Envisioning 2022 Food Safety and Sanitation Expectations

We began 2022 with a renewed hope for better health, safety, and progress for all. Food safety management across our global supply chain, from farm to fork, is a priority that cannot be ignored as a large piece of that hope. Last year, as we celebrated 10 years of U.S. FSMA in the thick of a continuing COVID-19 pandemic, we saw sesame recognized as the 9th Top Allergen in the U.S. and a major nationwide recall of imported fresh onions towards the last quarter.

This year, we should expect to see some more food safety and sanitation-related progress in the U.S. and global food supply arenas, especially within the following areas:

  1. Greater Emphasis on Data Analytics and Information Sharing: Risk-based food safety decisions across food sectors will become more data-driven and based on real-time. More importantly, FDA’s New Era of Smarter Food Safety (1) approach has recently been initiated by stakeholders – this collaborative platform intends to leverage innovative technology and newer processes to help create a safer, more digital, and traceable food safety system.
  • Better Innovative Controls through Continuous Collaboration: Besides having a science-based research and policy on Salmonella reduction (2) in FSIS-regulated products, there will be an increased drive towards implementing modernized controls and newer technologies for reducing pathogens, especially in raw meat and poultry products.
  • Moving Ahead with an All-Inclusive One Health Vision: To get to the root source of food contamination, food safety and sanitation expectations will have to increasingly function under a multisectoral, One Health framework. (3) These efforts should work seamlessly at local, regional, national, and global levels with the goal of sustaining a positive public health outcome by recognizing the interconnectedness between people, animals, plants, and their shared ecosystems.

In the world of food safety standards and regulations, the following developments are expected:

  • British Retail Consortium Global Standards (BRCGS) Food Safety Standard Issue 9 is expected to be published around August 2022, and audits to the newer version are expected to start from February 1, 2023. Stay updated with recent changes through the BRCGS website. (4)
  • For those in the Produce Sector, listed below are all the FSMA Rule Requirement compliance date deadlines. (5)
FSMA Rule RequirementCompliance Date Deadline
Produce Safety Regulation – Very Small Farms, Remaining water requirements for Other ProduceJanuary 26, 2022
Produce Safety Regulation – Large Farms, Non-sprout agricultural water requirementsJanuary 26, 2022
Produce Safety Regulation – Small Farms, Non-sprout agricultural water requirementsJanuary 26, 2023
Produce Safety Regulation – Very Small Farms, Non-sprout agricultural water requirementsJanuary 26, 2024

The Produce Safety requirements are important especially when numerous recent food-illness outbreaks have been sourced to pathogen cross-contamination at the farms. For updated information on FSMA Compliance Dates, visit the FDA’s website.

Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene, and material handling equipment, is here to assist our customers with their site’s food safety and sanitation expectations. For more information, contact us.


  1. New Era of Smarter Food Safety | FDA
  2. USDA Releases Roadmap to Address Salmonella | Food Safety and Inspection Service
  3. One Health | CDC
  4. Issue 9 Revision | BRCGS
  5. FSMA Compliance Dates | FDA

Looking Back at 2021: A decade of FSMA, a new allergen, and updated guidelines

This year marked a decade since the FDA Food Safety Modernization Act (FSMA) came into effect as a means to facilitate preventive control interventions and lower foodborne illness outbreaks. Of course, despite the food industry’s primary focus being on managing employee safety and handling supply chain logistics during the ongoing COVID-19 pandemic, food safety still featured as one of the essential consumer-centric requirements from regulatory, standards, and industrial initiative perspectives. 

The following highlights some key food safety-related developments that happened in 2021: 



April 23, 2021 

The Food Allergy Safety, Treatment, Education and Research (FASTER) Act was signed into law, which adds sesame to the existing list of Big 8 major food allergens (joining milk, eggs, fish, shellfish, tree-nuts, peanuts, wheat and soy). This means that sesame must be labeled on all regulated packaged foods by Jan. 1, 2023. 

May 24, 2021 

The SQF Edition 9 Food Safety Codes, one of the GFSI Benchmarked global programs, became an auditable version standard. There is an enhanced focus on cross-contamination prevention and hygienic design, among other version improvements. 

July 2021 

New FSIS Guidelines for Controlling Salmonella and Campylobacter Bacteria in Raw Poultry were issued, which also relate to sanitation and HACCP requirements in poultry establishments. (It’s important to note: According to the CDC, Campylobacter and Salmonella are the #1 causes of bacterial foodborne illness outbreaks in the U.S.). 

September 2021 

The Retail Food Safety Association Collaborative launched an interactive U.S. Food Code Adoption Map. Through this collaborative platform, agencies such as the FDA and CDC, among others, will work together to reduce incidences of foodborne illnesses in the retail food establishments. (Note: Over 60% of U.S. food illness outbreaks are related to food retail and foodservice establishments). 

