MAINTENANCE SANITATION OPERATION SYSTEMS

By Steve Sayer, SNR Consulting

In today’s prophylactic food processing environment, it’s imperative that your maintenance personnel be partners and participants in your company’s HACCP, SSOP and Quality Control systems. Having a preventive maintenance system to document and verify equipment reliability and other critical areas is a fundamental building-block of a successful HACCP program. It should be an etched-in-stone prerequisite that all maintenance personnel attend accredited HACCP, SSOP and GMP seminars. Procedures to verify sanitary conditions are a must, and a proactive maintenance department will help to preclude many NRs.

Ponder this for a moment: What negative impacts can maintenance workers and inculpable outside sub-contractors have on your plant or products? Aberrant maintenance workers can cause any and all of the following misfortunes:

Chemical Hazards

Oil and grease contamination
Paint and solvent adulteration
Acidic and alkaline hazards

Physical Hazards

Nut, bolt and bearing contamination
Unintentional oddments of ferrous and non-ferrous shavings
Glass and wood oddments

Biological Hazards

Soiled hands, gloves and general garment hazards
Defiled tool and spare-part contamination
Personal vectors of viruses and pestilent pathogen cross-contamination risks

The catchall antidote is to institute a Maintenance Sanitation Operation System (MSOS) tailored to your company’s distinct needs. The foundation of such a system could be comprised of your company’s already established GMPs. But the MSOS should emphasize both worker and product safety, maintaining “HACCP integrity” of product contact surfaces. To function, the MSOS should be both living and variegated, and it should include accountability and verification practices. In general any new MSOS would include:

Mandatory participation of all “maintenance sanitation operating employee” with ongoing training for both established and newly developed GMPs and, when applicable, HACCP, SSOPs and Quality Control programs
Annual training involving cleansing chemicals and wash down techniques for all equipment
Annual training in microbiological testing and analysis
Documenting of daily maintenance logs verified by semi-quarterly audits
Strict employee and sub-contractor adherence to all applicable FSIS, OSHA and EPA regulations
Continued revisions of Material Safety Data Sheets (MSDS) and their letters of guarantee
Establishing protocols and paradigms for monitoring and record keeping of all outside sub-contractors including guests and other germane services

The objective of an MSOS is to maintain a perpetually safe, clean and trouble-free environment, while accommodating company policies and procedures, including those imposed by regulatory agencies. Only if top management provides continuous support can these very rigorous objective be met. Teamwork is the name of the game here. Any company that bases its policies and procedures on commitment and pragmatism, rather than merely reacting to regulatory consequences and their negative residual side effects, will always fulfill and often exceed its goals. Ultimately, such a commitment will result in a safe, clean and reliable workplace.

SNR Consulting offers consulting in HACCP, SSOPs, GMPs, food safety and EPA regulations. Contact Steve Sayer at (323) 377-7949.