FDA Inspection Checklist

Remco Products presents Food Industry Counsel’s FDA Inspection Checklist as a part of our commitment to bringing our audience the best information in the food industry. We don’t endorse any legal services or provide legal advice. For legal services or advice, please consult your attorney.  You can also contact Shawn Stevens, the author of this post, at stevens@foodindustrycounsel.com.

What to do Before, During and After Your Next FDA Inspection

Food Industry Counsel, LLC is pleased to provide you with the most comprehensive and useful FDA Inspection Checklist available. With the passage of the Food Safety Modernization Act (FSMA), the Food and Drug Administration (FDA) was given the mission of overhauling the safety of the nation’s food supply. The new FSMA regulations written by FDA are now coming into effect, and the agency is now aggressively enforcing its new rules during routine inspections. Within the coming years, FDA Investigators will conduct an onsite inspection of every food facility in the U.S.

Here are FDA’s new enforcement priorities during routine unannounced inspections:

(1) To carefully critique each company’s written food safety programs and verification records to ensure they are compliant with the new FSMA requirements;

(2) To conduct extensive Zone 1, Zone 2, Zone 3 and Zone 4 microbiological sampling inside all food facilities to find evidence of pathogenic contamination;

(3) To require recalls if the percentage of FDA samples testing positive for Listeria Monocytogenes, Salmonella or other pathogens exceeds FDA thresholds;

(4) To compare the DNA fingerprints of any pathogens found in the facility against the >1,000,000 human isolates stored in the CDC’s PulseNet database to identify any matches, and then require food product recalls if any matches are found; and

(5) To initiate broader investigations, including criminal investigations, against food companies whose products are found to have caused human illness. Against this backdrop, all companies should begin taking steps to prepare for their next FDA inspection.

Companies can use the following checklists to ensure that they have completed the needed preparations before the FDA Investigators arrive, to help effectively navigate the inspection process once the inspection is underway, and to appropriately respond to any FDA criticisms once the FDA inspection concludes.

PREPARING IN ADVANCE FOR YOUR NEXT FDA INSPECTION

PRE-INSPECTION CHECKLIST

Much of the work needed to ensure that the FDA inspection ends successfully should be completed long before the FDA Investigators arrive. All companies should begin work immediately to ensure that they have accomplished the following critical tasks:

□ Identify a Meeting Space: Identify a space within the facility to host the FDA investigators when they arrive. This might be a conference room or a vacant office with sufficient desk space to review large amounts of records. The space selected, however, should be free of any records (in binders, boxes or on computers) which FDA Investigators could access, unsupervised, while they occupy the space.

□ Assign Designated Individuals: Assign a primary and secondary Designated Individual (DI) for each facility to serve as the liaison with the FDA Investigators once they arrive. DIs should coordinate vacation time (and time off) to ensure that one DI will always be available in the event FDA arrives.

□ Complete PCQI Training: Ensure that the primary DI has received FDA’s Preventive Control Qualified Individual (PCQI) Training. Although the training is not required under FDA regulations to become a Qualified Individual, FDA Investigators will typically expect the training to be completed by at least one facility employee.

□ Finalize Written Food Safety Systems: Ensure that the company’s written food safety systems are finalized, and the primary and secondary DIs are familiar with each of the elements of the plans. Depending upon the size of the business and the nature of the products, this could include GMPs, Sanitation Programs, Preventive Control Plan, Recall Plan, Environmental Monitoring Program, Foreign Supplier Verification Plan, Sanitary Transportation Plan, Food Defense Plan, and Produce Safety Plan.

□ Ensure Ease of Records Access: Ensure that the supporting records for each of the programs are organized and maintained in such a way that the DI can immediately retrieve the past three months of records for FDA review. Although FDA requires the majority of these records to be maintained for at least two years, the FDA investigators will typically ask only to review records for the preceding three months.

□ Document Corrective Actions Properly: Ensure that, in the event there is a deviation, you are documenting all corrective actions correctly. All corrective actions should identify the root cause of the deviation, actions taken to prevent recurrence and, if product safety is not affected, a written conclusion (supported by factual and scientific data) that the deviation “does not create an immediate food safety issue.”

□ Upgrade Sanitation Flashlights: This may seem obvious, but many facilities are still using flashlights are severely underpowered or outdated. Be sure to equip your sanitation employees with the same high-power flashlights that the FDA Investigators will use so that your employees will be able to see (and then clean) what the FDA would observe with its own flashlights when it arrives.

