Round out your HACCP plan for maintenance to cut food risks

Joe Mikes, Life Cycle Engineering

Maintenance employees are often the exception to the rule for working on both sides of food plants, increasing the risk of cross-contamination. To be followed consistently, Hazard Analysis and Critical Control Point (HACCP) plans need to be realistic. Engaging maintenance crafts in creating the HACCP plans reduces this risk. Preplanning steps into every maintenance job plan also can significantly reduce the risk of cross-contamination. Maintenance employees have to take it upon themselves to do the right thing as they cross that often invisible line from one side of their plant to the next. Contractors who come on site need to be trained in safety issues as well.

In a typical food site, the buildings are physically divided to contain certain food properties and health risks (see Figure 1). In a precooked meat plant, there is a raw side and a cooked packaging area divided by huge ovens. In beef processing, the complex is divided into two separate areas, kill and packaging, which are divided by coolers. (Similarly, in pharmaceutical plants, there are sterile areas that have 100 percent containment [moon suits required] all the way down to final product packaging areas near the end of the process.)

Figure 1

Most production employees are intentionally routed to separate areas within these environments. There are different dressing rooms, restrooms and even divided lunch rooms in some businesses. A containment plan is typically well thought out and executed for production employees. However, maintenance employees are not always held to the same strict codes.

It’s 3:35 p.m. at shift change and the packaging manager finds out that his key packaging machine has jammed its feed roll, and the only maintenance guy still here during shift change is Louie. Louie has done this job several times, but this afternoon, he has been on the raw side of the house fixing a bacon slicer. He could be 30 seconds away by cutting through the oven rooms, but that would be an exception to the HACCP plan. On the other hand, it could take five to 10 minutes to make sure his tools are cleaned up and he arrives relatively germ-free for the next job. What is Louie going to do? What is an acceptable response and what really happens in your plant? What happens next is really up to the management running the operation. Did the packaging manager reinforce the food safety aspect in his radio call to Louie? Are those ideas shared every time, or just when it is convenient? Because these scenarios occur all too often, maintenance has to care about doing the right thing and management needs to support this.

Crafts have a double duty to avoid contamination when working in food environments. When possible, maintenance people are assigned to work on only one side of a food plant, but exceptions to the rule do occur. They are truly walking the line with food contamination risks every day. Plant leaders, in coordination with government inspectors and employees, should work together to continuously improve the food safety aspect of daily business. Leaders must take the time to reinforce food safety procedures with their maintenance staff and not request emergency attendance unless it is truly an emergency. They also need to recognize that, for the craftspeople, it takes a little longer to get each job completed and sterilized when working in a food environment

Here are some elements to consider adding to your HACCP plan if they have not already been introduced:

  • Retrain maintenance employees on HACCP training frequently; include them in committees for improving food safety
  • Encourage maintenance employees to learn best practices from other maintenance groups
  • Include in each job plan:
  • Instructions to maintain a sterile environment during the tasks
  • Clear direction for any dry clean-up procedures required for that area to get started
  • Recommendations for cleaning the asset and tools after the job is done
  • Recommendations for leaving that environment and heading to the next job without contamination issues
  • When maintenance must be performed during the third-shift sterilization process, list special considerations that should go into effect for that job at that time of day
  • Craftspeople need to maintain records on food-grade lubricants used and make sure they are using clean tools to inject these lubricants
  • If craftspeople are expected to work both sides of the house, consider:
  • Disposable gloves that are easy to access (two different colors)
  • Disposable boot/shoe covers (two different colors)
  • Jackets or coveralls that can be changed at the point of entry for each environment
  • Toolboxes or carts set up for both sides to reduce carry-over contamination
  • Always use the appropriate disposal containers per type of waste: No. 2 food product, hazardous material, contaminated food, equipment parts and pieces
  • If there are physical items like janitorial supplies, warning/working placards, caution tape and other commonly used items on each job, purchase a set for each side of the business
  • Add disinfectant wipes to the toolbox to sterilize tools and surfaces as the jobs are completed

Using contractors within the maintenance group also can introduce risk in food safety. Many contractors have been on site many times before and know what they should be doing. Regardless of their past performance, they should be HACCP trained, including a working knowledge of foodborne illnesses and methods to reduce risks. They should be taught how to identify high risk situations and report them to management if there is any possibility of food contamination. Maintain plant records on HACCP-certified contractors and renew that training regularly.

The maintenance group has a significant responsibility for food safety and reducing the risk of cross-contamination. Typically, crafts have the authority to cross the line in food plants from one side to the other. With that authority, there is a duty to make sure every reasonable effort has been taken to reduce contamination risks while performing maintenance.

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About the Author

Joe Mikes, CMRP, is a senior consultant at Life Cycle Engineering. Joe has helped dozens of organizations improve their performance while producing their goods safely. You can contact Joe at Read More