October 2021 

The first ever New Era of Smarter Food Safety Summit on Retail E-Commerce Foods was organized and well-attended by the FDA, other U.S. agencies, industries, academia, and stakeholders from about 49 countries. The panel and public discussions were centered around cross-contamination prevention strategies during food delivery, among other food safety control interventions. 

October – November 2021 

multi-state outbreak of Salmonella Oranienburg involving whole fresh onions were traced to a farm in Mexico. As of November 12, the CDC reported there were 892 illnesses in 38 states and territories. The FDA recommends that anyone who received, or suspects having received recalled onions use extra vigilance in cleaning and sanitizing any surfaces and containers that may have touched these products to reduce the risk of cross-contamination. This includes cleaning and sanitizing cutting boards, slicers, countertops, refrigerators, displays, and storage bins. 


Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene, and material handling equipment, appreciates and fully supports the role of the food industry and the front-line workers in assuring food safety and sanitation.  

 We earnestly look forward to a healthy, prosperous, and stable 2022 for all. Meanwhile, we wish everyone happy holidays and a safe season! 


Understanding SQF Edition 9 Changes from a Hygiene & Sanitation Perspective

Safe Quality Food (SQF) is a GFSI-benchmarked food safety and quality management system standard. As a globally recognized certification program that covers the food supply chain (from primary production to foodservice), it is a popular standard with at least 80% of SQF-certified global sites located in U.S. and Canada.

According to SQFI, SQF Edition 9 Code audits will begin on May 24, 2021. Prepare for these changes by reading the major sanitation-related updates from SQF Edition 8.1 to Edition 9, listed below:

1. SQF Edition 9 food safety code books have become more sector-specific:

Previous Edition 8.1 Codes

NEW SQF Edition 9 Codes

GMP Modules Covered


  Primary Production

 Primary Plant Production

 Primary Animal Production

Aquaculture (Seafood Production)

7, 8, 10, 18






(Processed) Food Manufacturing

Pet Food Manufacturing

Animal Feed Manufacturing

Animal Product Manufacturing

Dietary Supplements Manufacturing






Food Packaging

Manufacture of Food Packaging


 Storage & Distribution

Storage & Distribution


Food Retail

N/A (Still Under Edition 8.1)


Food Service

N/A (Still Under Edition 8.1)


  • By referring to relevant code books, a site should be better able to address specific food safety aspects such as hygiene and sanitation GMPs, and other programs specific to their industry sector(s).

Note: In the subsequent points, we’ll focus on key changes in SQF Edition 9 Code: Food Manufacturing.

2. There is a significant transformation of GMP module sections and elements. As a key example of this, some of the following Module 11 (GMP for Processed Foods) sections have been reorganized and/or updated:

 11.1 Site location & premises


11.1.1 Premise location and approval

11.1.2 Building materials

11.1.3 Lighting and light fittings

11.1.4 Inspection/quality control area

11.1.5 Dust, insect, and pest proofing

11.1.6 Ventilation

11.1.7 Equipment and utensils

11.1.8 Grounds and roadways

11.2 Site operation


11.2.1 Repairs and maintenance

11.2.2 Maintenance staff and contractors

11.2.3 Calibration

11.2.4 Pest prevention

11.2.5 Cleaning and sanitation


11.3 Personnel hygiene & welfare


11.3.1 Personnel welfare

11.3.2 Handwashing

11.3.3 Clothing and personal effects

11.3.4 Visitors

11.3.5 Staff amenities (change rooms, toilets, break rooms)

  • These changes have promoted more structural clarity in sanitation and related GMPs, and further reduced redundancies within the codes.

3. There’s an enhanced focus on cross-contamination prevention. Module element further states that: “… Unprocessed raw materials shall be received and stored separately from processed raw materials to avoid cross-contamination risk.

  • We’ve been saying consistently over the years that color-coding is a preventive control strategy that can work to significantly reduce contamination incidents within food facilities, whether we are designating distinct hygienic zones or separating color-coded tools in raw and ready-to-eat zones (RTE) to help avoid cross-contamination, or allocating identifiable cleaning tools for food-contact surfaces and non-food contact surfaces.

4. Module element on air testing requirements for high-risk processes states: “Ambient-air [in such areas] shall be tested at least annually to confirm that it does not pose a risk to food safety.

  • This requirement points to the need for maintaining air hygiene in high-risk zones such as RTE prep rooms or exposed product handling areas. Microbes or allergens may aerosolize and contaminate food and other surfaces. One way of controlling these hazards is through the right choice of mechanical tools and methods to ensure effective cleaning while preventing/minimizing contamination spread over time.