□ Review Allergen Controls: FDA is requiring companies to recall vast amounts of products if the FDA Investigators find, during their visual inspection, that the companies’ allergen controls are not adequate. Make sure that your ingredient labels are accurate, and that opportunities for cross-contact are being guarded against and avoided.

□ Conduct Environmental Monitoring: If your company processes readyto-eat food products that are exposed to the environment prior to packaging, FDA will require you to have an environmental monitoring program. Ensure that an appropriate program is developed and implemented before FDA arrives.

□ Conduct More Environmental Sampling: Because FDA will collect between 100 and 200 microbiological samples from your facility, it is critical to know exactly what FDA will find before it arrives. Thus, you should “Play FDA for a Day,” and conduct your own FDA-style facility swabbing, to identify and immediately correct any hidden problems. If done correctly, and if your swabbing and testing plan is developed with the assistance of legal counsel, the final testing results can be kept confidential.

□ Develop a Microbiological Sample Retain Policy: If, after reporting your testing results, your lab retains your isolates or testing materials indefinitely, create a policy requiring the lab to discard all testing material within 24 hours after testing. This is appropriate as long as the records of the final results are maintained.

□ Develop a Companion Sample Policy: When FDA collects food product or environmental samples, some companies elect to collect companion samples at the same time. Although we typically counsel against this practice, if you choose to collect companion samples, make sure to have a policy in place governing exactly how those samples will be handled, tested and/or discarded following collection.

□ Develop a “No Photographs” Policy: In many cases, FDA Investigators will insist on taking photographs while inspecting the processing environment. If you have a corporate policy which prevents visitors from taking photographs, you may be able to use the policy to prevent FDA from taking pictures.

□ Develop a “Do Not Sign” Policy: Sometimes, during an FDA inspection, the FDA Investigators will insist that a company representative sign a statement or affidavit. You have no legal obligation to do so. Develop a policy that states you will neither sign nor acknowledge any written statements presented by FDA Investigators.

□ Identify an Appropriate “On Call” FDA Lawyer: Long before your next FDA inspection, you should add an FDA lawyer familiar with the Inspection process to the company’s emergency contact list who can be notified and remain “on call” once the inspection begins. This person can serve as a useful resource to help quickly answer any difficult regulatory or investigator-related questions that arise during the inspection.

□ Conduct a Mock FDA Inspection: One of the best ways to prepare for a visit from FDA is to conduct a mock inspection. FDA consultants and/or lawyers can visit your facility and play the role of the FDA Investigator. Ask them to review your programs to identify possible regulatory shortfalls, and work with you to implement strategies that will strengthen your programs and reduce your regulatory exposure.

MANAGING THE ACTUAL FDA INSPECTION

INSPECTION CHECKLIST

When the day comes, the FDA Investigators will arrive unannounced. The FDA Investigators will present their credentials and ask to conduct an entrance meeting. During this meeting, the FDA Investigators will detail how they plan to conduct the inspection, how long the anticipate the inspection will last, and the specific tasks they intend to accomplish. These tasks will typically include the following:

(1) a facility inspection, during which the FDA Investigators will tour and carefully inspect the processing and other areas of the facility;

(2) a records review, during which the FDA Investigators will carefully scrutinize the company’s written food safety programs, and at least three months of monitoring and verification records; and

(3) a swab-a-thon, during which the FDA investigators will collect approximately 100 to 200 microbiological samples from: (a) incoming ingredients; (b) outgoing finished products, and (c) Zone 1, Zone 2, Zone 3 and Zone 4 environments.

The entire inspection process will usually take a few days and, in some cases, can last weeks. Once the inspection begins, use the following checklist to help appropriately navigate the inspection process.

□ Attempt to Negotiate the Areas Being Sampled: During the entrance meeting, the FDA Investigators will typically disclose the types of ingredients, products and/or environmental areas they intend to sample. Attempt to negotiate with the agency to limit the amounts, types or overall focus of the sampling in such a way that, if any results are positive, you can limit to the greatest extent possible the scope of any recall.

□ Carefully Document the Areas Being Sampled by FDA: While the FDA Investigators are conducting their sampling, be sure to carefully document the exact areas from which the FDA Investigators are collecting their samples. In addition, be sure to appropriately characterize the areas being sampled by the agency as Zone 1, Zone 2, Zone 3, or Zone 4. This information will be critical in the event that any samples are positive to determine the most appropriate response.

