A compliance audit is often an anxious time for a food and beverage facility manager. The last thing that manager wants is a shutdown, let alone one that could have been avoided by making a simple proactive coatings repair, for example. Yet, violations of the Food Safety Modernization Act (FSMA) flagged by a third-party compliance auditor are common and can lead to major operations interruptions if the problems cannot be remedied quickly.
The likelihood of flagged issues and stalled operations has risen in today’s environment of higher industry standards. This is evident in the amount of product flagged for contamination. Foreign-material contamination caused 23% of all recalls in 2018, up from 7% in 2015, according to a report published in The National Provisioner. Has the industry become more lax about allowing contaminants into food products? No; the more likely interpretation is that today’s stringent regulations lead auditors—and facilities themselves—to catch potential dangers previously left unchecked.
With companies of all sizes now in compliance with the more rigorous FSMA, the question becomes how well they can maintain these standards. That will be determined, in part, by company culture. In some companies, teams will do the minimum to remain compliant, making incremental updates just before an audit or emergency corrections thereafter to avoid a shutdown. This may be especially true for mid-sized companies, where a plant manager does not have the time or expertise to identify the optimal coatings products to fix specific conditions, for example. Most generalist facility managers will not know which floor coatings offer a fast return to service to minimize downtime or which wall coatings are the most durable against chemical washdowns.
However, in other companies, teams will adopt a more proactive approach. The facility manager will not wait for an auditor to point to a problem or learn on the fly how to repair an area. Instead, the manager will work with stakeholders and a third-party coatings expert, for example, to spot not just current violations, but also future vulnerabilities, and to develop proactive repair specs so the facility can address any deficiencies before they become an issue. As such parties anticipate how a facility could someday risk contamination or hazards, the facility manager will not only minimize the facility’s chance of FSMA infractions but will also create long-term peace of mind.
Four Key FSMA Audit Areas
One way for a facility manager to plan ahead is to take on the mindset, and even the checklist, of an auditor. By performing self-assessment walk-throughs that consider hazard analysis, sanitation, equipment preservation, and warehouse and distribution matters, the manager will mirror the checklist an auditor uses when visiting sites. This approach allows the manager not only to see current problems, but also to envision and create a strategy for future issues. By inviting a third-party coatings expert to participate in the assessment, the facility manager can better identify potential vulnerabilities, learn what products will enable fast returns to service and long maintenance intervals, and develop a proactive plan for making repairs.
1. Hazard Analysis & Controls
Personnel, hand carts, forklifts, and other machinery create heavy traffic throughout a facility, so one aim of a FSMA audit is to minimize the risk of employee injury. A coatings specialist can be especially helpful to a facility manager here by suggesting products that will limit injury risks related to slips from flooring hazards or burns from hot surfaces.
Slips and falls are among the primary hazards to employees. Although FSMA does not set any specific floor skid-resistance standards, a facility manager will want to work with a coatings specialist to determine what surface treatments can reduce the chance of unfortunate incidents, yet still meet other facility objectives. Skid-resistance options range from aluminum oxide to sand to a quick-texture system, a splatter coat created by a hopper gun. The latter is especially advantageous, as it establishes skid resistance, but without the pointy profiles that occur with other broadcast aggregates. The rounded, quick-texture profile allows better drainage following wash-downs and is potentially more durable, as pointier profiles created by other aggregates may break off over time.
Tripping hazards can develop when floor quarry tiles or dairy bricks—which are commonly found in food facilities—become uneven, in some instances because water has ponded beneath them and worked them loose, leaving bumps and voids in the flooring. Beyond contributing to falls, such voids can become harborage points for bacteria, and a facility may fail inspection if these areas are not corrected. A facility manager can mitigate both slipping and sanitation concerns by installing a seamless resinous flooring system at the outset of a flooring installation or on top of quarry tile or dairy brick. Such floors offer better drainage, provided the floor has a proper slope, and eliminate grout lines, which trap moisture and promote bacteria growth.
To minimize the risk of another hazard such as burns, a facility manager should look at any area where a worker may come into contact with a heated surface, from piping to tanks, and treat it with a heat-resistant insulative coating. Such coatings allow otherwise hot surfaces to remain cool to the touch without insulation applied, while also providing some insulative properties that will retain heat inside the pipe or vessel. Using coatings instead of insulation also removes the opportunity for corrosion to develop beneath insulation, which can be a hidden and potentially dangerous development.
