FOOD SAFETY AND SANITATION Chapter{ Learning Objectives Select appropriate controlled storage methods for all non-ingredient chemicals identified at your facility Segregate chemicals from non-compatible chemicals and other materials Separate chemical categories (maintenance, sanitation, and pest control) to prevent crosscontamination of food-contact surfaces Use a chemical log to document all chemicals at the facility, along with associated information for each chemical Maintain a chemical inventory at each chemical storage location Retrieve and follow important storage, usage, application, handling, and disposal information from a chemical label and Safety Data Sheet Control secondary chemical containers to prevent product contamination Approve any chemicals brought on-site for the intended application using a chemical approval process Use contractor control measures to prevent pest control and maintenance chemicals brought onsite from contaminating products Table of Contents...2 Controlled Storage...2 Segregated Storage...3 Chemical Log...4 Chemical Inventory...4 Labels and Safety Data Sheets...5 Container Control...5 Chemical Approval...6 Contractor Chemicals...7 Reference Card...8 Chemical Identification Workshop...10 Chemical Storage Workshop...11
FOOD SAFETY AND SANITATION } Chapter Chemicals, including those used for production, sanitation, maintenance, pest control, and laboratory work, are essential for the proper functioning of a food plant. However, if the wrong chemicals are used or if the right chemicals are misused, there is a risk of product contamination that could lead to serious health risks for consumers. Mishandling chemicals can also lead to health risks for employees. A complete and effective chemical control program must be in place to ensure that necessary plant chemicals do not pose a risk to product or personnel. This chapter will focus on product protection. The first step in developing a chemical control program is to identify all chemicals on-site. This should include all areas of the facility, with the possible exception of segregated office areas. If there are chemicals used exclusively in an office area that is segregated from production and for which there is little traffic between the office and product areas, then it would be reasonable to exclude them. However, if there are offices in or adjacent to product areas, such as a receiving office in the warehouse, chemicals there should be included. Others areas to include are: restrooms, laboratories, maintenance shops, sanitation rooms, warehouses, production and packing areas, break rooms, locker rooms, refrigeration units, and boiler rooms. These areas should be searched and all chemicals found should be logged. It is important to remember that chemicals may be in liquid, solid, or gas form and include store-bought chemicals. Controlled Storage The purpose of controlled storage is to allow only personnel who are authorized (trained) to access and use chemicals. Controlled storage is best provided with a small or large locked area where only authorized personnel are allowed access. It can be a cabinet, a cage, or 2
FOOD SAFETY AND SANITATION even an entire room, such as a laboratory or a maintenance shop. For example, if all personnel who are authorized to be in the laboratory are trained and authorized to use the chemicals in the laboratory, the chemicals in the laboratory do not need to be kept locked, only the laboratory itself would be locked. If such an area is used, the doors must be locked when no one is present to maintain control and to prevent unauthorized personnel from gaining access to chemicals. Signage indicating that only authorized personnel are permitted is also advised. Chapter } Segregated Storage Chemicals in storage must be segregated from non-compatible chemicals and other materials. For example, an acid chemical should never be stored near chlorine or an alkaline. Mixing them intentionally or accidentally would give off a very dangerous chlorine gas that may cause serious injury. Certainly, chemicals should not be stored with ingredients, packaging, work-in-progress, or finished product. The concern is that chemical spillage or even vapors could lead to product contamination. Chemical categories must also be separated. For example, maintenance chemicals must not be stored with sanitation chemicals and sanitation chemicals must not be stored with pest control chemicals. If there is cross-contamination among chemicals, it could lead not only to a potential occupational safety hazard, but also to potential product contamination. For example, if a chemical that is not approved for food-contact surfaces contaminates a sanitizer that will be applied to the equipment, this would likely lead to chemical contamination of the product. Using this same concept, it may even be necessary to further segregate chemicals within a particular category. For example, storing all sanitation chemicals together could pose a risk. Consider a janitorial cleaner, such as toilet bowl cleaner, being stored directly above a food-contact surface cleaner. If there was crosscontamination, the non-food approved chemical could ultimately come in contact with a food-contact surface. There is a similar concern with food grade and nonfood-grade lubricants. These items must be segregated from one another, or at a minimum, food-grade lubricant must be stored above nonfood-grade. 3
