There are no specific regulatory requirements for time intervals between plant clean up procedures. To decrease downtime, increase production efficiency, and minimize expense, establishments can extend the period between clean ups, the FSIS stated in the notice.
The notice was issued to clarify a number of inquiries from inspectors about how to deal with firms that are able to skip daily clean-ups in their operation.
The inquiries reflected confusion about how to verify that this approach, sometimes referred to as "extended clean-up," the FSIS stated in the notice. The document defines the general matters that inspection program personnel should consider in performing their verification duties. It also spells out what standards processors will have to keep to in order to remain within the law.
When deciding not to clean up daily; plants must still comply with the lax, which requires that they develop, implement, and maintain written standard operating procedures (SOP) for sanitation. Sanitation SOPs must be effective in preventing direct contamination or adulteration of the food product.
"Establishments, particularly those that are operating with extended periods between clean-ups, must ensure that their sanitation SOPs are effective in meeting these requirements of the regulations, and FSIS will verify that the establishments are doing so," the notice stated.
Establishments may choose to extend clean-up frequencies if they can demonstrate that the alternative sanitary procedures are adequate to prevent the creation of insanitary conditions and the contamination and adulteration of product.
The FSIS expects plants to maintain records and documentation supporting the rationale for their sanitation SOPs and the procedures and frequencies for cleaning.
When developing a sanitation program, a plant should consider what operations may have an impact on sanitary conditions. The characteristics should be considered in developing a sanitation SOP that supports alternative clean-up procedures and frequencies.
"For example,an establishment may be able to reuse cooking trees more than once without cleaning them between uses," the FSIS suggested. "The operational characteristics that would support that cleaning between uses is unnecessary are the facts that the product is in casings, that there is no accumulation of product on the trees that transfers to product, and that microbial data have been collected on the condition of the trees between uses to establish a baseline."
The plant would collect microbial data on the trees that do not receive sanitation between uses. The data would have to show that the condition of the trees is comparable to the baseline.
"The operational characteristics, along with associated operational sanitation procedures, will affect microbial growth in certain areas on equipment and this will affect how much flexibility an establishment has to employ for alternative cleaning procedures and frequencies," the FSIS noted. "The establishment should always carefully consider the potential for product contamination or adulteration before implementing alternative procedures."
Most importantly, attention to these characteristics does not relieve the establishment from its paramount responsibility of developing procedures that will prevent conditions from developing in that will cause contamination or otherwise create the possibility of product adulteration, the FSIS stated.