[Food Safety] Developing a Food Plant Chemical Control Program

There are many types of chemicals available in food facilities. Cleaning chemicals, pesticides, and maintenance chemicals are types found in most plants. Although their intended purpose is to aid in some way, chemicals can actually become very harmful if not used properly.

Perhaps the most prevalent cause of beverage recalls is improperly flushing product lines to remove cleaning chemicals after the CIP system has been run. Other recalls have been attributed to improperly applied lubricants and oils and misapplication of pesticides that adulterate product flow. All of these instances can be prevented with a well-organized and implemented Chemical Control Program.

BEST PRACTICES. Developing and maintaining a sound control program for chemicals that are used within a food handling operation is a prerequisite for a successful HACCP plan and is necessary to maintain a safe environment. Effectively controlling chemicals that are essential and routinely used manages potential risk associated with these chemicals. In most cases, all chemicals used in a food operation can be categorized into four basic categories: maintenance chemicals, sanitation chemicals, pest control chemicals, and laboratory chemicals.

All chemicals should be stored in a designated area in which there is no potential for spills or leaks to contaminate food or packaging materials. Pesticides must be stored in a locked and labeled area so that ventilation of any fumes does not impact product integrity or the health of employees working in the area. This also provides restricted access to authorized personnel only. Any secondary chemical usage containers must be labeled to prevent potential for accidental misuse. Unlabeled containers should never be tolerated in a food operation environment.

To determine what other chemical control methods are necessary, you must first know what chemicals are in the facility. Start with a physical inventory all chemicals by category. Make a list including the chemical name, where it is currently stored, known usage information, and the category into which it best fits.

When doing the initial inventory of chemicals in maintenance areas, open all cabinets and check stock shelves, tool chests, boiler rooms, compressor rooms, etc. to ensure that all current chemicals are identified on the list. Sanitation chemicals are usually stored in a central location, but also check sanitation lockers for stashes of chemicals used by the sanitors. Do not overlook the janitorial supply chemicals used to clean rest rooms, offices, and break areas. Make sure CIP chemicals are included on the list. Pest control chemicals should be stored in a locked and labeled location; however, maintenance shops may have cans of wasp and hornet pesticides that should not be overlooked when creating this list. Finally, laboratory chemicals may be stored in the laboratory or in a supply room.

Once the initial inventory is assembled and the known usages are defined, review the list to determine if any obsolete materials are still in stock. If so, these materials should be discarded according to the label directions and/or federal and state regulations.

Next, be sure to obtain usage directions for all chemicals on the list to determine if the usage in the facility is in accordance with the label directions. For instance, if a boiler treatment chemical is used and the steam directly contacts exposed food product, is the material approved under 21 CFR 173.310? Are sanitation chemicals used to clean food contact surfaces approved for such use? Does the use require a rinse and is this practice included in the written SSOP? Are the concentrations used the same as those listed on the labels? Are pest control chemicals approved for use inside the food plant/food storage area? Do laboratory chemicals require any special storage ventilation considerations?

Create a chemical control book for each category that includes the list of approved chemicals, sample labels, Material Safety Data Sheets (MSDS), areas where each chemical is approved for use, dilution information, storage locations, and any specific usage restrictions. A common usage restriction that might be included states that "approved non-incidental food contact lubricants may not be used in product zones."

Establish approval authority for ordering chemicals for each of the four categories. The approval authority should be clearly defined in the program. Only he or she should be allowed to purchase chemicals that are brought into the plant. Approval authorities may by corporate level employees, however in a typical situation, the following personnel are assigned responsibility:

Maintenance Chemicals – Engineer

Sanitation Chemicals – Sanitation Manager

Pesticides – Sanitation Manager

(or whoever oversees the pest control program)

Laboratory Chemicals – Laboratory Manager

ADDITIONAL RECOMMENDATIONS. Every food facility should have a clearly defined protocol for handling chemical samples to be used for evaluation trials. Once approved for use, the approval criteria should be added to the chemical control manual. Provisions should be in place for emergency backup supplies on an emergency basis. If a chemical must be purchased from a local retailer, the approval authority must obtain the necessary documentation to cover this purchase and temporary usage.

Procedures for handling chemical spills in the plant should be in agreement with the hazards presented by the specific materials. It is strongly recommended that spill cleanup kits be provided in storage and usage areas. Make sure that whoever responds to clean a spill is equipped with the appropriate attire and training to prevent further problems.

Once the approved and categorized manuals have been verified, training should be provided for all employees who will use these chemicals to ensure they understand the proper application in the defined environment. This training is in addition to the OSHA Right to Know training that is required for all facility employees. All training should be documented as to when it was conducted, the subject materials covered, and who was in attendance. It is advisable to test attendees to ensure that the information is understood.

The implemented program should be audited on a routine basis to ensure that unapproved chemicals are not introduced into the facility environment and therefore not controlled by program requirements. A partial audit can be done during the monthly self-inspection program by checking a few chemicals in each category against the approved list. An annual in-depth audit could include a complete inventory of the chemicals on-site, an audit of the usage logs, verification of the sanitation chemical concentration logs, and interviews of employees who use the chemicals as well as approval authorities. Any identified discrepancies should be addressed to bring the control afforded by the program back in line. In addition, take into account the following special considerations by chemical class when developing a chemical control program for your food processing facility:

Special Considerations

Maintenance Chemicals

l Store food grade lubricants in a segregated location.

l Ensure that boiler treatment chemicals used for steam that will contact food or food contact surfaces are in compliance with 21 CFR 173.310. Maintain supporting documentation.

l Define where incidental food-contact approved lubricants are required on food processing and packaging equipment.

l Maintain supporting documentation for incidental food-contact lubricants.

l Wipe off excess lubricant from bearings and fittings and maintain seals to prevent oil leaks.

Sanitation Chemicals

l Verify usage concentrations for sanitizers and maintain a log.

l Verify that sanitizers and cleaning chemicals are rinsed out of CIP lines prior to resuming production operations.

l Maintain calibration logs of mixing dispensers.

l Ensure potable water is used to rinse cleaned and sanitized food contact surfaces as indicated on usage labels for the specific chemicals used.

Pest Control Chemicals

l Maintain usage logs with complete information to document that all applications were made in accordance with label directions.

l Store pesticides in locked, labeled and appropriately ventilated locations.

l Ensure that restrictions on the pesticide labels are followed.

l Provide for proper disposal of empty pesticide containers in accordance with label directions.

l Maintain inventories of pesticide chemicals as a backup to the usage records.

l Maintain a spill cleanup kit in the storage room.

Laboratory Chemicals

l Maintain only the minimum amount of chemicals needed to complete testing in the laboratory environment.

l Maintain appropriate spill cleanup materials.

CONCLUSION. Once a Chemical Control Program is established in your facility, ongoing program maintenance should help maintain a food operation environment that is safe from chemical misuse that could lead to product contamination. This program is essential to ensure that product sent to consumers is safe for consumption. AIB

The author is Regional Director, Eastern United States, AIB.