FOOD SAFETY AND SANITATION } Chapter Chemical Log A chemical log includes the identification of all chemicals on-site along with associated information for each chemical. This additional information should include the location(s) where the chemical is designated to be stored, the method and location for use, approved use of the chemical, and personnel authorized to use the chemical. Depending on the chemical, these descriptions maybe general or very specific. For example, a lubricant may be listed for use on bearings, or it may specifically be listed for use on the line 1 dryer bearings. Persons authorized to use a specific chemical may be general, such as mechanics, or very specific, such as a certified welder. Chemical EPA Approved Approved Use Authorized Name # Storage Person(s) Super Kleen 1234 Cage Food-Contact Sanitors Surfaces (foamer) Lube Plus 555 Shop Oven Chains Mechanics Silver Nitrate 777 QC Lab Salt Titration QC Supervisor Chemical Inventory An inventory of chemicals should be maintained at each chemical storage area. The inventory includes the name and quantity of the chemical. Each time an authorized person uses the chemical, the date and quantity used is recorded. When additional suppliers are added to the storage location, this quantity is also recorded. This log provides valuable tracking information if there is suspected product contamination. For smaller containers, such as one gallon jugs or cartridges of lubricant, inventory is not tracked by each application, but rather each time a new container is opened. Lube Plus Inventory (EPA #555) Cabinet 4 Date Mechanic Units Added Units Initials Removed 2/5/12 SRL 48 - - 2/7/12 KRR - - 2 2/15/12 MAJ - - 1 4
FOOD SAFETY AND SANITATION Labels and Safety Data Sheets For each chemical used on the premises, a label (other than the one affixed to the chemical container) and a Safety Data Sheet must be maintained. The label must be separate from the one on the container for a couple of reasons. At some point, the container will be discarded and the label will be lost. In addition, the label on the container may become damaged and unreadable from spillage, heat, or moisture. The label provides important information about how the chemical is to be stored and applied. It may include dilution information and whether or not the material is approved for food contact or use in a food facility. The label will also provide important disposal information for unused chemicals or empty chemical containers. The Safety Data Sheet provides important safety information about the exposure to the chemical, such as what health or physical effects may occur if it is ingested or inhaled. This exposure could affect employees or consumers if there is a contamination issue. A file of obsolete labels and Safety Data Sheets should be maintained in the event that applications are being questioned. An old label can demonstrate that a chemical was applied according to the instructions that were available at the time of application. When a chemical is no longer used and will not be purchased again, the Safety Data Sheet must be retained in compliance with government regulations. For example, in the United States, OSHA regulations require the Safety Data Sheet or other chemical identification to be kept for 30 years. Container Control Many of the chemicals used in a food plant will be moved to a secondary container for use. These containers include items such as spray bottles, pails, and grease guns. It is imperative that secondary containers are labeled to prevent product contamination. For example, if a nonfood-contact cleaner is to be placed in a spray bottle, it must be clearly identified for use with that type of cleaner. The label must prevent the use of the same Chapter } 5
FOOD SAFETY AND SANITATION } Chapter spray bottle for food-contact cleaner or for a processing aid, such as mineral oil, at a later date. Color-coding and labeling are the most common ways to identify containers. Typically, color-coding is used to identify the category or department that uses the chemical, such as sanitation or maintenance. Labels are used to identify the specific chemical within that department that each container is designated for. Labels often consist of laminated tags or engraved identification tags to prevent the label from wearing off. Remember, in the US, secondary container labels must at least show the name of the chemical and the associated hazard warning to comply with OSHA. If color-coding is used, it is recommended that signage identifying the color-code should be posted in key areas. These areas include where the containers are stored and where the containers are used. Once the original contents are used, follow the disposal directions on the container label, which often recommend that the container be triple rinsed, punctured, and then properly disposed of. It can be tempting to reuse a five gallon bucket for other purposes, but this causes several concerns, including: the original contents may not be completely removed original labels may still be present it creates confusion about the actual contents in the container The label is the law for container disposal and must be followed. Chemical Approval Chemicals must go through a chemical approval process before they can be used on the premises. This process will ensure that chemicals brought on-site are approved for the intended application, that supporting controls, such as approved storage and training, will be provided, and that supporting documentation, such as labels, Safety Data Sheet, and updated procedures are established. 6
FOOD SAFETY AND SANITATION The approval process consists of: Identify the person(s) who are authorized to approve and purchase chemicals. This may be by department. Identify, organize, and file documentation that must be obtained (Safety Data Sheet, sample label) for each chemical. Obtain documentation for any chemical to be used for productcontact surfaces or potential incidental contact stating that it is approved for this application in food processing. Ensure that new chemicals are added to the chemical log and quantities are indicated on the inventory. Ensure that associated procedures, such as those for cleaning, lab analysis, or preventive maintenance have been updated to reflect the new chemical. Establish a training plan that includes proper use, handling, storage, application, and health effects for the implementation of the new chemical. Chapter } Contractor Chemicals Contractors working on-site often need to bring chemicals with them that are not already included in the site s chemical control program. The two primary types of contractors who bring chemicals on-site are pest control and maintenance; although, there may be others, such as contracted janitorial services. Pest control contractors typically provide service on a routine frequency. A pre-established list of pest control chemicals (pesticides, monitoring blocks, pheromones, etc.) that they intend to use is typically included in the facility s integrated pest management program. Any pesticides used inside the facility, including support areas, such as break areas, must be approved for use in food handling facilities. While many rodenticides are approved by law to be used inside facilities, it is advised that they not be used inside since rodents may transfer them to product or product-contact surfaces. For all pesticides applied on the premises, inside or on the grounds, a sample 7
