The cleaning programme

Contents

• The standards.
• The requirements.
• BRCGS Food Safety Issue 9.

The standards

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

BRCGS Food Safety Issue 9	4.6.5 Storage of equipment 4.11 Housekeeping and hygiene 4.16.4 Vehicle maintenance and hygiene
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 requirements

Scope

A cleaning programme must be in place which ensures that facilities and equipment are kept in a suitably hygienic condition. The aim of cleaning is to prevent:

• Allergenic contamination
• Microbiological contamination which may lead to food poisoning or spoilage
• Taints and odours
• Physical contamination including product debris and integrity of claims
• Chemical contamination
• The attraction of pests

The minimum scope of the cleaning programme must cover:

• Product handling environment.
• Ceilings and roof voids.
• Overheads, wall ledges and pipework.
• Elevated walkways.
• Ventilation systems, including air socks and filters.
• Product handling equipment.
• Vehicles, tankers and containers.
• Loading and unloading equipment.

 

Procedure

A procedure for how the cleaning programme will be managed must be in place which details the requirements for:

• The scope of cleaning.
• Cleaning risk assessment.
• Cleaning schedule.
• Provision of resources.
• Cleaning facilities and equipment.
• Cleaning procedures (CICs).
• Cleaning records.
• Validation.
• Monitoring.
• Review.

Where cleaning of customer’s equipment is carried out, such as baskets or containers, the procedure must include:

• Customers requirements.
• Routine assessment against customer requirements (e.g. KPIs, customer reviews).

 

Risk assessment

The frequency and methods of cleaning must be based on risk.

 

Schedule

Cleans must be scheduled, to ensure that:

• The required amount of time is planned, as defined by the CICs (Cleaning Instruction Card).
• The required amount of human resource and consumables are available.
• Engineering support is organised where needed.
• Any specialist equipment is available.
• Cleaning is planned for non-production periods where necessary.
• Suitable screening or other controls can be applied, where there is a risk of contamination to product or equipment.

 

Resources

Sufficient resources must be provided, to ensure that the cleaning schedule is achieved, including:

• Allocation of time.
• Provision of human resource.
• Cleaning consumables, chemicals, utilities and equipment.
• Training.

 

Cleaning chemicals

Cleaning chemicals must be:

• Assessed to make sure they are suitable for the application.
• Assessed to ensure that they are not strongly scented, which could cause taints.
• Assessed, taking into account what is going to be cleaned, and what the surface is made from – to make sure it won’t negatively impact the integrity of the material.
• Used in accordance with manufacturers’ instructions, so that they achieve the required clean.
• Rinsed according to the manufacturer’s instructions, so remove chemical residues.
• Kept in closed containers, to reduce the risk of spills.
• Labelled so they don’t get used by mistake.
• Stored in a designated and secure location, so that they are only accessible to trained personnel.

 

Cleaning equipment

The equipment used for cleaning must be:

• Hygienically designed, so that it can be kept clean.
• Fit for purpose, so that it doesn’t become a foreign body risk.
• Colour coded or labelled, so that it’s clearly identifiable for its intended use.
• Provided so that there is sufficient quantities to segregate it for it’s intended use.
• Separate equipment must be provided for product contact and non-product contact cleaning.
• Equipment used for cleaning toilets must be separate from equipment used in product areas.
• Cleaned after use and stored in a hygienic manner.
• Checked prior to use to ensure that it’s not defective.

Automatic cleaning equipment must be:

• Maintained at a set frequency.
• Checked before use to make sure it’s working.
• Removed from service until it’s repaired – where it’s found to be defective.
• Monitored to ensure it’s effective, e.g. temperature, chemical strength.

 

Cleaning facilities

Areas specifically used for cleaning must:

• Be segregated from product areas to prevent cross-contamination.
• Be designed so that the layout and flow of equipment in the area ensures segregation of clean and dirty equipment.
• Have suitable drainage in place, to prevent pooling of water.
• Have adequate ventilation to prevent condensation from cause mould growth.

 

Cleaning checks

Cleaning must be checked to ensure that the aim has been achieved.  This is achieved by setting limits of acceptable and unacceptable cleaning performance, based on the aim of the cleaning. For example if the aim is to remove:

• Pathogenic contamination, then pathogen testing should be considered.
• Allergenic contamination, then allergen swabbing would be appropriate.
• Physical debris, then 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 are not 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.

 

Validation

Cleaning methods must be validated to ensure that:

• There is no risk of chemical residues.
• To confirm acceptable limits which are designed for safety (pathogens or allergens) can be consistently achieved.

 

CICs

Cleaning procedures (CICs) for product contact surfaces and equipment must include:

• A unique document reference.
• The role which is responsible for completing the cleaning task.
• The equipment or area to be cleaned.
• How often the clean must be completed.
• The method of cleaning.
• Any relevant instructions for dismantling the equipment.
• Photographs to highlighting areas that are difficult to clean.
• Cleaning chemicals, concentrations and instructions for use.
• Cleaning equipment and consumables to be used.
• Any personal protective equipment (PPE) to be used.
• Which cleaning records to complete and how this should be done.
• How the cleaning checks must be done and who is responsible for them.
• Acceptable limits and any photographs of key inspection points.

Procedures for the cleaning of non-product surfaces and equipment must also be in place, but they do not have to include all of the information above.

The cleaning method must be developed based on good cleaning principles, which follow the six steps of cleaning:

1. Gross debris removal.
2. Rinse.
3. Detergent clean.
4. Rinse.
5. Disinfect (where needed).
6. Rinse (if specified in the disinfectant manufacturer’s instructions).

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 puts the area underneath at risk, equipment must be protected from contamination.

Where equipment requires different types of cleaning, e.g. between products, or between daily and weekly cleans, the cleaning procedure must detail the method for each.

Equipment must be checked for defective before use and cleaned after use.

 

Cleaning records

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.

 

Review

Results of cleaning must be trended to identify trends for continuous improvement.

The cleaning programme must be reviewed when:

• There is a changes to the equipment or area to be cleaned.
• There is a change to the cleaning chemicals or the supplier of chemicals.
• The methods of cleaning needs to change.
• Revalidation is required due to changes to safety acceptable limits, or chemical residues.
• Identified from a trend in failures of cleaning checks.
• When root cause analysis identifies an issue with the effectiveness of the programme.
• As required by the customer for contract cleaning (cleaning as a service).

Where preventive action requires specialist knowledge, which isn’t available in-house, external expertise must be provided.

 

Equipment

Equipment stored in internal production and storage areas shall be kept clean.

Food contact equipment which has been stored but is not in daily use shall be cleaned and, where necessary disinfected, prior to use.

BRCGS Food Safety Issue 9

Clause 4.6.5 now states that equipment stored in internal production and storage areas shall be kept clean. This sounds like a silly clause, because it’s obvious that equipment must be clean – but it’s probably been added, so that auditors have a clause to assign non-confomrances to, where they find a problem.

It also now states that food contact equipment that’s in storage, as it’s not used daily, must be cleaned (and disinfected if needed) prior to use.