This article is written to meet the following sections of the Standards:
|BRCGS Food Safety Issue 8||4.11 Housekeeping and hygiene|
4.16.4 Vehicle cleaning
|BRCGS Packaging Issue 6||4.8 Housekeeping and hygiene|
5.10.4 Vehicle cleaning
|BRCGS Agents & Brokers Issue 3||Not applicable|
|BRCGS Storage & Distribution Issue 4||6.4 Housekeeping and hygiene (not 6.4.4 as this is training)|
16 Contract cleaning of baskets, roll cages and other distribution containers
|FSSC22000 Version 5.1||ISO 22000:2018 8.2.4 i) PRP – cleaning and disinfecting|
|IFS Food Version 7||4.10 Cleaning and disinfection|
|SQF Edition 9||11.2.5 Cleaning and sanitation|
The aim of cleaning is to prevent contamination from:
- Taints and odours.
- Foreign bodies.
The cleaning programme must cover:
- Product handling environment.
- Product handling equipment.
- Ceilings and roof voids.
- Overheads, wall ledges and pipework.
- Elevated walkways.
- Ventilation systems, including air socks and filters.
- Vehicles, tankers and containers.
- Loading and unloading equipment.
- Tools and bulky pieces of equipment such as waste bins.
A procedure for how the cleaning programme will be managed must be in place which includes the requirements for:
- The scope of cleaning.
- Cleaning risk assessment.
- Cleaning schedule.
- Provision of resources.
- Cleaning facilities and equipment.
- Cleaning procedures (CICs).
- Cleaning records.
Where cleaning of customer’s equipment is carried out, such as baskets or containers, the procedure must also include:
- The customer’s requirements.
- A routine review of customer-related KPIs.
The frequency and methods of cleaning must be based on risk.
To determine the frequency of each clean, you need to list all the items (and surfaces) to be cleaned. A method of how the risk assessment is going to be completed is needed. The method should clearly define how the frequency is determined. This means you need to determine what risk rating will result in what frequency, for example:
- High risk rating – weekly.
- Medium risk rating – monthly.
- Low risk rating – annually.
However, if you’re risk assessing a high-risk area, your risk ratings would result in more frequent cleans, for example:
- High risk rating – daily.
- Medium risk rating – weekly.
- Low risk rating – fortnightly.
The risk assessment method should consider aspects such as:
- The severity of the hazard that the clean is trying to remove.
- The likelihood of the item getting contaminated – as in the how fast it would get dirty.
The cleaning method needs to be developed so that it considers the risk of the hazard. For example, if the hazard is allergenic contamination – the cleaning method would need to be carried out precisely to remove all residues of allergenic material. Whereas the cleaning method to remove general debris wouldn’t need to be as precise or diligent.
The method once defined, also needs to be validated, to prove that it does remove the hazard in question – to the level needed.
The cleaning method must be based on good cleaning principles, which follow the six steps of cleaning:
- Gross debris removal.
- Detergent clean.
Cleaning methods should also be designed so that splashing or movement of debris is kept to a minimum.
Where high-level cleans take place (which would obviously create contamination that would affect the area underneath) the method needs to specify what precautions should be taken – such as protecting equipment from contamination.
Once the cleaning methods are defined, they must be validated to ensure that:
- There’s no risk of chemical residues.
- The acceptable limits are set for safety purposes, such as pathogen or allergen limits.
- Confirmation of the limits can be consistently achieved.
Re-validation must also take place when there’s a change to the method of cleaning, including the consumables or chemicals that are used.
A cleaning instruction card (CIC) is the term that’s generally used for a cleaning procedure. There needs to be a CIC in place for all product contact surfaces and equipment.
The CIC needs to include:
- A unique document reference.
- Who is responsible for cleaning.
- The item to be cleaned.
- How often the clean must be completed.
- A step-by-step method with relevant instructions and equipment needed.
- Chemical instructions.
- Cleaning checks, acceptable limits and any photographs of key inspection points.
That doesn’t mean you don’t need CICs for cleaning of non-product surfaces and equipment – you do. But the CIC doesn’t have to be as comprehensive, and the Standard doesn’t specify exactly what information it has to contain.