□ Carefully Consider Whether to Collect “Companion Samples”: In some instances when a company collects companion samples, the samples that the FDA collects test negative while the companion samples test positive. Because taking companion samples doubles the chances that a positive will be found (whether because of the presence of actual contamination or lab error) we generally do not recommend taking companion samples. With that said, be sure to consult with legal counsel because there may be some limited circumstances where companion sampling would be advisable.

□ Hold any Product that FDA Samples: In the event FDA collects finished product samples to test for the presence of Listeria Monocytogenes, Salmonella or any other pathogens, be sure to hold any products produced from the same lot or batch, or any products produced using the same ingredients, until the FDA results come back. If any results are positive, and the product has been held, a recall will not be necessary.

□ Hold any Product from any Lines that FDA Samples: In the event FDA collects any Zone 1 samples from any processing lines, be sure to hold the products that were produced during the periods that FDA was sampling until the FDA results come back. Here too, if any results are positive, and the product has been held, a recall will not be necessary. To provide additional protection, the company may also consider holding any product processed on equipment where Zone 2 samples were collected as well.

□ Aggressively Clean and Sanitize all Areas Sampled by FDA: As soon as possible after FDA has completed its sampling, be sure to aggressively clean and sanitize each of the areas that the agency sampled. This is because, in the event any sample is positive, you will be able to argue that whatever contamination existed at the time of sampling was eliminated and thus could not have affected any additional production.

□ Correct all FDA Observations Immediately: During the course of the inspection, the FDA Investigators will likely share their findings and observations with the DI. Wherever possible, make sure to immediately correct to the satisfaction of the FDA Investigators any observations that are critical of the company. Doing so will demonstrate that the company is committed to quickly resolving any concerns, and the FDA Investigators may choose not to record those observations in the final FDA Form 483.

□ Know What Records FDA is Permitted to Review: FDA has very broad powers to access records. Generally speaking, FDA will be able to review a company’s written food safety programs and related records. The agency is not entitled, however, to review or copy any recipes, financial data, pricing data, personal data (other than to ensure that the company’s employees have received training appropriate to their position and responsibilities), research data, and sales data (other than shipment information).

□ Protect the Confidentiality of any Records FDA Copies: If FDA requests copies of any records the company deems confidential, be sure to mark those records with the following statement: THIS DOCUMENT AND THE INFORMATION CONTAINED HEREIN CONSTITUTES TRADE SECRET, CONFIDENTIAL AND PROPRIETARY COMMERCIAL INFORMATION PURSUANT TO 5 U.S.C. 552(b)(4), AND SHALL BE STRICTLY PROTECTED AS SUCH FROM ANY DISSEMINATION AND/OR DISCLOSURE. This will put the agency on notice that the information must be protected and may not be disseminated publicly.

□ Do Not Leave the FDA Investigators Unaccompanied: Make sure that while the FDA Investigators are in your facility they remain accompanied. This way, the DI can observe and document the actions of the FDA Inspectors, and respond immediately to any concerns. Additionally, if a company employee remains present at all times, the FDA Investigators will be less inclined to develop or discuss additional “unplanned” inspection “strategies” or “goals” with each other during the course of the inspection.

□ Do Not Sign Any Statements of Affidavits: At the conclusion of the inspection, the FDA investigators may ask you or your employees to author or sign a statement or affidavit describing the inspection, the observations and/or the conclusions. Do not sign, correct or acknowledge any documents, as you have no legal obligation to do so. If such a request is made, consult with your FDA lawyer immediately.

MANAGING THE AFTERMATH OF AN FDA INSPECTION

POST-INSPECTION CHECKLIST

Once the FDA Investigators have finished with their assigned tasks, they will conduct an exit interview and share their findings, observations and conclusions. In most cases, where violations have been identified, the FDA Investigators will issue a FORM 483, which details the specific violations observed by the FDA Investigators. In some cases, depending upon the nature of the observations and conclusions, the FDA Investigators may also ask the company to consider a recall of certain products. The following checklist can be used to help navigate the aftermath of the FDA inspection and bring all issues to closure.

□ If FDA Issues a FORM 483, Prepare a Written Response: During the exit interview, the FDA Investigators will likely present their observations, findings and conclusions. In most cases, any regulatory or food safety violations will be documented in an FDA FORM 483. Although a response is not required by law, a company is generally expected to provide a written response within 15 business days. If the written response adequately addresses FDA’s concerns, FDA will not pursue further regulatory action. If the response is inadequate, however, the agency may issue a “Warning Letter” threatening to withdraw the company’s registration and prevent it from producing product.