5. Foreign matter contamination control has become more relevant. Module element further requires that inspections must be performed to ensure “… plant and equipment remain in good condition, and [that] equipment has not become detached or deteriorated, and is free from potential contaminants.

  • Sanitation requires buildings and equipment be cleaned based on risk assessments and that only durable tools that can withstand operating conditions (i.e., varied temperature, chemical use, and mechanical stresses) over time are used. A common query we get is: Do metal detectable bristled brushes really work in reducing foreign matter contamination? A reliable technical study has shown that such kind of bristles do more harm than good since they tend to be more brittle and difficult to detect due to their size. A better solution would be color-coded, hygienically designed brushes with the right type of bristles secured onto the block.

6. Greater accountability of non-conforming site and equipment is now required. System element on internal audits and inspections states: “Regular inspections of the site and equipment shall be planned and carried out to verify GMP and facility and equipment maintenance are compliant to the Code requirements. The site shall also take corrections or corrective and preventive action, and maintain records of inspections and [on] any corrective action taken.”

  • Tools, as material handling or cleaning equipment, have the potential to easily become vectors of key contaminants, e.g., microbial biofilms, allergens, and foreign matter, and therefore, a contaminated tool should be treated like a non-conforming environmental surface that’s capable of creating a food safety hazard. Hence, cleaning tool maintenance becomes absolutely critical, and these implemented preventative actions should also be accounted for.

7. There’s a widened focus on the review of specifications critical to food safety. System element requires that: “Specifications for raw materials and packaging, chemicals, processing aids, contract services, and finished products shall be reviewed as changes occur that impact product safety… A list of all the above specifications shall be maintained and kept current.”

  • Tool specifications, in our view, can also impact food safety. Tools and utensils used in food processing operations must be compliant with 21 CFR FDA or equivalent regulatory requirements. Remco offers a range of FDA-complaint cleaning and material handling tools to our clients. Our FDA-compliant tools all have up-to-date technical specifications, declarations of compliance, guidance, and technical support, where required.

8. Expansion of hygienic design requirements for sites and equipment should be expected. With the alignment of SQF Edition 9 Codes to the new GFSI Benchmarking Document 2020, hygienic design industry scopes (i.e., JI and JII) should prominently feature in the near-future-standards. Moreover, benefits of ease in accessibility, inspection, cleaning, and maintenance of newly designed and installed sites and equipment shall eventually be realized by stakeholders through proper adoption of these scopes.

9. Food Safety Culture is a new component in the Edition 9 Codes. System element on management responsibility states that “senior site management shall lead and support a food safety culture within the site…” Food safety culture is defined as a set of food safety-related attitudes, values, and beliefs that are shared by a group of organization members.

  • Remco’s sales and support team can help by offering cleaning and material handling tools that meet the site’s food safety objectives by offering and recommending viable color-coding solutions in tool selection, usage, cleaning, storage, care, and maintenance requirements, which has been shown to strengthen food safety culture in an organization. To schedule a complimentary site visit with one of our trained and experienced business development managers who understand the SQF Codes and other food safety requirements, click here.

Please note: The author has sampled just the significant changes in SQF Edition 9 Food Safety Code for Food Manufacturing (assuming a transition from previous Edition 8.1 to new Edition) that support our company’s relevant viewpoints and best possible industry advice on key sanitation and hygiene requirements. Refer to the SQFI website as the best resource for comprehensive information on understanding and preparing for the SQF Edition 9 Code certification standard requirements for a site. For any queries on the advisory information above, feel free to email us at edtech@remcoproducts.com.



2020 Food Safety Development Recaps in Anticipation for 2021 and Beyond – The Future is Now!

With the COVID-19 pandemic raging on, it’s essential for the global food supply and food safety systems to keep delivering safe and quality food to consumers. Notably, the message from the FDA has been clear: “There is no evidence, as yet, regarding transmission of COVID-19 through food and food packaging.” 

However, out of an abundance of caution, we recommend that the industry and public-at-large keep abreast of relevant regulatory changes and follow science-based experts’ guidelines. Furthermore, as we all look forward to the progress on the vaccines, CDC/WHO/Public Health guidelines on minimizing the virus transmission and spread will still need to be followed.

This has definitely been a year of challenges for the food industry; however, let’s take a moment to recall some of the significant developments in food safety that should positively influence the North American food safety landscape in the years to come:

  • On July 13, the FDA unveiled its blueprint on the ‘New Era of Smarter Food Safety’ on creating a more digital, traceable and safer food network system to help reduce food illnesses in the U.S.
  • On August 22, the FSIS-USDA held a virtual public meeting to launch the “Roadmap to Reducing Salmonella” for meat, poultry, and egg products, and also to meet part of the Healthy People 2030 goals.
  • On November 18, the FDA released a new outbreak investigation tool that shall tabulate all foodborne outbreaks in an effort to initiate an early response from the FDA’s CORE (Coordinated Outbreak Response & Evaluation) team.