Where the item needs different types of cleaning, such as changeovers, daily and weekly cleans, the CIC must detail the method for each – or there needs to be a different CIC for each.
Cleaning must be checked to make sure that the clean has been done properly.
The check must be completed by defining limits of acceptable and unacceptable cleaning performance, based on the aim of the cleaning. For example, if the aim is to remove:
- Pathogens – pathogen testing should be considered.
- Allergens – allergen swabbing would be appropriate.
- Physical debris – visual inspection may be sufficient.
At a minimum, acceptable limits must be defined for product contact surfaces and equipment.
Acceptable limits must check worst-case or hard to clean areas, to prove that the whole clean has been effective.
Corrective action procedures must detail what to do when the acceptable limits aren’t met. Cleaning checks must be:
- Carried out by authorised and suitably trained personnel.
- Completed (at a minimum) on product contact surfaces and equipment prior to the restart of processing.
The completion of cleaning tasks and the checks following cleaning must be recorded. The cleaning and the check of that clean, can’t be completed by the same person.
Cleaning certificates must be in place as a record of cleaning, where:
- Cleaning is carried out by a contractor.
- Cleaning is carried out as a service for customers.
Once you’ve got all your cleaning instruction cards (CICs) done and your cleaning records ready, you need to train them out to everyone who will be doing the cleans and also anyone who will be verifying the cleans.
There will most likely be a lot of CICs to train out, to a large number of people. So, including the list of CICs on your training matrix will help you make sure you cover everyone that’s needed. And don’t forget to set a retraining frequency.
Cleans must be scheduled, to ensure that the resources are available and at the right time.
Cleaning should be planned for non-production periods if possible, but if it’s not – then suitable screening or other controls must be put in place.
Sufficient resources must be provided, to make sure that the cleaning schedule is achieved. This includes providing:
- The required amount of time for cleaning to be done.
- Trained staff to do the clean.
- Consumables, chemicals, utilities and equipment.
When choosing cleaning chemicals to use, you need to make sure that:
- They’re suitable for what you want to use them for.
- They’re not strongly scented.
The cleaning method, needs to ensure that the chemicals are:
- Used following the manufacturers’ instructions.
- Rinsed to remove chemical residues.
Staff need to be trained to make sure that chemicals are kept in closed, labelled containers which are stored so that they’re only accessible to those who are trained.
The equipment used for cleaning must be hygienic, fit for purpose and provided in sufficient quantities so that staff can meet the CICs.
Cleaning equipment for cleaning different surfaces must be separate, to prevent cross-contamination, for example:
- Product contact.
- Non-product contact.
- Floor contact.
The equipment must be colour-coded or at least labelled, so that it doesn’t get mixed up.
Before use, the equipment must be checked to make sure it’s not defective and after use, it must be cleaned and stored hygienically. Shadow boards are a great way of making sure that equipment is stored properly and that segregated (colour-coded) equipment isn’t stored together.
Any powered cleaning equipment must be maintained and monitored to make sure it’s effective.
Areas specifically used for cleaning must:
- Be segregated from product areas.
- Be designed so that dirty equipment doesn’t contaminate clean equipment.
- Have suitable drainage and ventilation.
When your cleaning programme is up and running, it’s not finished – it should constantly be in a state of review.
Use the verification of the cleans to see if the cleaning programme is working. If cleans are failing when they’re checked and having to be recleaned, this is an indication that the system isn’t working. Your task is then to find out why it isn’t working. It may be that:
- The training hasn’t been adequate.
- Enough time to complete the clean may not have been allocated.
- The cleaning method might not be right.
Non-conformances raised from GMP inspections or audits will also indicate if the cleaning programme is working.
The results of cleaning must be trended to identify trends for continuous improvement. This means that where verification checks of cleaning fails, this needs to be trended.
Where a negative trend is seen, the cleaning programme must be reviewed. And make sure when you carry out this review, that you document it. Because – if it’s not written down, in an auditor’s eyes it never happened.