This article is written to meet the following sections of the Standards:

BRCGS Food Safety Issue 84.9.1 Chemical control
BRCGS Packaging Issue 64.9.3.1 Chemical control
5.9.7 Hazardous chemicals
4.8.3 Cleaning chemicals
BRCGS Agents & Brokers Issue 3Not applicable
BRCGS Storage & Distribution Issue 44.3.6 Chemical storage
7.4.3 Chemical control
FSSC22000 Version 5.1No specific clauses
IFS Food Version 74.10.8, 4.10.9 Chemical controls
SQF Edition 911.2.5.2, 11.2.5.3 Chemical control

The aim of chemical control

Chemicals are needed, there’s no getting away from that. Without them, you wouldn’t be able to clean equipment – and unclean equipment would cause product contamination.

Also, you wouldn’t be able to lubricate equipment – and unlubricated equipment could cause metal on metal contact, which in turn could also cause product contamination. However, uncontrolled use of chemicals can also cause contamination to the product. So, the aim of chemical control is three-fold:

  1. You need to make sure the chemicals you use don’t pose a contamination risk.
  2. You need to make sure that the chemicals you use, are suitable for what you want to use them for.
  3. You need to make sure that the chemicals you use, are suitable for use in a food environment. Which means that they must comply with food regulations and they must not contain allergens.

This means that selecting the right chemical is key.

Selecting the right chemical

You need to select a chemical that will do the job that you want it to (this is known as ‘the application’).

Cleaning chemical control

Cleaning triangleIf the chemicals you’re using are for the purpose of cleaning, you need to consider what kind of clean you want to achieve and what conditions you want to clean under. To do this, it’s probably worth mentioning the cleaning triangle.

To clean effectively, you need three elements: temperature, time and friction. If you remove one of these elements – the clean won’t be effective.

You can adjust the balance of the elements and still achieve an effective clean. For example, you can lower the temperature of the water, if you increase the amount of time and friction. Or you could increase the temperature and friction and reduce the amount of time.

When you’re selecting a chemical for cleaning, you need to know how much time you have to clean, what temperature you can achieve and how much scrubbing (friction) you can apply.

Finally, you need to make sure that the chemical doesn’t cause a contamination problem, which means you need to know how to rinse the chemical off.

Chemical suppliers develop different chemicals to suit lots of different applications, so you need to know what you want, to be able to select the right chemical.

Engineering chemical control

If you’re wanting a chemical for engineering purposes, the same principles apply.  Many equipment manufacturers will recommend chemicals to use with their equipment, based on the needed functionality of the chemical. Using the wrong chemical (or lubricant) on a piece of equipment will mean that the lubricant doesn’t do the job it was intended for, resulting in failure of the equipment.

Engineering chemicals often include allergens, so you need to check this as well.

Operational chemical control

These tend to get forgotten, as they aren’t seen as chemicals. All chemicals, not just the ones you see typically as chemicals, such as cleaning chemicals or lubricants – need to be included.  To do this, you need a way of identifying what materials are ‘chemicals’.

What makes something a chemical?

The easiest way to do this is to look for the hazardous symbols. Any chemical, by law, has to have a hazard symbol – which explains how hazardous it is to people and the environment. Here are the symbols and their meanings:

http://www.hse.gov.uk/chemical-classification/labelling-packaging/hazard-symbols-hazard-pictograms.htm

Chemicals, which tend to get forgotten are things like:

  • Printing or coding inks.
  • Printer toners.
  • Paint.
  • Pesticides.
  • Glues.
  • Cooling chemicals, such as glycol.

Is it suitable?
Once you know what you want the chemical to do and you’ve selected one that’s suitable for the job you want it for, you then need to check to make sure it’s suitable for use with food. This means two things:

  1. It must meet the regulations with regard to chemicals suitable for food use.
  2. It must not contain allergens.

The law
In the EU there’s a piece of legislation that ensures that you can only use chemicals for food use, where they meet certain rules. This piece of legislation is called Regulation 1935/2004 and the following link provides details for the UK: www.food.gov.uk/business-guidance/food-contact-materials

In America the FDA provide similar guidance, which can be found at: www.fda.gov/food/food-ingredients-packaging/packaging-food-contact-substances-fcs

Using SDS and technical specifications

Once you’ve selected the right chemical and you’ve checked to make sure it’s suitable for use – you need to put a procedure in place for its use, which:

  1. Ensures that it’s safe to use from a health and safety point of view.
  2. Ensures that the chemical is effective, by following the manufacturer’s instructions.
  3. Ensures that it doesn’t pose a risk of chemical contamination.

SDS

An SDS is a safety data sheet. Sometimes also known as a MSDS – a material safety data sheet. This document contains all the information you need to ensure that it’s handled safely – so that it doesn’t put health and safety of personnel at risk.