2. Sanitary Facilities & Controls
Bacteria and allergens are a serious concern for any facility because they jeopardize food products with contamination and cross-contamination potential, respectively. An FSMA auditor tests extensively for these unwanted contaminants, knowing that, despite cleaning protocols, nut material, for example, can get lodged in walls and floors, and then days later, potentially dislodge and end up in another product. For a facility manager developing a preventive maintenance program, the aim should be to eliminate any risks from bacteria and allergens. The focus for both will be to ensure proper water management and eliminate porous surfaces
Facilities are washed down regularly, but how much of the water and chemicals, potentially loaded with bacteria and allergens, make their way to the drains? It is critical to prevent these fluids from ponding behind the walls or under the floor. A coatings specialist can suggest the right products to create seamless systems for these surfaces. In a facility with block walls, for instance, a specialist might suggest using block filler to reduce any divots where allergens can rest before applying a smooth topcoat material designed for washdowns.
Consider also the transition from walls to floors. The crevice of a 90-degree transition makes it easy for bacteria to lodge and remain there following cleaning processes. However, a cove or cant base, with its curved or 45-degree transition, respectively, from wall to floor, creates a seamless floor-to-wall transition and slope that enables more thorough draining and better hygiene following cleanings.
Of course, the end destination for cleaning water is the drain, which is why the floor must have a proper slope that allows fluids to drain away. A cove or cant base helps with this movement at the wall, as does the design of the drain itself. For example, many facilities are transitioning from trench to box drains because the former has more surface area where water and microbes can lodge and allow bacteria to proliferate. Installing a box drain will limit contamination; however, to ensure proper drainage, the floor surrounding the box drain must be re-pitched a quarter inch for every foot that fluids must fall from the edge of the wall.
3. Equipment Preservation
Food and beverage facilities are rife with steel—metal ceilings, railings, columns, and more—found above and near production lines and packaging operations. As steel wears, rust and paint chips can break loose and potentially drop into products. This is one reason why an FSMA auditor closely inspects any steel along a product’s path through a facility. A facility manager should also trace those paths, across every floor and up every stairwell, looking for exposure risks and treating the steel with proper coatings. Coated steel is not only better at resisting corrosion and rust, but also easier to clean.
FDA sets specific standards for which coatings may be applied to steel, and those conditions vary based on whether the steel has direct or indirect contact with food products. For example, grain elevators and storage silos, which store dry goods, must comply with the 21 CFR 175.300 standard. While a facility manager might not be familiar with the entirety of FDA regulations on these matters, a third-party coatings expert will be able to supply that knowledge and recommend appropriate products.
4. Warehouse & Distribution
At most food and beverage facilities, ingredients and finished products sit in a warehouse where high traffic and outdoor access might invite some undesirable agents such as dust mites, bugs, and rodents. In such areas, the right surfaces can help to stave off critters or identify their presence. For instance, sealer placed on a concrete floor makes the surface more cleanable, so dust comes up during washing, which minimizes mites. A run identification strip, a set of white lines painted on the floor around the perimeter of a warehouse, creates contrast so that workers can spot rodent droppings against the light floor surface. In addition, seamless flooring systems reduce the cracks and crevices that bugs nestle within. For each of these matters, a coatings specialist can recommend ideal solutions.
In cold storage and processing areas, a facility manager needs to be concerned about contamination from insulated metal panels (IMPs), as their factory-applied finish may flake off over time. One way to protect this material is to apply polyurea, a chemical-resistant waterproofing membrane that fills cracks and joints and limits flaking. However, not all contactors have the plural-component equipment needed to spray such coatings. A coatings specialist can help facilities identify contractors for the project, which can be completed in one weekend, even at low temperatures.
Establish a Proactive Plan
With so many ways to prepare ahead, there is no reason a facility manager should let an auditor’s visit become a nail-biting experience. Instead, a manager can work directly with a coatings specialist to walk through the facility together, identify any areas of current and future concern, and create a proactive plan to rapidly address repairs as needs arise, especially if an auditor raises an issue. The proactive approach of thinking like an auditor will help the facility maintain compliance and avoid costly fines and shutdowns.