GMP/GHP standard of cleanliness

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It is expected that a documented procedure and checks for Good Manufacturing Practices (GMPs) are in place at your dairy facility. Associated records must be kept and verified to show that GMPs are clearly defined, and staff are adequately trained to ensure that the manufacture of your products is maintained to a standard of cleanliness that complies with the regulations.

These procedures and checks must ensure that:

  • Staff are complying with documented procedures, wearing suitable protective clothing, and observing good hygiene and manufacturing practices.
  • Premises are maintained to a standard of cleanliness that ensures there is no build-up of garbage, food waste, dirt, or foreign matter.
  • The premises and surrounding area, including any storage areas must be included in the site’s internal GMP audits and housekeeping systems.
  • Any equipment used must be designed to ensure it can be effectively cleaned to prevent accumulation of any food waste, dirt, grease, or other foreign matter which can pose a risk to the safety of the product.

For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.

Good Manufacturing Practices (GMPs) & Good Hygiene Practices (GHPs) can be defined as the operational and behavioural requirements necessary to enable a food business to consistently produce safe food. GMPs & GHPs are essential to a food business as practices that work together with your HACCP system to control hazards in the food processing environment. Your GMP & GHP procedures are an overarching set of procedures that would incorporate key GMP pillars such as:

  • Cleaning and sanitation
  • Waste removal
  • Competency training
  • Personnel hygiene (including handwashing, protective clothing, hygienic behaviours, and illness reporting)
  • Foreign object control measures
  • Handling and storage of chemicals
  • Preventative maintenance (including considering the contamination risks from maintenance activities) and
  • Pest management, to name a few.

You may choose to have separate procedure for each area or decide to have these incoporated into one GMP procedure. You will also need to conduct an GMP/GHP audit, on top of your internal audit programme, to ensure that the GMP/GHP practices are being carried out and managed with the requirements of your procedure. However, when conducting your GMP/GHP audit, you must include all areas of your premises, including the surroundings and any storage areas, and associated polices or procedures.

GMP & GHP audits should not be just a quick inspection with a tick or cross. The items and evidence that you assess as part of an GMP audit need to allow you to determine if your GMPs/GHPs are being followed, and you must keep records of these audits. Any issues identified during the GMP audit should be documented along with corrective and preventative actions, timeframes for completion and who is responsible for actioning the finding.

Some common observations to indicate that your site GMPs & GHPs are not being effectively managed includes:

  • Deteriorating floors with cracks and potholes
  • Deteriorating condition of walls, ceilings and equipment (e.g. damaged parts, rust, flaking paint), inadequate cleaning (e.g. mould growth, build-up of residues on equipment)
  • Use of unlabelled chemicals or containers
  • Improper storage of equipment and maintenance tools
  • Protective clothing requirements not being followed
  • Uncontrolled and overuse of adhesive tape as temporary repairs
  • Accumulation of waste, debris and wood splinters on floors
  • Uncontrolled garden surrounds
  • Evidence of pest activity on site

During manufacturing, staff may get caught up with different priorities and forget the basics. This could be simple as forgetting to put items or utensils back where they belong or not sweeping or cleaning areas adequately. The use of shadow boards alongside regular equipment location checks and GMP audits can help ensure equipment storage requirements are met after use. Staff should be encouraged to follow a ’clean as you go’ approach to their day-to-day activities.

It is important to remember that this element covers not only the manufacturing areas, but also the building surrounds and any storage areas which may be onsite, along with all relevant policies and procedures.

When reviewing your GMP procedures and conducting internal GMP audits, you should take the following into consideration:

  • Do you have a documented procedure which includes the requirement for staff to wear suitable protective clothing and observe good hygienic and manufacturing practices?
  • Are all relevant personnel, including staff, contractors and visitors who may need to enter the manufacturing area suitably trained and complying with procedures?
  • Are regular hygiene and housekeeping inspections conducted? Are there records kept for these?
  • Are inspections up to date as per your proposed schedule?
  • Are all areas including storage areas and external surrounds covered as part of regular internal audits?
  • Are corrective actions from issues found during GMP audits recorded and rectified?
  • Are chemicals clearly identified and stored correctly after use to ensure they do not inadvertently contaminate products?
  • Are walls and ceilings cleaned effectively (e.g. no evidence of mould growth or residues)?
  • Are rubbish bins emptied regularly and not overflowing? Do they have lids which are kept closed? Who is responsible for ensuring this?
  • Are there designated areas for the separation and storage of waste and inedible material before their removal from the site?
  • Are food waste containers clearly labelled or differentiated from non-food waste containers?
  • Is equipment maintained to a standard of cleanliness that ensures there is no accumulation of any food waste, dirt, grease, or other foreign matter that could contaminate any dairy products?
  • Are operators aware of how to clean equipment effectively? Are their areas clean and tidy? Is there any risk of contamination?
  • Are there any other operations occurring at the site which can affect the site from producing a safe quality product?
  • Are facilities for cleaning and sanitising equipment in contact with milk products readily accessible by food handlers?
  • What controls are in place for managing personnel eating or drinking inside the site?
  • Do staff enter processing areas through the designated access doors only?
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Self Assessment

How much do you know about GMP/GHP Standard of cleanliness?

Take this short assessment to find out.

Question 1

Nicole is the shift supervisor at a dairy site. She has arrived early and noticed as she enters the dairy site that the bins at the hand wash stations are overflowing. Nicole knows that this has happened several times in the past month.

What should Nicole do?

Click all that apply.

Question 2

Tang is conducting a monthly GMP audit of his production area. He notices an unlabelled water bottle next to the ink jet printer. As per the company policy, all containers and bottles need to be labelled. Labelled water bottles are allowed in low-risk areas of the site, such as the printing area, but are to be kept out of the high risk areas, such as the manufacturing areas.

As an operator conducting an internal audit of the printing area, what actions should Tang take with the suspected water bottle?

Click all that apply.