The Facility Evaluation Before the Audit

A compliance auditor arriving with a clipboard in hand could be a food and beverage facility manager’s worst nightmare. No matter how well the facility operates, the inspector is likely to find something that will need to be addressed. Then the facility will need to quickly correct any flagged deficiencies so it can maintain compliance and continue operations. If it’s not prepared to fast-track the required repairs, the facility may risk a potential shutdown.

During a facility evaluation, a certified coatings professional covers the entire site looking for any potential deficiencies such as corrosion, peeling paint, cracked flooring, and porous surfaces that can harbor bacteria.

As part of the FDA Food Safety Modernization Act (FSMA), food and beverage facilities are required to implement preventive control plans that describe how they will correct any problems that arise. These plans are designed to expedite repairs so facilities can quickly return to compliance. For example, having repair specifications already in place for rehabilitating and recoating concrete structures will allow a facility to take immediate corrective actions—such as issuing a detailed bid for repairs—following a compliance issue. Being able to initiate repairs this quickly improves the likelihood that the facility will be able to restore compliance within the three- to four-week window auditors typically mandate.

To prepare a comprehensive preventive control plan, facility managers may be best served by taking a page out of the compliance auditor’s playbook and conducting a detailed facility evaluation of their own. Conducting a proactive facility evaluation, which is recommended to be performed with a reliable third-party coatings expert in tow, will allow the facility to write repair specifications for the wide array of environments found throughout its operations—and potentially correct issues prior to an official audit to avoid compliance citations.

This article focuses on compliance issues related to assets and areas of food and beverage facilities that feature industrial coatings.

Performing an Expert-Guided Facility Evaluation

Part of the FSMA directive requires facilities to perform periodic audits of their own to document and proactively address non-conformances throughout the year, not just at audit time. However, internal staff may not have the expertise to properly assess all areas of concern. That’s where an expert—like a NACE-Certified Coatings Professional—can deliver significant value by participating in a detailed facility evaluation.

A certified coatings professional will be able to identify the optimal coating systems to use for specific facility environments and applications to ensure longer service lives and reduced maintenance needs. For example, internal staff may think an epoxy-based system is the most appropriate material for patching floors in a wet processing area. But the coatings professional will know that epoxies are prone to cracking and flaking in wet environments exposed to frequent wash downs and thermal cycling. The coatings professional would therefore recommend repairing the area with a urethane concrete-based system, which will expand and contract with the concrete substrate below, offering less opportunity for cracking, less potential for bacteria to grow under loose coatings, and a longer service life.

Like an FSMA audit, a comprehensive facility evaluation with a coatings professional will cover the entire site. However, the coatings professional will only focus on those assets and areas that require industrial coatings, such as wet and dry processing areas, mechanical equipment rooms, chemical storage areas, cold storage areas, warehouses, storage silos, employee welfare zones, water and wastewater treatment structures, and other areas that require coatings solutions that are suitable for use in USDA-/FDA-inspected facilities.

A certified coatings professional may recommend converting trench drains into box drains (shown) to reduce the wet surface area available to trap bacteria.