Process and Operations

MRO Q&A: Legislation on Food Plant Maintenance Issues

MRO Q&A is a Food Processing series addressing maintenance, repair and operational issues in food plants.

Q: Where can I find information on legislation on food plant maintenance issues?

A:You are casting a really wide net here. You need to determine what types of food plant issues to include in your scope. I would suggest product, people and process, all as they relate to maintenance practices. In other words: product safety, human safety and asset preservation.

A few subsets come to mind, including many requirements, such as maintenance, sanitary design, process controls, lubrication, utility, providing disabled access, human safety, indoor air quality, and preservation of physical assets.

There are several agencies where you will find specific legislation on food plant concerns. The main ones are USDA, FDA, OSHA, state and federal EPAs, the Dept. of Homeland Security and the International Organization of Standardization (ISO). The data is voluminous.

In addition to the rules these agencies enforce, there are specific pieces of federal legislation you may find helpful, especially the FDA's Food Safety Modernization Act and Dept. of Justice's Americans with Disabilities Act. Don't overlook the value of reviewing the state design and construction codes for the state you operate in. These sometimes have a direct effect on the maintenance activities of a facility.

Another alternative to reading through dry legislation is to tap into industry associations. Your plant issues may be better handled by dealing directly with the associations with ownership for specific concerns. Some of those organizations are the SQF (Safe Quality Food) Institute, Society of Tribologists and Lubrication Engineers, Cooling Tower Institute, Industrial Institute of Ammonia Refrigeration, National Association of Manufacturers and NSF (National Sanitation Foundation) to name a few.

Delving into legislation can be time-consuming and could lack clarity. My advice would be to work through your direct vendors on specific problems first. If you are not satisfied with their solutions, contact the organizations mentioned earlier. If you are not comfortable with the response you get, you may have to dig into the legislation, but it may be painful.