6. Contamination control
The effective use of chemicals
MSDS, technical specifications, chemical handling, effective use and validation of chemical cleans
The standards
This article is written to meet the following sections of the Standards:
| BRCGS Food Safety Issue 9 | 4.9.1 Chemical control |
| BRCGS Packaging Issue 6 | 4.9.3.1 Chemical control 5.9.7 Hazardous chemicals 4.8.3 Cleaning chemicals |
| BRCGS Agents & Brokers Issue 3 | Not applicable |
| BRCGS Storage & Distribution Issue 4 | 4.3.6 Chemical storage 7.4.3 Chemical control |
| FSSC22000 Version 5.1 | No specific clauses |
| IFS Food Version 7 | 4.10.8, 4.10.9 Chemical controls |
| SQF Edition 9 | 11.2.5.2, 11.2.5.3 Chemical control |
The requirements
Health and safety
When storing or handling any chemicals all local legislative requirements and site health and safety procedures must be followed.
Chemical procedure
A procedure must be in place to control the use, storage and handling of non-food chemicals to prevent chemical contamination and taints, which requires:
- An approved list of chemicals for purchase.
- Availability of material safety data sheets and technical specifications.
- Confirmation of suitability for use in a food-processing environment.
- Avoidance of strongly scented products.
- The labelling and/or identification of containers of chemicals at all times.
- A designated storage area with restricted access to authorised personnel.
- Use by trained personnel only, evidenced by training records.
- Spillage procedure.
Storage aspects already covered in chemical storage.
Chemical approval
Cleaning chemicals must be purchased from a reputable cleaning supplier and are appropriate to the specific cleaning tasks and compatible with the equipment/material being cleaned.
All post-harvest chemicals must be approved for the intended purpose. This must be supported by the relevant technical documents.
Approved chemical list
An approved chemical list is required to prevent inappropriate chemicals from being purchased. This must cover all chemicals used on site.
This applies to all:
- Non-food chemicals which may be used in product areas.
- All chemicals which are stored in the same areas (even if locked away) as product, materials and product equipment.
Material safety data sheets and technical specifications
Both material safety data sheets and technical specifications must be provided by the supplier. These documents must be up-to-date and confirm that the chemicals are suitable for use with food.
The material safety data sheet (MSDS or SDS) provides health and safety information. The technical specification contains information on how the chemical must be used effectively. Information from both the MSDS and the technical specification must be transferred into procedures for the safe and effective use of that chemical.
Product contact chemicals
Chemicals that are designed to come into direct contact with the product, such as equipment lubricants or disinfectant must be suitable for food use.
Product contact chemicals must adhere to the local regulations.
Taints
Pine, perfumed or strongly scented chemicals must not be used anywhere on site.
MSDS and chemical technical specifications must be used to verify that the materials does not contain phenolics, which could taint the product.
Where strongly scented chemicals are necessary for building work, procedures must be in place to avoid the risk of taint contamination of products. A documented risk assessment should be completed prior to commencement of the work and controls implemented to prevent product contamination.
Chemical storage
Bulk chemicals must be bunded and stored safely; so that acid and alkaline chemicals are stored apart, and powders are stored above liquids.
A separate locked cupboard or cabinet should be used to keep cleaning and maintenance materials segregated from food products.
Cleaning chemicals shall be in closed containers.
Any chemicals transferred from their original containers must be correctly labelled with the contents, appropriate hazard warning labels.
Chemical storage
Chemicals must be stored in a secure/locked-off area and not in food production areas.
Accidental use and chemical concentration
Non-edible chemicals must be:
- Locked away, to prevent them from being used by mistake, or by personnel who are not trained to handle them.
- Labelled, at all times.
- Stored separately from edible chemicals.
- Used according to the manufacturer’s instructions and any legal requirements
Where possible cleaning chemicals should be provided for use, already diluted, through dosing systems.
Manual or automatic chemical dilution must be checked routinely.
Where possible, chemicals must be automatically dosed into the system. However, where manual dilution is carried out, the vessels/spray bottles containing the solution must be appropriately labelled and concentrations checked as appropriate.
Environmental control
Environmental procedures must be in place to manage controls for:
- Spills.
- The safe, legal disposal or return, of obsolete or out-of-date chemicals and empty chemical containers.
BRCGS Food Safety Issue 9
4.9.1.1 This clause has been expanded to include handling of chemicals. The interpretation has been updated in line with the additions to the clause, to include chemical controls for environmental, and health and safety purposes.
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Contamination control
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Hello Kassy,
How would that work in terms of training records?
Would there be a need to have signed training records stating that personnel have been trained how to use chemicals so that they know both how to handle them safely and use effectively. Would it be enough to say that personnel read the instructions without having any signed training in place?
BRC Packaging issue 6 states 4.9.3.1 that “use by trained personnel only” but it does not state it must be evidenced by training records.
This area has been problematic as we use a by-product of one of our materials for cleaning. Usual cleaning chemicals are viewed as contaminants and absolutely will not be used on food contact surfaces but some auditors struggle to get their head round it (think whiskey or gin distilleries although these are not what we produce).
In our recent BRCGS audit this created a bit of an issue. Where we do use food grade and approved cleaning chemicals is for offices, toilets and staff rest rooms but the same level of detail was required for these areas as if they were food contact surfaces. This ended up as an NC. Has anyone else experienced this? i’d be interested in your thoughts on this.
Hi Carrie,
This sounds really interesting, but I’m struggling to understand properly. Can you add any more detail? Perhaps you could share the NC from your audit with any specific details redacted?
Kassy