Controlling Food Safety During Equipment or Facility Repair

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1 Controlling Food Safety During Equipment or Facility Repair By David A. Baker, PhD, MPH, CQM Food safety standards accepted in support of the Global Food Safety Initiative require that maintenance of equipment or building structures be completed so there is no risk to product, packaging or equipment contamination. Food producers are responsible for documenting and maintaining procedures to perform routine, in process, and emergency repairs. They also must demonstrate equipment sanitation and product safety when maintenance is performed and at pre-operation inspections such as when food contact surfaces are in production and food may be present. The risks of contaminating a food production line or introducing foreign matter into finished product during mid-shift repairs are reasonably likely to occur. When a line goes down, time is of essence to get back into production. Therefore, it is critical to have a time-optimized system that ensures communication between production, maintenance, and quality assurance personnel. First, documentation of all plant and equipment failures and corrective actions are required during production. Normally, a food producer completes a down-time log for production and files a HACCP deviation if food safety is involved. To preserve food safety, all food processing should be placed on hold if maintenance is preformed during processing. This is to be sure all foreign material is removed and food contact surfaces are thoroughly cleaned prior to resuming processing. The following best-practice procedure is a good way to ensure that responsibilities are effectively transferred and that all records for production down-time, maintenance, and preoperation inspection are efficiently maintained. It s an efficient process to coordinate the response, activities, and hand-off of responsibilities between production, maintenance and quality assurance personnel: 1. Maintenance employees shall be trained in the proper procedure and steps in equipment failure work orders. (Appendix 1: Process to Control Food Safety During Equipment or Facility Repair Flow Diagram.) 2. Operations supervisors initiate work orders for all equipment or facility repairs that need to be done during the production day (Appendix 2: Sample work order form.) 3. Operations supervisor or QA place equipment on hold. 4. Operations supervisor notifies maintenance employees via radio to their specified location 5. Operations supervisor creates work order and downtime report. Qualtrax, Inc. 105 Industrial Drive Christiansburg, VA Phone: /

2 6. Maintenance employee goes to specified area and assess problem. 7. Maintenance employee is not to work on any process equipment unless there is a hold tag placed on equipment. 8. After initiating the work order, operations hands over the work order to the maintenance employee who is making the repair. 9. Maintenance employee is required to follow all maintenance GMPs while making repairs. 10. Maintenance employee is required to fill out all remaining parts of the work order form after the corrective action repairs were made, then turns the completed work order to the maintenance supervisor. 11. Maintenance supervisor is required to verify that the work is complete and determine if there is a preventative measure that can be taken so future equipment failure will not happen. 12. Maintenance Supervisor will sign and date the verified work order form to ensure its record is properly maintained. 13. If no immediate action is needed when a request is made from operations the following applies: 13.1 Operations fills out work order form Operations turns in work order forms, which are given to the maintenance supervisor Maintenance supervisor generates work order and assigns it to maintenance employee Maintenance employee completes repairs following all maintenance GMPs Maintenance supervisor is required to verify that the work was complete and determine if there is a preventative measure that can be taken so future equipment failure will not happen Maintenance supervisor will sign and date the verified work order form to ensure its record is properly maintained. This workflow or Process to Control Food Safety during Equipment or Facility Repair, ensures that processing lines are placed on hold by operations or QA if immediate corrective actions are needed during processing. The process effectively links all records involved with a line stoppage (i.e. Process Deviation Log, HACCP Deviation, Maintenance, Hold Tag Log and Hold Tag Release) while incorporating GFSI quality management system requirements. This process has effectively created alignment at work between the interrelated services provided by production, maintenance and quality assurance, allowing each to maximize their goals toward achieving company production, quality, and food safety expectations.

3 About the Author David Baker has more than 25 years of international food industry experience increasing brand value by integrating food safety, regulatory compliance and quality and risk management solutions in organizations and workplace culture. David s experience spans the food industry from primary production of plants, animals and fish, most food processing sectors and expertise in ready-to-eat foods, logistics and delivery by foodservice and retail operations. David worked with companies such as Nestlé, Unilever, McDonald s, Shangri-La, IKEA, Coca-Cola and Gold Kist, in Europe, North America and Asia Pacific. He managed projects to review and improved company-wide management strategies for food safety while integrating risk recognition into the business culture. David holds an MS in Aquaculture from Auburn University, an MPH in Environmental Health from University of Minnesota, and a PhD in Food Safety from University of California at Davis. He is a Certified Quality Manager of the American Society of Quality. Contact Information: David Baker, PhD, MPH, CQM bakerdavid@earthlink.net (Office/Fax) (Cell)

4 Appendix 1 Process to Control Food Safety During Equipment or Facility Repair Failure or Risk to Food Processing Equipment or Environment Version: Process Established for: 1. Process Deviation SOP 2. SOP 3. Equipment Hold Tag SOP YES Immediate Action Needed NO Request Maintenance Process Deviation Log Operations; Initiate Process Deviation Address Issue Generate QA Hold Log Enter Hold Tag Operations / QA: Label Equipment with QA HOLD Tag Complete Repair Completed Request Maintenance Sanitation Responsible: Clean & Sanitize Equipment & Food Processing Area Generate Address Issue Pre- Op Inspection Completed Implement Preventive Action Or Update PM Program Complete Repair Operations Over Sees: Clean & Sanitize Equipment & Food Processing Area Inspection Clean Sanitary No Foreign Material Risks Begin Production Not Implement Preventive Measures As Needed Complete Process Deviation Clean Sanitary No Foreign Material Risks Inspection Remove HOLD Tag Resume Production Not QA Hold Log Complete Implement Preventive Action Or Update PM Program

5 Appendix 2

ZOLL Document Number: 90A0036 Page 3 of 11 Equipment Maintenance TABLE OF CONTENTS

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