During the last quarter of this year, the FDA cited an inspectional violation to a manufacturing facility because of poor cleaning tool storage and use that led to RTE product cross-contamination. This reinforces the point we have been making for years that tools are vectors of contamination and so they need to be properly selected, used, cleaned, stored, and maintained.

Here is a list of key food safety-related developments to look out for in 2021:

  1. The FDA has just released the Proposed Rule for Food Traceability to provide the basis for additional traceability recordkeeping for certain foods based on Section 204 of FSMA. In 2021, we should expect a finalization of the rule and more guidelines, specifically on the Food Traceability List.
  2. SQF Edition 9 Code books were published during the latter half of 2020. In a nutshell, the new codes now reflect a more sector-specific approach, and with an emphasis on food safety culture. The new codes shall be aligned to the newest GFSI Benchmarking Documents Version 2020. SQF Edition 9 is expected to become the auditing standard from May 24, 2021 onward.
  3. GFSI version 2020 has also incorporated two new scopes of recognition on Hygienic Design i.e., JI and JII. We should expect more food safety system requirements regarding hygienically designed facilities, equipment, tools, and utensils in the very near future.

Important Company News:

  • In order to effectively serve grocery stores, our parent company, Vikan, has launched the Food Retail line of products and solutions. To download the guide, click here.
  • Remco now stocks high temperature resistant tools that can be effectively used for cleaning ovens or other heated surfaces. 
  • Our SQF practitioner-qualified, HACCP- and PCQI-certified Business Development Managers are now capable of conducting virtual site assessments. To request a site visit, contact us.

Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene and material handling equipment, appreciate and wholly support the role of the food industry and the front-line workers in assuring food safety and sanitation even during these trying times. 

We earnestly look forward to a healthy, prosperous, and stable 2021 for all. Meanwhile, we wish everyone happy holidays and a safe season!


ABC’s of Manual Cleaning Part I: Why is it important?

Part I

This blog series will go over the various ins and outs of manual cleaning and why it’s necessary for the safe production of food. It is essential for food processors to understand that the proper selection, use, cleaning, storage, and care of tools employed can prevent or minimize cross-contamination of food from hazards that are of a public health concern, e.g. microorganisms, allergens, and foreign materials.

 Cleaning and sanitation of environmental surfaces (both food-contact or non-food contact) and food production equipment can be a time-consuming operation in food facilities. Nevertheless, the maintenance of sanitary conditions to ensure product safety and quality is a regulatory, industry, and global food safety standard requirement.

The CDC estimates that every year, 1 in 6 people in the U.S. get sick from eating contaminated food. The use of contaminated equipment and utensils is one of the top 5 contributing causes to foodborne illness outbreaks. The key food safety hazards of public health concern are bacterial pathogens, allergens, and extraneous foreign material – and consequently, the cleaning methods and equipment capable of minimizing the risk of these hazards are required.

Industry cleaning methods may range from being process-specific (e.g. clean-in-place [CIP] for cleaning processing pipework and closed vessels]) to the much simpler, process-agnostic manual cleaning involving the use of brushes, scrapers, squeegees, etc.

Automated cleaning isn’t always foolproof

In contrast to manual cleaning, CIP normally involves the automated cleaning of equipment parts, such as the interior of pipes, vessels, or fittings without disassembly. This is generally done by pumping chemicals at a set concentration, temperature, and pH through the system for a controlled period of time at a flow rate that generates turbulence, which provides the mechanical action required as part of the cleaning process in a closed system. Clean-out-of-place (COP) involves disassembly and removal of parts to a remote automated cleaning system.

Once all the cleaning parameters used by these automated systems have been determined and programmed in, cleaning is as easy as pressing a button. However, the biggest limitation of CIP and COP cleaning is that the poor hygienic design of some equipment doesn’t always allow for a thorough using the automated method. Moreover, poorly designed pipework and equipment can result in contaminants getting trapped in narrow, inaccessible, or dead-end zones of the equipment or surfaces being cleaned.

CIP components like spray balls, and the valves, coupling, and sampling ports of CIP cleaned processing pipework also require regular disassembled and manual cleaning, to ensure the on-going efficiency and effectiveness of the CIP clean.

On an important note, the 3-A SSI industry cleaning standard clarifies that if food-contact components of equipment parts are not designed for CIP or other automated methods of cleaning, these parts should be cleaned and sanitized manually.

