Chapter: Operations and Documentation
Section: F.B.4 Sanitation
Sub-Section: N/A

Elements

The regulatory requirements contained in this guideline will be met when:

F.B.4 (01) There is a current, plant-specific written sanitation program that contains schedules and effective procedures to clean and sanitize the fish processing plant, equipment, utensils, and food contact surfaces used by the operation. (Risk Ranking: Medium)

F.B.4 (02) The sanitation program is implemented and performed in a way that minimizes the contamination of the fish processing premises, equipment, utensils, fish products, ingredients, labelling materials and packaging materials. (Risk Ranking: Significant High)

F.B.4 (03) The fish processing plant, equipment, utensils, and food contact surfaces are cleaned and sanitized for the start of each working day or as often as is necessary to maintain a hygienic environment and to prevent the contamination of food. (Risk Ranking: Significant High)

F.B.4 (04) Sanitation activities are recorded on the day they are performed, the records accurately reflect the implementation of the sanitation program, records are legible, complete, in chronological order, readily accessible, and kept for at least one year. (Risk Ranking: Medium)

F.B.4 (05) Equipment that is used to clean and sanitize a room, equipment or utensils is handled, maintained and stored in a way that minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials. (Risk Ranking: Medium)

Rationale

Cleaning and sanitizing are critical steps to ensuring food safety. During processing, food residues and debris accumulate on equipment, utensils and food contact surfaces. If these residues are not removed, their presence can encourage the growth of microorganisms.

Improper or inadequate cleaning and sanitation can lead to contamination of food, ingredients, labelling materials and packaging materials.

Cleaning and sanitizing

Cleaning is the removal of food, soil, and physical debris from a surface with the aid of approved cleaning products. Sanitizing is a process that reduces the number of microorganisms on a clean surface to safe levels with the aid of approved sanitation products. To effectively sanitize, the surfaces must first be thoroughly cleaned with hot water and detergent and then rinsed with potable water before the sanitizer is applied.

All facilities, equipment and utensils must be cleaned and sanitized for the start of each working day. During operations, all equipment, utensils and food contact surfaces that contact contaminated materials must be effectively cleaned and sanitized to minimize the risk of cross-contamination. Sanitation chemicals that are not used according to the manufacturers’ instructions, as well as overspray from cleaning and sanitizing activities, can cause food contamination. To prevent chemical contamination, it is best practice to remove or protect fish products, ingredients, packaging materials and labelling materials before cleaning and sanitizing procedures begin.

Chemical hazards may also result from chemical concentrations that are too high to be effectively rinsed. Conversely, chemical concentrations that are too low to effectively remove microorganisms can result in biological hazards.

Pre-operational inspection

The fish processing plant, equipment, utensils and food contact surfaces must be cleaned and sanitized for the start of each working day.

One way to verify that the plant is clean, sanitary, and ready to start operations each day is to conduct a pre-operational inspection of the plant, equipment, utensils and food contact surfaces. A pre-operational inspection assesses the effectiveness of cleaning and sanitizing activities, and ensures they were done properly. The inspection involves a visual check and may also include tests (such as swabbing and/or ATP tests) to determine if cleaning and sanitizing was effective in removing contaminants.

During the pre-operational inspection, other conditions can also be verified, such as:

  • lighting
  • cooler and freezer temperatures
  • hand wash station provisions (soap, paper towels, etc.)

Using a simple checklist will simplify the pre-operational inspection and help ensure consistency.

If the plant, equipment, utensils or food contact surfaces have not been adequately cleaned or sanitized, corrective actions must be taken before operations begin. For example, the area or equipment must be re-cleaned and sanitized.

Written program

To ensure that the plant, equipment, utensils and food contact surfaces are effectively cleaned and sanitized, operators must have a written sanitation program. This program must include effective procedures and schedules to clean and sanitize the fish processing plant, equipment, utensils and food contact surfaces used by the operation. It is the operator’s responsibility to ensure that cleaning and sanitizing are carried out in a way that minimizes the risk of contamination of the fish processing premises, equipment, utensils, fish products, ingredients, and packaging and labelling materials.

The program should include, but is not limited to:

  • the employee(s) responsible for sanitation activities, pre-operational inspections and any noted deviations,
  • all chemicals used, including the concentration and directions for use according to manufacturers’ specifications,
  • storage location and conditions for any chemicals used,
  • equipment, utensils and areas to be cleaned and sanitized,
  • procedures that provide specific instructions for each piece of equipment, utensil or area, such as:
    • pre-preparation activities
    • equipment disassembly and reassembly instructions
    • order of activities
    • instructions for application of chemicals, including water temperature and contact time where applicable
    • cleaning equipment and utensils to be used
  • instructions to prevent cross-contamination and to protect fish products from sanitation products and overspray,
  • pre-operational inspection procedures,
  • the record-keeping practices and requirements.

For more information on chemical handling and storage requirements, including the workplace hazardous materials information system (WHMIS) and material safety data sheets (MSDS) requirements, see the “Handling and Storage” FPG.

Records

Written records must include the:

  • date the activity was performed,
  • type of activity that was performed,
  • results of the procedure.

Written records must:

  • be made on the same day the activity is performed (including pre-operational inspections),
  • be readily accessible for at least one year,
  • accurately reflect the results of the procedures (for example, by including all corrective actions taken),
  • be legible, complete, and kept in chronological order.

Regulatory references

Food Safety and Quality Act, 2001; O. Reg. 465/19 s. 41, 42, 61

    1. The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that a written sanitation program is developed, implemented and monitored and that the program,
      1. includes effective procedures to clean and sanitize the fish processing plant, equipment, utensils and food contact surfaces used by the operation;
      2. includes cleaning and sanitation schedules; and
      3. is updated as needed.
    2. The operator shall ensure that the cleaning and sanitizing procedures referred to in clause (1) (a) are performed in a way that minimizes the risk of contamination of the fish processing premises, equipment, utensils, fish products, ingredients, labelling materials and packaging materials.
    3. The operator shall ensure that on each day the cleaning or sanitation activities referred to in subsection (1) are performed, a record is created that includes,
      1. the date the activity was performed;
      2. the type of activity that was performed; and
      3. the results of the activity.
    4. The operator shall ensure that every record created under subsection (3),
      1. is kept for at least one year from the date the record is created; and
      2. is readily accessible.
    1. The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that the fish processing plant, equipment, utensils and food contact surfaces are cleaned and sanitized for the start of each working day.
    2. The operator shall ensure that the equipment, utensils and food contact surfaces that have become contaminated are effectively cleaned and sanitized in a way that minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials.
    3. The operator shall ensure that equipment and utensils used in connection with inedible material is,
      1. effectively cleaned and sanitized prior to entering any area where the equipment and utensils may contaminate fish products, ingredients, labelling materials and packaging materials; and
      2. kept in good repair.
    4. The operator shall ensure that the utensils used in connection with inedible material are,
      1. marked to indicate their intended use and not used for any other purpose;
      2. kept in good repair; and
      3. kept in a storage area provided for that purpose.
    5. The operator shall ensure that any equipment that is used to clean and sanitize a room, equipment or utensils is handled, maintained and stored in a way that minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials.
  1. Any records required to be created and stored under this Regulation must be legible, complete and kept in chronological order.