Q. We have been tasked by the FDA to develop a "Maintenance Sanitation Program" that supports adequate cleaning of maintenance supplies, new equipment, parts, hand tools, etc. This is separate from our Sanitation Standard Operating Procedure (SSOP). What would be your perspective on the differences between these two documents?
A. Traditionally food plant sanitation is broken down into two parts. First, those surfaces that come into direct connect with the food product; second, those surfaces that do not come into direct contact with the food product. These secondary types of items usually include areas like walls, floor, ceilings, roofs, lights and fans.
Regardless of the type of sanitation program you are developing, any food sanitation procedure will require three basic steps. First you clean, then you sanitize, then you validate. The primary difference will come from the methods and timing used for each of these steps. It would appear that the FDA would like to see you document the procedures you are using in regard to your maintenance equipment, supplies, parts and tools.
As you deal with a maintenance sanitation program, it is always good to remember that cleanliness is an unnatural condition because all surfaces get dirty, and your maintenance items are no different than any other surface. Dirt or contaminants are any unwanted matter on the surface of an object and may be visible or invisible. Invisible contaminants primarily would be some type of unwanted microorganisms.
The process of cleaning deals with the removal of these unwanted items from the surface area. Once the surface has been cleaned, sanitizing usually will be accomplished using heat or chemicals. In the case of your maintenance items heat may be the preferred method of sanitizing, and you will find various sanitizers available on the open market that will meet your specific needs.
The most critical item in your maintenance procedure is the validation step. Cleaning and sanitizing procedures should be regularly monitored using inspections and audits to ensure you have documented the steps involved and that the items were sanitized and then stored in a clean place until used.