Key message: Clean before you sanitize

If the food equipment and surfaces aren’t cleaned properly, certain microorganisms may survive and persist by secreting a slimy, extracellular polymeric substance that can enmesh other organisms, nutrients, moisture, and foreign materials to form a biofilm that can firmly attach to a surface.  According to Moorman and Jaykus (2019), manual cleaning is important for surface biofilm removal because “one just can’t sanitize one’s way out of a persistent biofilm problem within a facility. Biofilm eradication, therefore, generally requires equipment teardown, deep-cleaning and sanitation, and a follow-up verification.”1,2

Proper cleaning of equipment and surfaces, therefore, is the first step toward better overall sanitation in food processing plants. Debra Smith, Vikan’s global hygiene specialist, clearly demonstrates the importance of manual cleaning action and the use of cleaning detergent and potable water to significantly reduce surface biofilm load rather than simply immersing a dirty piece in a chemical solution.Sanitization only follows after appropriate cleaning and rinsing of the surface.

In a nutshell, applying detergents and sanitizers alone cannot make a fundamental difference in removing surface biofilms. Manual cleaning will always be required in addition to other cleaning methods because there will always be hard-to-reach places where biofilms can form and can only be effectively be cleaned using hand tools.


Selected References:

  • Moorman, E., & Jaykus, L. A. (2019). Impact of Co-Culturing with Pseudomonas aeruginosa on Listeria monocytogenes Biofilm Physiochemical Properties and Sanitizer Tolerance. In IAFP 2019 Annual Meeting. IAFP
  • Remco (2020). The Role of Manual Cleaning in Biofilm Prevention and Removal. Whitepaper Link: https://go.remcoproducts.com/biofilms
  • Vikan (2020). Biofilm Demonstration Workshop. Video Link: http://vikan.com/media/10408/vikan-biofilm-movie.mp4

ABC’s of Manual Cleaning Part II: What does Manual Cleaning Involve?

Part II

In part one of this series, we discussed how manual cleaning involves the use of tools such as brushes, scrapers, and squeegees, along with other sanitation aids. This can effectively remove contamination from surfaces and equipment – and, in numerous instances, there may be no other practical option for cleaning some components or parts, even for the state-of-the-art automated systems. However, is manual cleaning just about, say, an employee using a hand brush to clean the internal surface of a soiled tank? Well no, it’s more than just that!

Understanding the concepts

Cleaning involves the removal or significant reduction of debris such as visible soil and contaminants from a surface. Industry best practices and regulatory requirements have always been to clean before you sanitize the surface.

Cleaning should not be taken as a one-size-fits-all activity, since several factors may influence the formulation of the right kind of parameters required to remove soils from a surface. The cleaning activity may be achieved in many ways, and a single cleaning method may involve overlaps of various cleaning activities:

As shown, manual cleaning may or may not involve the disassembly of the parts of equipment. Moreover, it is important to define the ‘level of clean’, which is a risk-based decision generally dependent on the type of contaminant (mainly microorganisms, allergens, and foreign material) to be removed from a surface. Some of the factors influencing the level of clean are as follows:

  • Whether the contaminant/hazard present is required to be eliminated or minimized to an acceptable level through the cleaning process.
  • Whether the cleaning activity itself should minimize the spread of the contaminant.
  • Whether the cleaning activity will have a negative impact on the surface being cleaned.
  • Whether the prevailing regulations, standards, and best practices will be met through the cleaning activity.

Choose the right cleaning activity

The choice of cleaning activity is crucial since we do not want to sacrifice effectiveness for the sake of efficiency. As shown below, certain cleaning activities may increase the risk of contamination spread, hence they are deemed high-risk.

As illustrated, hosing, especially at high pressure, is a high-risk activity compared to vacuuming. The former will generate liquid aerosols and droplets that will spread over a considerable distance, carrying with them contamination from the surface being cleaned. However, other common manual cleaning techniques, like scraping, scrubbing, or sweeping, are generally classed as medium risk, requiring some caution in their performance. For instance, scrubbing dirty parts using a brush is better done submerged under the water to minimize the spread of droplets generated by the scrubbing action.

Select the right tool for the right job

The selection of manual tools is vital, since this can greatly influence its cleaning efficacy and durability, and its subsequent cleaning maintenance and storage. Some useful tips on tool selection are provided below:

  • Choose the right bristle type for brushes and brooms. Stiff bristled brushes may scratch and deteriorate sensitive surfaces, while very soft bristles may be ineffective in removing rigid soils from surfaces but are good for sweeping up fine powders.
  • It is best to use total-color tools that are easily identifiable, trackable, and manageable in their respective hygienic zones at a site. Color-coding may also be used to separate to food-contact and non-food contact tools. This goes a long way in reducing cross-contamination in food plants.
  • Where higher temperatures are encountered in operations, use tools capable of withstanding high temperatures.
  • Evaluate whether special application tools will be required, say, for conducting deep cleaning, detailed cleaning, or high- or low-level cleaning.
  • Hygienically designed tools normally have smooth surfaces, rounded edges, and no crevices where contaminants can accumulate and be difficult to remove. Remco’s one-piece construction scoops and shovels, and Vikan’s UST brushes and Ultra-Hygiene squeegees are great options for hygienic tools to use for food manufacturing facilities processing high-risk products.


