auditor has completed his checklist.
Dolton is regional market segment director—Food and Beverage/Pharma for Sherwin-Williams Protective & Marine Coatings. Reach her at Rebecca.L.Dolton@sherwin.com.