It will explain H&S aspects such as:

  • What personal protective equipment is needed.
  • If there is an explosion risk.
  • Other hazards relating to people and how to control them.

This information should be used, to create a risk assessment for the safe use of the chemical and then, the risk assessment should be used to create a safe system of work. A safe system of work is basically a step-by-step instruction on how the chemical must be handled – safely.

Technical specification

When you know how to handle the chemical safely, then you need to use the technical specification to develop a method to use the chemical – so that it does what it’s intended to.

The SDS is all about using the chemical safely, whereas the technical specification contains the information about how to use the chemical effectively.

If it’s a cleaning chemical it will tell you what concentration is needed to use it, at what temperature, how long to leave it on (known as contact time), how much scrubbing to do and if it needs rinsing off afterwards. The technical specification may provide you with different methods for different applications, so you need to pick the right one for your application.

Also, it’s important to follow the instructions for cleaning chemicals because it will tell you if you have to rinse the chemical afterwards. If you need to rinse the chemical off and you don’t do this, you risk contaminating your product with chemical, especially if it’s a product contact surface you’re cleaning.

Validating that the cleaning procedure works

Validation is only for cleaning chemicals, you don’t typically need to validate other chemicals. You need to prove (validate) that the procedure you’ve developed works. To do this, you need to be clear on what you want to achieve:

  • Do you want it to provide a sterile surface?
  • Do you want it to remove allergen residue?
  • Or do you want it to achieve a target ATP swab result? (For example, of less than 100.)

Once you know what you’re trying to achieve, you then need to prove that the chemical does this using the method you’ve provided. To do this, you first need to prove that the surface you’re about to clean is contaminated.  So, you’d swab it – to prove it is.

Then, you do the clean following the instructions you’ve laid out in your procedure. Because you’re validating the chemical you would need to record all the key criteria, such as:

  • The chemical contraction you’ve used (how much chemical was mixed with how much water).
  • The temperature of the water used.
  • How long it was ‘scrubbed’ (friction) for.
  • How the friction was applied.
  • How long (exactly) the contact time was.
  • What temperature the rinse water was, how it was rinsed and for how long.
  • You also need to record the date, the time, who was involved, and who did the clean etc.

Once the clean is complete, you’ll then need to swab it again. Make sure that you swab any key inspection points, as these areas would be the most difficult to clean – so you need to validate that the clean works on them.

You only need to do this validation once unless something changes. If you change the method, or the equipment or if you change the chemical, then you’ll need to do it again.

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 of chemicals containers.
  • A designated storage area with restricted access to authorised personnel.
  • Use by trained personnel only, evidenced by training records.
  • Spillage procedure.

Approved chemical list

An approved chemical list is required to prevent inappropriate chemicals from being purchased. This applies to all non-food chemicals which may be used in product areas.

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.

As we’ve explained above, these documents must be used to establish if the chemical is fit for purpose and also how it should be used – safely and so that it doesn’t contaminate the product.

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

Strongly scented chemicals, or phenolics which may taint the product must not be used. Where strongly scented chemicals are necessary for building work, procedures must be in place to avoid the risk of taint contamination of products.

Chemical Storage

Cleaning chemicals must be secure and stored in closed containers. Bulk chemicals must be bunded and stored safely.

Accidental use

Chemicals must be labelled at all times, to prevent them from being used by mistake – or by personnel who aren’t trained to handle them.

Dilution

Where possible, cleaning chemicals should be provided for use; already diluted using dosing systems. The dilution of the chemicals must be checked routinely.

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Contamination control is one of the most important prerequisite controls, to support the Product Safety Plan and our eDocs are here to help you save valuable time.

Contamination control

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Allergens:
This pack includes a detailed procedure which explains how the allergen risk assessment will be carried out and how the allergen controls will be implemented. You’re also provided with detailed allergen controls, so all you need to do is identify which ones meet your needs, adapt and implement them.

Chemicals:
The pack details chemical verification, approval, storage, spills and training. Plus, utilities in the form of gas, air and water are covered too.

Glass, brittle plastics, and ceramics:
A risk assessment for glass, brittle plastics and ceramics is needed. Again this pack provides you with detailed instructions on how to carry out the risk assessment, using a decision tree which will define the frequency of the conditional-based checks that are needed. Once you’ve defined what needs checking and when, you’re provided with the records you need so you can populate and implement them.

If your site packs into glass, brittle plastic or ceramic containers – this is covered too, to ensure that the risk of containers contaminating the product is controlled.

Metal sharps:
Finally, metal sharps for items like knives, wood control and other hazards are also included.

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Have your say…

2 thoughts on “The effective use of chemicals

  1. 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.

    1. 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

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