Selected References

ABC’s of Manual Cleaning Part III: How does Manual Cleaning Work?

Part III

In this part, we address the key question: how is the manual cleaning process typically implemented? A robust manual cleaning program is generally an integration of the best of science and management – which go into developing Sanitation Standard Operating Procedures (SSOPs) that should be well-understood by the employees implementing the program.

Assess the TACTER Parameters

The TACT circle was originally developed by Dr. Herbert Sinner in 1960. This model lists the parameters needed to remove soil from a surface. Remco has added two parameters, “Employees” and “Resources,” to make it a holistic model for effective cleaning. Please refer to the comments I made on the TACTER section notes in the 5S White Paper:

Where a thick layer of allergens, foreign matter, or biofilms build up on a surface, the TACTER requirements are intensified, such as a worker needing to do intense manual scrubbing to remove such contaminants.

Evaluate Cleaning Program Considerations

The SAVER2 model was developed by Remco to assist with understanding the points necessary to build a comprehensive cleaning and sanitation program:

The following important questions are taken into consideration:

  • What type of Surface is being decontaminated?
  • What is the nature of the Soil being removed or reduced to an acceptable level?
  • What is the Aim of the decontamination action?
  • What step-by-step decontamination Activity is being implemented?
  • Is the decontamination process Validated?
  • Is the decontamination process adequately Verified?
  • How Effective is the decontamination activity?
  • How Efficient is the decontamination activity?
  • Are the processes supported by valid scientific, technical, or credible References?
  • Are Remedial actions being put in place to correct or prevent anything significant that could go wrong?

Cleaning decisions must be risk-based

Depending on the nature of the soil, surface, and other cleaning considerations, the site may decide to conduct dry-cleaning, wet-cleaning, or controlled wet-cleaning:


Dry-cleaning, where little or no water is used, is normally practiced in environments where low water activity foods (e.g. flour, milk powder, biscuits, etc.) are manufactured. This is because the introduction of water could provide a medium for microbial growth. However, care is taken not to aerosolize allergen ingredients in the process, as this could create cross-contact issues.

In wet-cleaning, water is used for removing soluble or emulsified soils from the surface. This is the most common method in operations processing high water-activity foods (e.g. meat, beverages, etc.). The biggest drawbacks faced in such environments are problems related to condensation and waste-water issues.

However, in several food plants, controlled wet cleaning at a separate sanitation station is conducted to avoid any contamination or aerosolization occurrences. This may be done to clean small equipment pieces or even large, dismantled tanks.


Document and implement the cleaning steps clearly

More importantly, employees implementing and maintaining the cleaning program must be well-educated and trained on the cleaning tasks. For a wet-cleaning operation, the following are the cleaning steps:

  • Secure equipment, disassemble, and dry-clean to remove gross debris.
  • Pre-rinse equipment surfaces with potable water, from top to bottom.
  • Apply detergent and foam, and scrub from bottom to top.
  • Post-rinse with potable water and conduct self-inspection (by the operator).
  • Conduct a formal post-sanitation inspection (usually done by QC).
  • Sanitize (with approved sanitizer) and assemble the equipment.
  • Dry equipment and let a supervisor verify as part of the pre-op inspection.


Using the right detergents and approved sanitizer concentrations is critical to ensuring cleaning effectiveness.


Next Steps

In our next blog, we’ll discuss how to set the frequency and locations for manual cleaning. Stay tuned!


Selected References:

ABC’s of Manual Cleaning Part IV: Where and When to Manual Clean?

Part IV

Part three briefly explained how to implement a typical manual cleaning process. In this part, we will explain the basics of how to identify the locations or areas that require cleaning, and how to determine how often they’ll need cleaning. These steps are very important for the establishment of the consistently sanitary environment required for safe food production.

Keeping your master cleaning schedule up to date

Every possible area, spot, or location that could potentially create an unsanitary or unhygienic food production environment if left uncleaned should be systematically accounted for. This denotes the concept of risk-based cleaning.

Generally, a typical cleaning schedule is used to document the provision of effective facility, fixture, equipment, tool, utensil, clothing, amenity, and external area cleaning. An illustration of the elements is provided below:

Any changes to the schedule should be clearly justified and be reflected in the procedures, training programs, and reviews.

