The Good, the Bad ... and the Ugly

The good news is your plant has decided to build something nice, shiny, and new. The bad news for those of us who are managers of our food safety teams, is that the plant has decided to build something nice, shiny, and new. The ugly is … how are we supposed to maintain sanitation and everything else while this is going on?

Having new construction and getting new machinery in your plant can be an exciting time. When all is said and done, it can increase productivity, improve safety, and even improve food safety. However, the time before and during construction can prove to be a difficult time for your food safety group. There are so many things to consider before, during, and even after construction. Small things can happen, and things can get overlooked that cause substantial food safety and regulatory problems later. As I always say, stay a step ahead or you’re already a step behind.

When dealing with construction, this is the best advice I can offer you. Don’t wait until after everything is done to find a problem. Just as with any food safety issue, being proactive, not reactive, is your ultimate goal.

So what can you and your team do to prevent food safety and regulatory problems from occurring?

Let’s divide our actions into three groups: before, during, and after
 

1. Before construction starts. The first thing to be aware of is the constant need for communication. Unfortunately, sometimes your plant engineer or manager won’t think about including you in the conversation to get your point of view. Be the squeaky wheel. You must be involved in these conversations. Everyone has his or her area of expertise, and although you might not know how to hammer a nail, you do know where things should and shouldn’t go and where doors should and shouldn’t be. You understand traffic and air flow. Look at things from a HACCP standpoint and determine your hazards. Talk to your on-site USDA personnel (or FDA representatives); let them know that you will be undergoing construction or getting new equipment, and tell them what you are doing to protect the product. Determine the hygiene rules you need to have for all the contractors and where they can and can’t go in the plant. Ask questions such as:

• Where is the water coming from?
• Where are the drains located?
• If it is new equipment, is it constructed to be sanitary and cleanable?

Most importantly, plan ahead if construction will take place during production times that could affect your product. Don’t assume that your construction personnel and engineers have thought about this, it’s your job to yell loud enough to be heard. There is a lot to think about—so plan ahead.
 

2. During construction. Obviously the most important thing is to protect your product. To do so:

• Develop procedures for maintaining sanitary conditions, and document them.
• Pay attention to employee and contractor flow. If you are in a ready-to-eat (RTE) plant, this becomes crucial.
• Ask your engineers for updated drawings and plans.
• Keep an eye on the construction.
• Start developing a new pest control plan either internally or with your pest control supplier.
• If you are required to have lock out/tag out, start working on new plans with safety/engineering personnel.
   

And, again, maintain sanitary conditions above all else. Construction in your plant is not an excuse to relax or ignore your food safety rules and procedures.

3. After construction. Even if you did everything perfectly, none of us are clairvoyant. Something will happen that you didn’t expect. There will be problems from a construction standpoint, and you will have problems from a food safety standpoint. Often, everything is great and we don’t see the consequences downstream. But something small can cause a big issue. A new wall can change the airflow, and you walk in the first day to find condensation out of control.

There are always things no one thought to consider. So, the best advice is to have your team ready and at your facility early on the first day after construction and anticipate problems. Prepare your team, and don’t put them in just one place. Remember, consequences of new construction can be in the next room or the next building. Make sure your sanitation crew knows how to clean new equipment. Be aware that everyone wants to come see the shiny new area or equipment, and every salesman, truck driver, maintenance, and executive will be in there. But they need to follow the same hygiene rules as everyone else.