FOOD SAFETY AND SANITATION } Chapter label and Safety Data Sheet must be maintained, regardless if the pesticide is stored off-site. The facility and contracted pest control service must address whether or not pesticides will be stored onsite. If they are stored on-site they must be fully segregated from production materials (product, ingredients, and packaging) and fully segregated from any other chemicals. They must be kept in a locked and labeled room that is ventilated to the outside. Further information about pesticides is provided in the Integrated Pest Management Chapter. The non-routine contractor, such as a maintenance contractor that may be on-site for a specific repair or installation, is more difficult to control from a chemical standpoint. Upon arrival, the contractor must be informed about the facility s chemical control program. The contractor should then disclose any chemicals that he or she is bringing on-site and it should be determined if Safety Data Sheets for these chemicals are available to site personnel. The chemical should not be permitted in the facility until the Safety Data Sheet is obtained. It must also be determined who will be responsible for ensuring that these chemicals are secure, either through locking or supervision. Reference Card Use this Reference Card to ensure that necessary plant chemicals do not pose a risk to product or personnel. When you are ready, proceed to the workshops to apply what you have learned about chemical control to real-life situations. 8
FOOD SAFETY AND SANITATION Reference Card Chapter } Chemical Uses Production (ink) (cleaners, sanitizers) (lubricants, adhesives) Pest control (pesticides, pheromones) Laboratory (reagents) Chemical Forms Liquid Gas Solid Storage Locked Access only by authorized personnel Signage Ventilation Segregation of Non-Compatible Chemicals Acid vs. chlorine (non-compatible) Food-grade vs. nonfood-grade Pest control vs. sanitation vs. maintenance Chemical Inventory Chemical ID + quantity Each use recorded Quantities confirmed at predetermined frequency Chemical Labels Storage information Dilution and application Food plant approval Disposal requirements Safety Data Sheet Employee safety information 30 year retention (OSHA) Chemical Approval Approval and purchase authority Label and Safety Data Sheet on file Food plant/food-contact suitability Update documents (log, inventory, procedures) Train authorized personnel Contractors Labels and Safety Data Sheet Usage records (pest control) Secure storage Container Identification Label/hazard warning Color-coding Dedicated purpose Use this Chemical Control Reference Card to ensure that necessary plant chemicals do not pose a risk to product or personnel. When you are ready, proceed to the workshops to apply what you have learned about chemical control to real-life situations. Chemical Log Chemical EPA # Approved Approved Authorized Name Storage Use Personnel AIB INTERNATIONAL - Reference Cards
Chemical Identification Workshop } Chapter FOOD SAFETY AND SANITATION Which of the following chemicals need to be included in the chemical control program? chemicals used on food-contact surfaces Propane on forklifts Fire extinguishers Water used for hand washing Salt used as an ingredient Salt used as ice-melt Salt used in the lunchroom Food-grade lubricants lubricants Janitorial chemicals Hand soap Ammonia used in refrigeration units for product storage Hand sanitizer Caustic used for fryer cleaning ph buffer used for lab analysis Silver nitrate used for lab analysis Ink used to code-date product Paint cans (paint used in office areas) Rodent bait inside bait stations (placed by contracted pest control service) Dish soap used in the employee lunchroom Dish soap used in the laboratory Alcohol wipes used to clean thermometers before taking product temperature Antifreeze for distribution trucks, stored in the maintenance shop Air freshener used in the restrooms 10
FOOD SAFETY AND SANITATION Chemical Storage Workshop Chapter Look through these chemical storage cabinets. There are 3 shelves and 2 columns in each cabinet. Using the chemical log provided, identify any unauthorized chemicals or improperly stored chemicals. Chemical Log: Approved Chemical EPA # Storage Use Personnel } Brrr Ice Melt 555-123 Coding Ink 555-234 Production Final Rinse 555-345 Food-grade Lube It 555-456 Food-grade Lube It Extreme 555-567 Food-grade Maxwell s Grease 555-678 Rat Kill 555-78 Out Building PCO Roach Bait LX 555-321 Out Building PCO Shine All 555-432 Sparkle 555-543 Stain Rite Paint 555-654 555-765 Food-grade Super Kleen 555-876 Food-grade Window Shine 555-87 Chemical Storage Example Chemical Storage Example Answer Sparkle Shine All Mop Rite Cabinet Window Shine Window Shine Sparkle Cabinet Sparkle Window Shine Shine All Window Shine Mop Rite } Sparkle Mop Rite is not on approved log 11
Chemical Storage Workshop FOOD SAFETY AND SANITATION } Chapter Cabinet 1 Cabinet 2 Final Rinse Lube It Lube It Final Rinse Shine All Maxwell s Grease Lube It Super Kleen Shine All Lube It Extreme Maxwell s Grease Cabinet 3 Final Rinse (Empty) Cabinet 4 (Empty) Sparkle Shine All Rat Kill Roach Bait LX Super Kleen Window Shine Rat Kill Wasp Spray Cabinet 5 Cabinet 6 Maxwell s Grease Lube It Extreme Final Rinse Maxwell s Grease Lube It Extreme Final Rinse Brrr Ice Melt Final Rinse II Cabinet 7 Cabinet 8 Final Rinse (Empty) (Empty) Shine All Super Kleen Stain Rite Paint Brrr Ice Melt Sparkle Lube It Stain Rite Paint Roach Bait LX 12