Food must be prepared in a manner that ensures its safety. Hence, design is important in preventing potential hazards. Foods that are not prepared in facilities with the appropriate food safety design are deemed by the FDA as adulterated, regardless of the quality of the food. What do regulatory food safety inspectors look for when they inspect your facility? To answer that question, I will pull from my own experience inspecting food processing facilities for regulatory compliance.
The inspection of the food facility begins as I drive up to the location. The plant should be situated in an area that is free from potential environmental sources of contamination. Therefore locating the facility near sewage plants, refineries, salvage yards, and landfills should be avoided. As I drive onto the premises, the existence of a fence and gate is usually encouraging, as it tells me that there is at least some basic level of food defense infrastructure in place.
As I enter the parking lot, I like to see that it is paved to keep down dust and is well drained to prevent puddles. Visually scanning the premises, I want to be satisfied that the yard is also well drained and is properly groomed to remove trash, tall grass and shrubs that could harbor pests. Any garbage held outside must be in a designated area and must be kept covered. The perimeter of the building should be paved or pebbled 30 – 36 inches wide and about 3 inches deep to prevent rodent activity. Trees should be sufficiently located away from the building to prevent rodents from gaining access.
After inspecting the grounds, I turn my attention to the building envelop, including roof, outside walls, doors and windows. These elements must be designed so that they can be maintained in a sanitary manner. The roof should be smooth enough to prevent accumulation of debris and dust, and must be self-draining. Holes that carry pipes in and out of the building must not have gaps between the pipe and the wall that are large enough to allow pests to pass through. Generally, if a pencil can fit into the gap, a mice can also pass, not to mention other vermin of smaller size such as small lizards, roaches and flies. Any gap present must be back-filled and finished with concrete or covered with echelon plates. As a temporary fix, the holes may be stuffed with steel wool or copper meshing.
Since pests can also enter through windows, screens 22 mesh size or smaller, should be installed over them. These screens should be designed so that they can be easily removed and cleaned. Doors to the building may be screened as well, or otherwise designed to prevent entry of pests. For example, the bottom of doors providing entrance to the building must not have gaps large enough to allow pest entry. Where gaps exist, door brushes may be installed to prevent pests from entering.
After completing inspection of the building envelop, I begin my inspection of the building interior. I check to make sure that the floors are water-tight, cleanable, non-slippery and well-drained. Pits and cracks suggest that the floor is either suffering from poor maintenance or is of a type that provides little resistance to chemicals, extreme temperatures, and/or physical impact. No accumulation of water should be seen on the floor. This is an indication that it is not designed for proper drainage. Floors are required to be sloped one-eighth to one-quarter inch per feet every 10 feet apart. The drains must be covered with grates to filter large solid waste and must have the capacity to handle the volume of liquid waste produced in the plant. Equipment discharge should be piped directly to the drains. Floor elevation should be such that it allows waste water to flow from clean to dirty areas and not in reverse.
While checking the floors I also inspect the joints where the floors meet the walls. These intersections must be coved to prevent accumulation of dust, debris and microbial niches that are generally found in sharp corners. From the corners of the floors, my eyes are drawn up to the walls and ceiling. I like to see that the walls are smooth, non-porous, and cleanable. Cracks, pits and and peeling paint are unacceptable. The ceiling should be cleanable, and free from dust and condensation accumulation. Overhead bulbs should be covered with shatter-proof covering, and must provide adequate illumination. Generally, this is anywhere between 25-150 lumens 30 feet from the floor, depending on the area of the plant. Production areas should have the highest illumination to ensure safety and efficient operations. Overhead utility piping must not be situated where they can create condensate that will drip onto exposed food or processing equipment. Where possible, piping should be routed outside the processing area. Waste and sewage lines must never run above production areas. Condensate on overhead piping and other surfaces can be prevented by adequate control of temperature and air flow. This means having a proper heating ventilation and air conditioning (HVAC) system. HVAC systems should be designed to move air from clean to dirty areas and not the reverse. Smoke, steam and off-odors must be adequately removed, and clean, fresh, odor-free air brought in.
In addition to inspecting the infrastructural elements mentioned (building envelop, floor, walls and ceiling), I also verify that equipment layout is able to facilitate proper cleaning and sanitation. There should be at least 18 inches provided between equipment and the wall, and a distance of at least 36 inches maintained between equipment for easy cleaning and inspection. Stationary equipment should be installed at least 6 inches above the floor or must be fixed directly to the floor with a water-tight seal. Adequate facilities such as hand wash sinks, hand sanitizers, boot washers, foot baths, hose stations, break rooms, locker rooms and toilet facilities must be in place to maintain sanitation. Toilets should be clean and have adequate supplies of toiletries. They must never open into areas where food is being handled, processed or stored. Locker rooms should be provided with adequate lockers of a design that is cleanable, sloped (about 60o) at the top and slotted to allow air flow. In order to minimize risk of cross-contamination the facility should be designed with adequate separation between raw and finished products. This may require separate entrance to the facility for raw material handlers and those who work in processing areas. Separate rest rooms, lockers, break rooms and storage areas may also be required. Other food safety design requirements that inspectors look for are included in the GMA facility design checklist. You can download a copy for free. Use it as a checklist to verify the sanitary design of your facility.
Reference: Cramer, M. M. (2013). Food plant sanitation: Design. maintenance, and good manufacturing practices. Boca Raton, Fl: CRC Press