□ Support Your Written Response with Documentation: When FDA issues a FORM 483 or “Warning Letter,” make sure your response is appropriately supported with adequate documentation. For instance, FDA will not be satisfied if you simply state in your response that you corrected a problem that the FDA Investigators observed by “conducting additional employee training.” Rather, in addition to stating that you completed the training, FDA will expect you to attach a training log or other document to your response which provides evidencing that the training was, in fact, completed.

□ If FDA Suggests a Recall, Consult Your FDA Counsel: Sometimes the FDA Investigators will observe conditions they believe warrant a recall. The decision whether to announce a recall in the first instance, and any determinations regarding the scope of any such recall, can vary greatly depending upon the facts and data. Any recall decisions should thus be made very carefully, and only after consultation with an experienced FDA compliance attorney. Many companies have successfully convinced FDA, based upon the availability of supporting facts, forensic analysis and scientific data, that the agency is incorrect and a recall is not needed, or the scope can be significantly limited.

Although there are countless variables which will ultimately affect the way in which your next FDA inspection unfolds, the information provided within this FDA Inspection Checklist is designed to provide some of the tools you will need to deal with the most common scenarios. We truly hope that you will find these checklists useful as you prepare for and manage your next FDA Inspection.

About the Author: Shawn Stevens is a food safety consultant and lawyer, and the founding member of Food Industry Counsel LLC, the only law firm in the world that represents the food industry exclusively. Mr. Stevens works throughout the country and abroad with food industry clients (including the world’s largest growers, food processors, national restaurant chains, and food distributors and grocery chains) helping them protect their brand by complying with FDA and USDA food safety regulations, managing recalls, and defending high-profile foodborne illness claims. Additional information about Mr. Stevens’ legal and consulting practice can be found at: www.foodindustrycounsel.com.

 

How to Prepare a New Cleaning Tool for Use

New cleaning tools—especially those sealed in plastic pouches like the ones from Vikan and Remco—often look like they’re ready for use right out of the bag. It’s easy to assume these tools can start sweeping, mopping, and brushing right away, however, as most in the food industry know, looking clean isn’t the same as actually being clean. Here are a few steps that must be taken to ensure all new tools are ready for use in food production plants:

  1. Remove any labels

Vikan and Remco both apply labels directly to some of their products, as do many other cleaning tool manufacturers and distributors. Ideally, these labels will peel off easily, especially when they’re dry. If there’s a problem removing a label or there’s residual stickiness, simply use a washrag with warm water and soap, or use a sponge soaked in vinegar to remove the label and any adhesive left behind. It’s easier to peel labels when they’re dry, but a little extra effort may be needed for particularly stubborn adhesives. It’s essential to remove the label and adhesive fully, as the sticky residue can be a trap for debris and bacteria.

  1. Clean the tool

New tools may seem clean, but they’re produced in factory environments that do not have the same rigorous sanitation requirements as food manufacturing facilities. Put new tools through an industrial dishwasher or hand wash them, depending on what the plant’s HACCP plans call for during the tool’s regular usage. Either cleaning option may help remove any remaining label residue, along with preparing the tool for its first use. Don’t make the mistake of assuming a broom or a squeegee that will be used in a low-risk environment is “clean enough” when it comes out of the package. The tool should still be cleaned.

  1. Sanitize for high-risk conditions

To decide how clean a tool should be before use, follow HACCP plans for how they’ll be cleaned during their regular usage. If a tool will be used in a high-risk environment, it should be sterilized before its first use, ensuring any microbes that may have contaminated the item before it arrived to you are fully destroyed. If a tool is going to be used in a low or medium-risk facility, simply cleaning and sanitizing the tool should be enough for it to be used safely.  

  1. Dry the tool

No tool is clean without having been dried first. Whether by hanging it or by putting it through an industrial dishwasher’s drying cycle, tools must be dry to be considered clean. This helps prevent mold and other microorganism growth and ensures the tool is ready for use.

Once these steps are complete, the tools are ready for their designed purposes in food processing plants. Remember to maintain tools by keeping them free of debris and cleaning them frequently. Regular maintenance—starting with these first steps—will keep tools hygienic and help them last longer.

