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Are Your Sanitation Chemicals Audit-Ready?

July 11, 2017 • By Matt Prine

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Cleaning chemicals are at the core of any food plant sanitation program. Safe and successful food production depends on using chemicals properly to clean and sanitize all processing areas. There’s little room for error when it comes to managing sanitation products—especially when auditors come calling.

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Real-time titration of sanitation chemicals prior to use helps ensure products are effective and comply with audit requirements.
Image credit: PSSI

Audits are ever-present in the food industry. Some are industry driven, such as Global Food Safety Initiative and Safe Quality Food audits. Government regulations trigger USDA, FDA, and Occupational Safety and Health Administration (OSHA) inspections. And customers may require yet another round of audits and inspections at your plant.

Each of these audits may cover different aspects of food production. But regardless of the type of inspection, you can expect plant sanitation and chemicals to come under scrutiny. The best way to prepare for any potential audit is to always follow chemical handling best practices and document them religiously from start to finish.

Chemistry 101

The basics of chemical handling are simple—use the right chemicals, at the right place, and in the right amount. It’s critical to adhere to the chemical product label, which specifies what the product is to be used for and how it should be mixed and stored.

Make sure your operation doesn’t have in-plant “chemists” who create their own cleaning concoctions. For example, mixing bleach and quaternary ammonium together can be an effective detergent for removing tough colored soil, like tomato-based sauce. However, the bleach label does not allow it to be combined with other chemicals. Any product mixing that’s not listed in label directions will be a red flag in case of audit. Plus, mixing incompatible chemicals, such as chlorine with acid, could produce toxic gases and safety hazards for employees.

All cleaners and sanitizers within the plant must be used for the purpose on the label—not to clean the parking lot, for example. Always stay “on-script” to stay audit-ready.

Some’s Good, More’s Better? Not.

This old-school saying would be a definite red flag for auditors. Always stay within concentration ranges specified on the chemical label for the product and how it’s being used. Lower concentrations may not effectively sanitize the food production area. Higher concentrations would be wasteful and costly.

Also keep in mind that the U.S. EPA classifies disinfectants and sanitizers as pesticides because they control microbes in the environment. Using a higher-than-labeled chemical concentration could risk EPA action against your plant—and risk food contamination.

The only way to know for sure that you are using correct chemical concentrations is through titrations to verify products have been mixed with the proper amount of water. Titration data is one of the key metrics that inspectors will look for during an audit of your chemicals.

Real-time titrations are recommended. Here’s why: If you mix and use a chemical product on a Monday and don’t run titration tests until Wednesday, you may have spent two days using the wrong concentration. That could jeopardize food safety as well as raise issues at inspection time.

Even before mixing and titration, make sure to use chemicals only from a licensed chemical blending facility. Look for a company that provides technical support and supplies high quality dispensers and foamers to ensure proper product application. Also, ask your chemical supplier about its quality control procedures. Ideally the chemical manufacturer or blender should test each lot for purity and potency prior to shipment.

Don’t Overlook Your H2O

An often-overlooked factor in sanitation chemical efficacy is water quality. Test water at least once a year and anytime your municipality notifies you of changes in the water supply.

Water hardness is one of the key factors affecting cleaning products. Between zero and 4 grains is considered soft water and above 7 grains is considered hard water. Chemical labels will outline the product’s effectiveness based on different hardness levels.

Mineral-based impurities also adversely affect cleaning and sanitizing. Iron, manganese, chlorides and silica can cause staining, corrosion, or filming.

Expect an auditor to test a water sample from the chemical mixing area to verify your chemical program aligns with onsite water conditions. To be prepared, work with your chemical supplier to adjust your chemicals or water supply as needed for optimal efficacy.

Store Chemicals for Safety and Efficacy

Storage is another issue for inspectors, from efficacy as well as worker safety standpoints.

