Elements of an Approved Arrangement

When considering upgrading your existing equipment or the purchase of new equipment, from a cleaning and hygiene perspective, you should consider the following;

• Is the equipment and areas that come in contact with food materials, made of durable materials that are approved to contact food and suitable for current cleaning chemicals?
• Are all surfaces smooth, impervious, and easy to clean?
• Does the equipment require manual cleaning? Are all areas of the equipment accessible for manual cleaning?
• Does the equipment have moveable parts? Do these need to be removed for cleaning purposes?
• Where CIP is used, does this adequately cover all contact areas?
• Are all areas that come in contact with chemicals made of durable materials that would withstand the cleaning process, repeatedly? (example; seals)
• Where metal to metal welding is sighted, are these smooth to allow easy cleaning?

Getting the right equipment will assist you in maintaining your cleaning and sanitation program.

Your procedures should document:

• The cleaning and sanitising processes for each equipment and product line (e.g. CIP or manual cleaning)
• Specific methods (including work instructions on how to clean different equipment and areas, and how staff are trained to carry out cleaning tasks)
• Specific cleaning equipment required
• Cleaning equipment specifically dedicated to allocated areas (example; allergen control rooms) or equipment
• A description of the specific cleaning and sanitising chemicals used
• Dilution ratios
• Water temperature requirements
• Specific contact times
• Validation methods
• The cleaning records to be kept
• Cleaning verification activities, and 
• Corrective action to be taken if needed.

A cleaning and sanitation expert or CIP expert can provide the site with evidence that their CIP program to be implemented will be effective. This evidence is known as validation documents and it should be specific to the products and manufacturing processes. The validation documentation needs to be documented and should be available at audit.

As part of the commissioning of the CIP circuits, the commissioner and/or chemical supplier will assess each circuit design and recommend a "CIP recipe" (type of wash/detergent, flow rate, circulation time/temperature) and a recommended frequency of conducting the CIP. The recommendations are based on the type of product the equipment contacts (e.g., the CIP setup for liquid milk may be different to other products which have a different pH or sugar or fat content).

The experts would then run a series of trials of each CIP circuit following their recipe, monitoring the parameter readings, and testing the effectiveness of the CIP through measuring conductivity, titration, rinse water testing, potentially swabbing or other means of validation.

You must document the validation of the CIP circuits in your AA along with documented records of what was done as part of the validation process (i.e., circuit diagrams, expert recommendations, trial data, verification data and conclusions).

If either the product or the process changes, the site should contact their cleaning and sanitation expert for advice and update their written CIP program. Updated written validation documents should capture critical validation information, such as time, temperature, pH, cleaning chemical type, process type, product type changes. Site management responsible for maintaining your Approved Arrangement and food safety, should familiarise themselves with likely problem organisms and cleaning challenges for their product and processes.

It is important the cleaning staff are kept up to date with CIP and other equipment cleaning and sanitising procedures and requirements. Staff should advise their supervisor if there are issues with CIP practices or if they notice any changes, for example; should water temperature not reach the required temperature?

Training in the correct CIP, equipment cleaning and sanitising and environmental testing processes is essential for ensuring that the correct procedures are followed.

Your site cleaning and sanitation program must be verified using a method that is suitable to your site and manufactured products. These may include the use of visual inspections, CIP rinse water testing, or testing of equipment/surface swabs for microbes, allergens or other residues. You must document how the verification test is carried out, how often, by whom, acceptable limits and any corrective actions that are required in the event of a failed result.

Your site cleaning procedures should apply to all areas of your site, not just your food contact areas. Waste bins, foot baths, trolleys, drains, sinks, walls, floors, ceilings, staff amenities, storage areas and even your cleaning equipment are some of the items you may want to consider including in your cleaning procedure as they can attract pests, which pose a risk on their own.

As a means of monitoring cleanliness across your establishment, you should consider implementing an environmental monitoring program. An environmental monitoring program involves regular testing of equipment and surfaces, across both food contact and non-food contact zones for known pathogenic and indicator microorganisms such as Listeria, Salmonella and E. coli. If you have such a program in place, then you must have the program fully documented to describe the scope testing methods, regime and corrective actions.

Considerations for creating an environmental monitoring procedure:

1. Does the procedure consider the potential of any environmental organisms which could pose a threat to food safety?
2. Are staff trained in how to conduct sampling?
3. Will your testing regime reflect differences in risk level for different areas?
4. Have you covered all relevant areas?

Corrective actions should be relevant to the type of area where unacceptable results were identified. For example, corrective actions for a positive result from a store room ceiling swab would be different to the corrective actions required for a positive result from production equipment. If you have a failed pathogen result from environmental testing, you need to notify your state food regulator and the department straight away.

It’s a good idea to keep in touch with advances in technology, through industry bodies or industry media which could be discussed with the cleaning expert.