2017 Letter from the President of Remco Products

As we look forward to the rest of 2017, I am excited about the future of Remco. 2016 was a banner year for Remco and we are reinvesting in our business to ensure the continued success of our customers. This year Remco has already added four new staff positions that directly support our customers. We added an additional business development manager, an account manager, a new market development manager, and a product manager. In 2017, we also plan to add two additional business development managers and an education and technical support manager. All of these new positions strengthen the level of support that we can provide our customers and further my goal of making Remco a trusted partner in food manufacturing sanitation programs.

With the growth in Remco’s staffing levels, we are also growing the physical space of our offices. We are currently in the midst of a construction and renovation project that will add new conference rooms and a large new meeting room, and revamp existing offices. The total project will effectively double the amount of usable office space at our facility and provide improved opportunities for on-site food safety trainings and presentations.

Thank you for your continued business and we look forward to helping in your success.

Regards,
Mike Garrison

See the Many Colors of Remco at IPPE

We’ll be showing all our true, bright colors at IPPE from 1/31-2/2 in Atlanta! Our experts will be on-hand to talk about the value of color-coding your operations and how our hygienically designed tools are different. You’ll also be able to see our nine distinct colors on some of our most popular Remco and Vikan tools. From orange to purple, and from yellow to pink, we can help you make your organization safer and more colorful.

Color coding can be used to:

1. Provide zone control. Different colors can be assigned to each step in the process, or by manufacturing lines. In the meat industry, many choose to use red tools in the raw prep areas and white for finished products. This is also useful for protecting against allergen cross-contact and can be an important part of an HACCP plan.

2. Increase traceability. When colors are assigned to zones, confirming that a tool is misplaced is easy, and tracing it back to its point of origination is quick. This level of traceability can translate to the prevention of costly recalls.

3. Divide workspaces. For example, red could be used by first shift, while blue could indicate second shift. Using color-coding to designate workspaces in this way can be particularly helpful to companies that closely monitor tool and equipment costs. The result can be a reduced incidence or misuse of tools in unapproved areas, as well as fewer lost or misplaced items.

4. Facilitate 5S Systems. This system works by promoting five pillars: sort, set in order, shine, standardize and sustain. If followed, a workplace should be completely organized at all times. The 5S System recommends integrating color cues throughout a work process or facility in order to reduce waste and optimize productivity. The color-coding promotes a workplace culture where tools and supplies are placed where they are needed and are well-maintained for longevity of use. Color-coded tools intuitively complement and support the goals of a 5S workplace.

5. Separate cleaning and sanitation. Black is commonly used to identify cleaning tools used on floors and around drains. Other colors can designate tools that are appropriate for sanitizing food contact surfaces, or to differentiate among tools that are specified for use with particular chemical agents. This can also help prevent using a powerful cleaner on the wrong equipment.

Remco representatives will be happy to answer all your color-coding questions at IPPE, as well as help you determine if it’s the right choice for your facility. We will have products on display, and we’ll proudly tell you what makes our hygienically designed, color-coded tools unique within the industry. If you’re unable to attend IPPE or you have questions before the show, please contact our customer service representatives here.

 

What are Documents of Compliance in Food Processing?

Food contact surfaces like cleaning and material handling tools must comply with the FDA’s rules about what they can contain and how they must be designed. FDA CFR21 110 Subpart C, states that “Food-contact surfaces shall be corrosion-resistant when in contact with food. They shall be made of nontoxic materials and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds and sanitizing agents.”

There currently isn’t an obligation to test finished products to comply with FDA regulations, however, it is a generally accepted practice to provide documents that show the base materials of food contact tools are FDA compliant.

But, companies that trade with Europe must follow a much stricter set of documentation laws. According to Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011, each food contact material (FCM) needs to undergo migration testing and be declared safe for food use.

Migration tests

Each base material—whether it’s the blue plastic used in a brush or the green bristles used on a broom—is put through migration testing. Migration testing reveals how much of any or a particular substance (such as harmful chemicals/compounds from the base materials) can be transmitted from the tool’s material to the food products. The maximum permitted quantity (QM) left behind in the food product is most often 10 mg/dm2 for overall migration limits (the total amount of migrated material left behind), but that figure changes when infant food or volatile substances are in play.

Specific migration limits, which consider the total amount of one specific substance that’s left behind, must be checked against Annex I for the maximum limit of each substance’s limit. The maximum amount allowed depends on the substance.