 Revisiting the ‘level of clean’ for environmental surfaces

It is essential to verify whether cleaning has been carried out effectively, and normally, the ‘Level of Clean’ of an environmental surface falls under one or more of the following classifications:

  • Sanitary: The surface must be free of pathogens. In the interest of public health, the FDA sets a zero-tolerance level for foodborne illness causing microorganisms. Micro-swabbing accompanied by testing the surfaces is generally conducted.
  • Micro-clean: Apart from keeping surfaces pathogen-free, spoilage organisms should also be significantly reduced. This not only enhances food quality, but also improves the hygienic condition of the environment.
  • Allergen-clean: This involves cleaning surfaces to remove allergens. Rapid detection allergen test kits are available to verify the presence or absence of specific allergens on the surface after cleaning.
  • Quality-clean: Here, surfaces are cleaned to remove debris, dirt, or soils from the surface, which may affect product quality. Post-cleaning verification using ATP rapid detection swab is common. Acceptable ATP thresholds need to be established and records maintained for inspection by auditors as evidence of assuring a quality-clean.

It is not generally acceptable to conduct “as-needed” or “emergency cleaning”. Instead, scheduled cleaning of food contact (FCS) and non-food contact surfaces (NFCS) should be the norm, with FCS (e.g. equipment surfaces) being regularly cleaned and sanitized before and after use. Equally important is cleaning NFCS (e.g. drains, ceiling fixtures, wall junctions, equipment bearings, etc.) since contaminants can easily transfer from these areas to food and food contact surfaces.

For the control of pathogens, like Listeria monocytogenes, a site can adopt a Seek and Destroy approach that has been reflected in the FDA Listeria Guidance for RTE Foods. Here, the goal is to find Listeria in locations where you’d least expect to find them and use appropriate controls, like deep cleaning, scrubbing, and biofilm removal strategies, to eradicate any micro-harborage areas.


Creating your Manual Cleaning Plan

Cleaning is not a “one-size-fits-all” approach, as different locations may require the use of specialized tools, as illustrated below:

What’s next?

To get the best outcomes from manual cleaning, allocating responsibilities and accounting for the effectiveness and efficiency of the tasks is crucial. In our next blog, we’ll focus on understanding the people or departments responsible for planning, conducting, reviewing, and maintaining cleaning programs and tasks.

Selected References:

  • Remco (2020). The Role of Manual Cleaning in Biofilm Prevention and Removal. Whitepaper Link: https://go.remcoproducts.com/biofilms
  • S. Food and Drug Administration. (2017). Draft guidance for industry: control of Listeria monocytogenes in ready-to-eat foods. Fed. Registrar, 82, 4803-4805.

ABC’s of Manual Cleaning Part V: Who is Responsible for Manual Cleaning?

Part V

Part four covered critical locations and the frequency of manual cleaning in those areas. In this part, we are going to briefly focus on understanding the relevant departments involved during the cleaning and sanitation process within a food facility.

Not a one-person job

Developing, implementing, and maintaining cleaning programs within a food plant is no small feat. Such an important activity cannot be left solely to the facility sanitation manager–it requires close and coordinated collaboration between many departments. Food safety and quality assurance, production, maintenance, and purchasing, to mention but a few, should all be part of the process. It involves the scheduling of tasks, selection and evaluation, usage, storage, care, and re-ordering of sanitation aids such as chemicals, tools, etc.

Part of the cleaning and sanitation tasks could be outsourced to third-party contractors, who may perform third shift or after-hours sanitation, and are therefore considered part of the food safety and sanitation team. Valuable input or feedback from regulatory inspectors; certification auditors; suppliers of cleaning tools, equipment, and chemicals; subject matter experts; and even customers, are also an essential part of a successful program. Furthermore, the intricacies of a robust cleaning program will depend on what is required to ensure that food products are free from disease-causing organisms and other contaminants that significantly impact on food safety and quality.

Accounting for manual cleaning responsibilities

Defining, implementing, and maintaining a Master Cleaning Schedule can become an intensive exercise.

If we look at the Master Cleaning Schedule shown below, it requires additional independent and trained personnel to develop the programs; monitor the progress; and verify or audit the process, and requires that responsibility for each of these be allocated, along with proof of documentation that these actions happened.

Toward a Hygiene and Sanitation Culture

The entire organization, from top management to every employee, needs to be committed to the production of safe food under sanitary conditions, as cleaning comprises an important component of a food safety and quality management system.

As Frank Yiannas, FDA deputy commissioner, rightly points out: “Food Safety Culture is about creating a behavior-based food safety management system.” Hence, an all-inclusive integrated sanitation approach (as we’ll discuss in Part 6 of this blog series) becomes a key aspect of the site’s education and training programs, which should be seamlessly embedded into the overall organizational culture.

Some ways of improving hygiene and sanitation culture when using manual cleaning tools may be as follows:

  • Use of FDA-compliant, color-coded, hygienically designed, durable, and high-quality cleaning tools.
  • Education and training of employees on the why, what, where, when, how, and who of tool selection, care, cleaning, storage, care, and maintenance.
  • Motivation of employees through transformational leadership and learning opportunities.