To ensure efficacy, always store chemicals in securely locked containers to prevent product tampering, contamination, or degradation. Store chemical drums and totes in well-ventilated, well-drained areas. Keep them away from sunlight or heat, which can cause oxidation that in turn reduces product potency.

Make sure all chemical containers are labeled. Every bucket or jug used to mix chemicals must have a tag identifying the product or product mixture that it contains. Frequently tour your plant and look for unlabeled materials. Any chemical container without a label is a food and worker safety risk because it creates the potential for its contents to be used improperly.

To ensure worker safety, store different types of chemicals in separate areas to prevent cross-contamination or toxic mixtures.

Don’t forget to monitor secondary containment—pallets or other structures meant to control spills or leakage from chemical drums or totes. Make sure the secondary containment is rated appropriately for the materials being stored and has no dents, cracks, or punctures that could cause products to leak through. Be aware of local requirements regarding secondary containment, as regulations can vary from state to state.

Training for Success

You want your plant clean and sanitized for the next day’s production. And above all, you want your sanitation crew to go home safely. Regardless of whether you have an in-house sanitation crew or use a contract sanitation supplier, make sure all workers have a clear understanding of cleaning procedures and how to use chemicals safely and correctly.

Training should cover chemistry basics, including proper storage, mixing, and labeling. Help workers understand the importance of personal protective equipment and how to respond in case of an accident or product spill. Include training on how to operate eyewash stations and showers.

As much as possible, make these training sessions interactive with hands-on experiences. When training, keep language barriers in mind and translate materials into Spanish or other languages that are appropriate for the sanitation employee population.

Once workers are trained, they must be well supervised in the food facility to ensure that all chemicals are handled and applied safely and completely.

Even after training has taken place, continue with frequent, ongoing refresher sessions to avoid procedural drift. And document each session, what it covered and who participated.

Audit-Readiness Means Safe Food

A modern, compliant food facility depends on the often-complex world of sanitation chemicals. Following sanitation best practices at all times will not only keep your plant audit-ready, you’ll have satisfied customers and a productive work force. And when an inspector shows up at your door, keep in mind that audits are really for your benefit—to ensure you can continue to supply your customers with safe, high-quality food products.


Prine is the food safety director at Packers Chemical. Prine and his team work closely with counterparts at Packers Sanitation Services, Inc. (PSSI). Reach him at matt@packerschemical.com

Ted Moffett (tmoffett@pssi.co), PSSI food safety director and Steve Weiland (sweiland@pssi.co), PSSI corporate microbiologist, also contributed to this article.

Prove It with This Paperwork!

From an auditor’s perspective, if a procedure isn’t documented it never happened. To stay audit-ready, keep the following sanitation program documents on site and available for inspection.

  • Master Sanitation Schedule that details the timetable for cleaning food production areas.
  • Safety Data Sheet (SDS) for every cleaning product, posted where workers can see them. The SDS lists important safety information including precautions and potential hazards that employees should be aware of.
  • Technical Data Sheet from the manufacturer that includes product specifications and instructions for use and disposal.
  • Cleaning Procedure Manual, describing how to clean the facility and what chemicals are used. This manual should also document how employees are trained to handle and apply chemicals.
  • Chemical Inventory Record, documenting chemicals on hand and titration data showing they are used in legal, safe ranges.
  • Letter of Guarantee from the chemical supplier to certify the company delivered the correct products to the facility.

Most food processing plants maintain these documents as paper copies, usually in a binder. Others are moving to electronic copies for ease of updating. It is still a good idea to print out hard copies because auditors may not have easy access to your computer system to view the digital files.

Regardless of how you store paperwork, be sure to update the documents anytime you change the plant’s sanitation program or chemicals. A contract sanitation provider can take responsibility for maintaining these important records.—M.P.

Filed Under: Auditing/Validation, Safety & Sanitation, Sanitizing Tagged With: Audit, Chemicals, Food Quality, Food Safety, Food safety audit, sanitation chemicals

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