Documentation

According to Regulation (EU) No 10/2011 – Annex IV, each declaration of compliance must contain the following:

  • Identifying information for the business issuing the declaration, and the business that manufactures the product
  • The materials used in the product, and confirmation they all conform to EU’s regulations
  • Migration test results, and that they conformed to the standard
  • Product information about what type of food the tool is meant to be used with, and the time/temperature it can safely be used at

For more specific information, read Regulation (EU) No 10/2011 – Annex IV here.

Use of documents of compliance

There must be one document of compliance for each product, excepting those made out of the same exact composition, which can share documentation. For example, one document for a blue push broom and a blue scrubber, as long as the plastic and bristles were made out of the same materials, is acceptable. However, one document for a blue and a red scrubber is insufficient to meet the requirements, since the color dye changes the product’s material composition.

This documentation is designed to give food processors the information they need to safely use tools in their production facilities. Though the FDA doesn’t require this type of documentation, it can greatly enhance your food safety plan. To obtain these documents, request them from your equipment manufacturer. Make sure that each document is unique to the material it’s made of. One generic document of compliance isn’t enough to comply with European regulations. For Remco Product customers, email our customer service department at cs@remcoproducts.com, and our representatives will get you copies of the documents you need.

 

Sources

Smith, Debra. “Are your cleaning tools food safe?” Vikan, 2015. http://ust.vikan.com/media/1288/food_hygiene_int_article_en_0615.pdf.

“Union Guidance on Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food as regards information in the supply chain.” European Commission Health and Consumers Directorate-General, 2013. https://ec.europa.eu/food/sites/food/files/safety/docs/cs_fcm_plastic-guidance_201110_reg_en.pdf.

Grosmans, Sonja; Thomis, Nadine. “Food Contact Materials EU No. 10/2011 lesgislation.” Intertek, 2012. http://www.intertek.com/events/2012/hes/eu-no-10-2011-for-plastic-food-contact-materials-webinar/slides/.

e-CFR. “Title 21: Food and Drugs, Part 110, Subsection C.” U.S. Government Publishing Office, 2016. http://www.ecfr.gov/cgi-bin/text-idx?SID=114e23c93d8ac137c1f2103395d974c8&mc=true&node=pt21.2.110&rgn=div5#sp21.2.110.c.

New-Employee-Proof Your Safety Plan with Color Coding

In the food processing industry, like many factory-based jobs, employee turnover is high. When you’re seeing a turnover rate of about 35% yearly, how do you train your staff to follow important safety plans? When you’re in an industry where a simple mistake by a single employee could result in thousands of people getting sick, how do you ensure HACCP compliance?

For many, color coding has become the easiest answer. Color coding offers a simple solution to an otherwise complex problem. Even the newest employee can quickly learn that red products belong with the raw product, and white goes with the finished.

Here are our top 5 tips to using color coding to ensure all of your employees follow CGMPs.

  1. Set up cleaning stations

Cleaning stations serve as a visual reminder that everything has its place. Put a sign over a station filled with blue tools to remind everyone that those tools are used to clean floors in the packing area, and another sign over a pink wall bracket to tell employees that those tools are used in receiving. Cleaning stations also remind employees to hang tools back up once they’ve been cleaned.

  1. Separate allergen control zones

Training new employees on how and why to respect allergen control zones is difficult. Popular culture has made everyone aware of the danger of peanuts, but many people don’t respect the potential harm trace residues of milk ending up in the wrong product can do. Even if your individual employee doesn’t understand why blue tools are only to be used in a certain area, they can at least quickly understand that it’s the way the factory operates. If the new employee still doesn’t respect the separation, they can be quickly corrected, since it will be immediately obvious they’re using a tool outside its zone.

  1. Back up your plan with pictures

It’s riskily idealistic to think every employee who walks through your door will know how to read in English, or know how to read at all. Photos of what to use each tool with will back up your written signs and make them easy to understand for all of your employees, no matter what their background or education level is. Use easy photos like a picture of peanuts with a big red X over them for your peanut-free tools, or a photo of a purple scoop next to wheat grains so employees know what those tools should (and shouldn’t) touch.

  1. Don’t use commonly color-blind colors

When you choose colors, be aware that some are more easily confused than others. Of people with color-blindness, about 99% have trouble distinguishing between red and green. Try not to use these colors in the same color coding plan. Also, be aware of the fact that about one in 12 men are colorblind, and one in 200 women. Choose shades that are contrasting, like white and red, and avoid putting similar shades near each other, like brown and orange or blue and purple.

  1. Use color-coding to spot training issues

Is someone using the brush meant for a different shift or a different area of the facility? It’s time for a small, informal retraining conversation with a floor manager. These easy discussions can essentially boil down to telling the employee the color they should be using for their purpose. Quick one-on-one sessions with a manager will reinforce these guidelines, and with very little time or effort wasted. Floor managers should have color-coded zones memorized so they can make the most of their time on the floor and correct problems where they see them.

 

Food safety is everyone’s job in the plant, but training comes down to managers and owners. Creating an environment where safety comes first starts with using the right tools for the job, and color coding can help with that.

Catalogs Now Available in French and Spanish

For the convenience of our customers, we now offer our catalogs in two additional languages. Québécois French was requested by our Canadian customers who wanted an easier way to browse our hygienically designed color-coded tools in their native language. A Latin American Spanish catalog is also available. Our catalogs contain category descriptions and each of our products along with their color availability and technical specs.

To order a catalog in a non-English language, please choose the appropriate language in the drop-down “Catalog Type” field on the catalog request form on this page of our website. You can also instantly download a full PDF of our catalog in all three languages on the same page if you prefer digital.

Product Selection Guides

Remco now offers product selection guides to help you and your customers pick the most effective products for your needs. Each guide contains specifications for all the variations of the product it features, along with information about brush fibers, hygienic design, and the available color selection.

Product guides are available for:

We also have industry-specific guides that highlight the most frequently purchased items from some of our more popular customer industries. Guides are currently available for:

We may add more product guides and industry-specific guides in the future, as well. If there is a guide that would particularly be of help to your company or your industry, don’t hesitate to reach out to our customer service department (cs@remcoproducts.com) to let us know. Our customer service representatives can answer any questions you may have in the meantime.

Selling Your Organization on Color Coding

Color coding benefits everyone from the company CEO to individual workers. Selling your organization on color coding is as easy as learning what appeals to each position, and presenting the benefits. Whether you’re a plant safety officer or a salesperson at a distribution company, here’s what you need to know to gain organizational buy-in.

Plant Owners – Minimize risk and product waste

Plant owners carry the responsibility of running a safe processing facility on their shoulders. Color coding can increase the safety of day-to-day operations, somewhat lessening that burden. In the event of charges being carried against a facility, owners/operators must provide a due diligence defense if their product causes illness or death. Color coding is a proven, standard method to prevent cross contamination and is widely accepted by standards organizations. BRC v.7 (2015) requires BRC registered companies to use either color coding or tools that are “visually distinctive” in high-risk areas. Color coding is a significant step towards being able to show auditors that a company is doing their part to minimize risk and promote food safety.
If color coding is helpful in minimizing the chances of cross contamination, it’s essential to minimizing the impact of a foreign body recall due to a piece of a tool breaking off and contaminating the product. If zoning is done by areas, or even shifts, the color of the chipped tool or plastic glove can pinpoint where (and possibly when) the contamination happened, which results in less product needing to be pulled off of shelves.

Middle Management – Simplify training and pinpoint issues

Color coded tool stations can significantly reduce the amount of time that must be spent training each employee. Instead of a complicated system where certain tools are only left certain places, the stations are immediately obvious to even the newest employees. Food processing facilities typically see a high amount of turnover, making brevity in training time even more valuable. Simplify the entire process by having total color tools for different purposes.

Tool stations also promote a culture of responsibility since it’s easy to see if someone didn’t bother to put a tool back in the right place. Having a place for each tool, and having each tool be zoned keeps the factory running smoothly and safely. If a tool is missing, finding it is as simple as asking the shift workers it’s color coded to. Retraining is also easier if it’s immediately apparent when an employee is using the wrong tool for a job.

Employees – Uncomplicate HACCP regulations

Training represents time and money to company executives. To employees, it’s time they’re not working toward production goals. Most workers appreciate a streamlined process that doesn’t require them to remember which station they went to for a tool. Color coded stations also means brooms aren’t propped against walls and buckets aren’t sitting in random places, all waiting to trip an employee who’s not paying enough attention.

Investing in a fully color coded system shows a commitment to food safety that won’t go unnoticed by employees. The shift of a company culture to one that deeply cares about the safety of its products will help employees feel good about their work, which, in turn, can make them better workers.

Getting organizational buy-in is a necessary part of adding color-coding to a company. Without it, the process may not be implemented correctly, if at all. However, once color coding becomes part of the corporate culture, it can streamline operations and training, as well as reduce risk.

The Differences Between Non-Sparking and Anti-Static Tools

Non-sparking and anti-static tools both have a common purpose—preventing fires or explosions in production facilities where flammable materials present a concern. However, they each are designed to prevent specific dangers, and shouldn’t be confused. Non-sparking tools are characterized by their lack of ferrous metals (steel and iron), which means they don’t cause sparks that could ignite under the right conditions.

Anti-static tools are carefully designed to work within a system of grounding equipment to prevent static electricity from building to the point it could damage electronics or provide enough of a charge to start a fire or explosion.

However, being non-sparking doesn’t mean a tool can’t also be anti-static. When properly grounded, a non-sparking tool can also prevent electrostatic discharge.

When are non-sparking tools needed?

Non-sparking tools are important for use in a facility that may have an explosive atmosphere or any reason to be especially concerned about the possibility of sparks causing a fire or an explosion. This typically concerns production facilities that contain flammable gas, mists, dusts, or liquids. Non-flammable tools are often used in oil refineries, paper companies, and ammunitions plants. Food processing facilities that use powdered milk, egg whites, cornstarch, grain, flour, or cornstarch may also use non-sparking tools since these can all create combustible dust hazards.

What are non-sparking tools?

Non-sparking tools are, essentially, those that don’t contain ferrous metals. Ferrous metals include steel and iron, in all of their different iterations. Items that are made from carbon steel, stainless steel, cast iron or wrought iron all have the possibility of producing a spark.

Non-ferrous metals include aluminum, copper, brass, silver and lead. They’re not the only materials that non-sparking tools are made out of, though.

Common non-sparking tools are made of:

  • Plastic
  • Brass
  • Bronze
  • Copper-nickel alloys
  • Copper-aluminum alloys
  • Copper-beryllium alloys
  • Wood
  • Leather

Plastic is a common non-sparking material for items like shovels, scrapers, paddles, and scoops.  Tools that need a higher tensile strength, like hammers or screws, are often made out of copper alloys, though beryllium tends to be avoided because of its possible toxicity.

There is a possibility that even non-sparking tools could cause a reaction called a “cold spark”, which doesn’t contain enough heat to ignite even the most flammable of substances, carbon disulfide. Cold sparks can still give the appearance that sparks are happening, but are safe around even the most flammable of substances.

When are anti-static tools needed?

Electronics components—especially motherboards—are extremely electrostatic discharge (ESD) sensitive. A simple static charge created by a worker walking across a floor to a workstation could destroy a motherboard, rendering the entire component useless. Most industries don’t need to worry about static discharge, but when flammable gas is in the air, such as acetone or methane, even a small discharge can create a fire or explosion.

What are anti-static tools?

Anti-static tools are more complex than not containing a specific type of metal. They must be a part of a complete program to safely discharge static.

Static electricity naturally builds up through three different processes:

  1. Tribocharging: Two materials (like socks and carpet) are brought into contact and then separated.
  2. Electrostatic induction: An electrically charged object is placed near a conductive object that isn’t grounded.
  3. Energetically charged particles impinge on an object: This is mostly a problem for spacecraft.

The most effective prevention for static electricity isn’t so much a single tool, as it is a system of precautions, grounding mechanisms and a lack of highly charged materials. Together, this creates an Electrostatic Discharge Protection Area (EPA) that works to keep electrostatic discharge (ESD) sensitive materials safe.

The principles of a successful EPA include:

  1. No highly charged materials
  2. All conductive materials are grounded
  3. Workers are grounded
  4. Electrostatic charge builds up on ESD-sensitive electronics is prevented

The hand tools you use in this environment are often made from plastics that are specifically created to work within this delicately balanced system. These electrostatic dissipative (ESD) tools have a balanced charge and low surface resistivity, which means they don’t gain or lose charge to the objects and surfaces that surround them. These tools have precise temperature and humidity ranges that they work in. If they’re used outside those ranges, they may still create a static charge.

 

If your facility needs non-sparking tools, all of our lines except our metal detectables will fit your needs. With the exception of some of our handles, they’re made of plastic, which makes our tools durable and safe to use in many different environments.

If you have a static sensitive environment, you may require anti-static tools, which we currently do not offer.

Some of our products, such as our green shovels, are made of plastic mixed with a static resistant compound. The compound is designed to reduce static and keep products from clinging to the tool. This doesn’t make them anti-static, and they shouldn’t be used in areas that have anti-static requirements.