What’s Next

In our next blog, we’ll understand the key regulations, standards, and industry best practices that support a manual cleaning program for a food facility.

Selected References:

  • Smith, Debra (2017). Optimizing Food Safety Through Good Cleaning Tool Maintenance. Whitepaper Link: https://remcoproducts.com/cleaning-tool-maintenance/
  • Yiannas, F. (2008). Food safety culture: Creating a behavior-based food safety management system. Springer Science & Business Media.

ABC’s of Manual Cleaning Part VI: Regulatory and Standards Expectations Regarding Manual Cleaning

Part VI

Part five of our blog series focused on allocating various manual cleaning responsibilities, and on how to create a robust hygiene and sanitation culture within an organization. In this blog, we’ll look at the U.S. regulatory requirements, key industry, and global standards, and the integrated sanitation best practices that would support a manual cleaning operation.

Understanding the U.S. Regulatory Context

Cleaning and sanitation are key regulatory requirements in the food industry. According to recent FDA estimates, about 1 in 3 U.S. food recalls may happen because of poor sanitary practices, and a significant proportion of these relate to Salmonella and Listeria monocytogenes cross-contamination incidents within a food plant.

The 21CFR 117 FDA regulations are clear about the importance of regular cleaning to prevent allergen cross-contact and cross-contamination of food products. Section 117.35 on “Sanitary Operations” clarifies that the food-contact surfaces of equipment must be cleaned and sanitized as necessary, and that non-food contact surfaces must be cleaned regularly.

Moreover, FSIS legislation based on Federal Meat Inspection Act, Poultry Products Inspection Act, and Egg Products Inspection Act also emphasizes proper cleaning and sanitation to ensure the sanitary conditions necessary to produce safe food. Cleaning surfaces in these establishments will need some efficient and effective form of mechanical agitation using manual cleaning tools to remove rigid soils, e.g. surface biofilms.

Industry and Global Standard Expectations

GFSI-based certification standards have provided a series of benchmarks for harmonizing global food safety programs to an agreed-upon level of industrial expectation. The common standards focus greatly on using the right types of cleaning tools, as stated:

  • According to BRC Global Food Standard – Food Safety, Section, “Cleaning equipment shall be hygienically designed and fit for purpose, suitably identified for intended use (e.g. color-coded or labeled), cleaned and stored in a manner to prevent contamination.”
  • SQF Code, Section states: “All equipment cleaned after use or at a frequency to control contamination and stored in a clean and serviceable condition to prevent microbiological or cross-contact allergen contamination.”
  • FSSC 22000 – ISO 22002 Prerequisite Programs on Food Safety – Part 1: Food Manufacturing, Section 11.2 on ‘Cleaning and Sanitizing agents and tools’ states: “tools and equipment shall be of hygienic design and maintained in a condition which does not present a potential source of extraneous matter.”

As explained in part one of our blog series, during the sanitation process, manual cleaning of surfaces and equipment becomes inevitable, since, according to 3A-SSI Standards, if the food-contact components of equipment are not designed for CIP or other automated methods of cleaning, these parts should be cleaned and sanitized manually.

Embracing an integrated sanitation approach

Sanitation is not just about cleaning and sanitizing surfaces and equipment but is a holistic risk-based methodology aimed at significantly minimizing or preventing allergen cross-contact and/or microbiological and foreign material cross-contamination incidents within a facility. Illustrated below are the components of an integrated sanitation approach:


In a nutshell, here is a good list of industry best practices that may be integrated into a sanitation program:

  • Color-coding – Use total-color tools to differentiate between hygienic zones, or allergen zones, or to distinguish between tools used for cleaning food-contact and non -food contact surfaces.
  • Hygienic Zoning – Implement a good zoning approach that separates raw and finished products, allergen products from non-allergen products, and thus prevents, or significantly minimizes, cross-contamination incidents. Proper zoning standards also support environmental monitoring and control programs.
  • Hygienic Design – Facility surfaces, equipment, utensils, and tools of a hygienic design and construction are more quickly and easily cleaned after use and pose less risk of contaminant harborage and transfer.
  • Process Flow Management – Manual cleaning and tools streamline processes because, in part, proper selection, storage, cleaning, and care of tools prevent contamination incidents in a food plant.
  • 5S – Workplace organization methods that incorporate elements of Sort, Straighten, Shine, Standardize, and Sustain into a manual cleaning program will be of benefit.


Manual cleaning, as an inevitable part of FDA FSMA Sanitation Control; FSIS-USDA regulatory requirement; and global and industry standard expectations, provides a proactive measure that should not only prevent or minimize food recalls, but also go a long way towards avoiding or reducing site inspection violations and foodborne illnesses.


Selected References: