As regulations tighten in the food industry, smarter technology may come to the fore, including two particular safety and documentation features for regulated plants: electronic signatures, as part of 21 CFR Part 11 compliance, and version control for preventive maintenance (PM) routines.
With features like these, we can create a very flexible set of abilities for food processors,” says James Jones of Infor. He says a poultry plant may want to attach a time/date stamp and user credentials on certain activities, giving it the ability to see who changed work order materials, tools or instructions, and when. In more strict plants subject to FDA rules, electronic signatures can be used.
While the technology is well established in pharmaceuticals, this is not a common practice or need in food processing — yet.
Pat Conroy, president and founder of MicroMain Corp., Austin, Texas — the system at HP Hood — expects the FDA to lead to greater food plant regulations “due to the salmonella and other food safety issues we’ve all seen in the news. They are going to get tougher, and inspections are going to get more frequent.” He notes that his system ships with 500 standard reports plus source code for IT-savvy users to modify as well as offering customization services.
Nelson says few if any reports of this nature have been customized, although there are plenty of food processes that call for documentation that goes beyond parts and work orders. For example, the HP Hood plant’s ultra-high temperature processing lines are subject to the FDA Pasteurized Milk Ordinance as well as state regulations. Maintenance departments must maintain all the equipment involved in meeting the ordinance — from motors, drives, sensors and valves to the larger mechanical and automation systems they comprise.
“If we don’t maintain all of those things, we can’t run the plant. The state would shut us down,” says Nelson. Instead, his personnel do inspections more frequently than required, document their work in the system and catch problems before a failure is imminent.
“Maintenance has gotten incredibly complex,” says Craig Miller, who spent 19 years at a large baking plant and was president of the users group of the Maintimizer CMMS from Ashcom Technologies, Ann Arbor, Mich., before becoming that company’s sales and business development manager. Decades ago, he says, “All a maintenance manager had to worry about was getting the job done by the end of the day. Today, it’s all hands on deck.”
He says companies should start with their own regulations, standards and practices before diving into the software. “Say you’ve got a 50-ft.-long Teledyne Readco oven with brownies going through it. Your CMMS details the asset — the oven, combustion details, model number, serial number, what parts are on it ... what's been replaced, performance trends to analyzed. All your PMs [preventine maintenance] would be generated based on that information, with frequency and tasks defined by and based on standard operating procedures.
“The system can't just say ‘check conveyor.’ Well, check it for what? Because if an oven’s down in a bakery, you could lose days of production.”
There is a possibility that CMMS/EAM systems can become a cross-functional documentation across the plant. Management mandates to conserve budgets and information technology standards are factors that could hasten such integration.
Infor’s Jones notes a gradual movement toward centralized document repositories. He sees further cross-functional features becoming more important as maintenance work flows better coordinate with production systems so, for example, PMs can be scheduled without interrupting manufacturing. By assigning a set of production resources that would be impacted by a given piece of equipment, he says, the system can tell the user how production processes, people and productivity will be affected.
While Infor has proprietary methods for this, others confirm the importance of production-and-maintenance synergy.
“If the marketing and sales guys sell a major order to an account like ShopRite or Acme [supermarket chains],” Hood’s Nelson says, “we don’t promise the world and then have trouble meeting the orders. Our system has supported us in the ability to maximize our capacity and be able to identify what our capability is.”
Note to Compliance Managers Plant Wide
Every food plant has its own standards and practices, and a CMMS may provide new opportunities to bring cross-functional departments together to eliminate duplication of efforts and software systems.
“It’s been my goal to get our users to realize there’s a bigger spectrum here,” says Ashcom Technologies’ Craig Miller. He says sanitation, quality, research, environmental, safety and other non-maintenance personnel all can use a single CMMS/EAM system and eliminate the duplication of efforts in multiple software systems. Consider how the maintenance system can bring together these people and practices:
Food quality/safety: Work orders can be printed with accompanying SOPs, GMPs, HACCP procedures and more. “Quality and research can actually tie into the system. Maybe there are metal detectors or checkweighers they need to maintain and calibrate for their inspectors, and they need to know who worked on them last,” Miller says.
CIP/Process sanitation: The sanitation department can share documentation such as CIP procedures, which can be hosted in the maintenance system. “I coach many customers on the use of CMMS for CIP. You’d be amazed how many sanitation departments don’t use anything to document this.” It’s a no-brainer to use the CMMS to track cleaning for assets already in the maintenance system, he says. Documentation, which can include images and material safety data sheets (MSDSs), improve safety in handling chemicals as well as complying with FDA regulations and other standards.
Worker safety: When an unsafe platform in front of an oven is classified as part of the oven, the safety manger may write a note or a safety work order. But it lacks the depth that a CMMS/EAM system can bring to track the problem and priority and its cause. A recurring problem can be diagnosed for its root cause. That fix can be a particular operator that needs retraining or a flawed work process that needs to be revised.
Security: The CMMS can track personnel from building and site entry to exit, including through hazardous area access, providing procedures and tracking locks and gates. RFID technology can be applied to personnel, materials and assets throughout the plant.
Environmental: The CMMS can record the delivery of liquid ingredients into 2,500-gallon tanks, handling of 5,000-gallon grease traps, the movement of other materials per EPA Title V operating permits (also 40 CFR part 70), air emissions and effluent. Likewise, the system can manage MSDSs and reporting under SARA Title III/the Emergency Planning and Community Right-to-Know Act.
At the docks: While maintenance there is relatively low, plants still need to meet safety and cleanliness standards that the maintenance system can track, such as forklift maintenance, the use of food-grade grease when food contact is an issue, segregating food materials from cleaning chemicals and other documentation required by FDA regulations or standards such as those from AIB.
Pest control: A grain manufacturer realized its CMMS could be a part of its AIB compliance when it numbered and tracked its 150 rat traps in the system. “They have to know where those traps are in the building, they can’t just put them out there and forget about them,” says Miller. A clipboard can be lost and it lacks the ability to easily track the traps and their contents.