While we’ve looked at the key issues—including COVID-19—facing food processors and A&E/Cs this year in FE’s 2020 Annual Plant Construction Survey, there’s a lot more to discuss. Parts two, three and four cover:

Part 2: Site related issues beyond wastewater (such as pad-ready sites, weather and flood plains)

Part 3 (this article): FSMA facility design criteria, especially in terms of intentional adulteration and food defense

Part 4: Automation trends: Integration and flexibility

Designing and building with food defense in mind

With most of the FSMA food safety-specific rules (e.g., Preventive Controls, Produce Safety (other than water), Foreign Supplier Verification, Sanitary Transportation, etc.) now being final, processors have turned their attention to FSMA’s Intentional Adulteration (IA) rule, which took effect for large processors in 2019 and becomes final for small processors this year (2020) and very small processors next year. So, while meeting the IA rule brings along with it several security measures that need to be addressed, processors are also taking extended looks at their facilities with an eye towards food safety and security.

Partial FSMA calendar for IA
Partial FSMA Calendar shows the IA rule is due this year for small processors and 2021 for very small businesses. Source: FDA

 “With food safety no longer an ‘option,’ food manufacturers proactively continue to improve their food safety and security plans, which start with facility design,” says David Ziskind, Black & Veatch director of engineering, NextGen Ag. Ensuring raw and RTE separation, allergen separation, sanitary vestibules and cleanable surfaces (which are accessible and discourage standing water)—and avoiding hollow materials (which could become a harborage point)—are all common “first pass” design considerations. Appropriate attention to HVAC systems and room pressurization—through a mechanical quality plan during design—is also important.

To fulfill the commitment to safety and security, it is crucial that facilities be designed to meet Good Manufacturing Practices (GMP), says Rob Rainbolt, Food & Consumer Products Group, Burns & McDonnell. By controlling all movements of personnel and materials, GMP minimizes health and safety risks while also addressing environmental scope and controls to guard against cross contamination. Each design should specify an air filtration system for use within a particular application. Moisture will inevitably be introduced during the wash-down process, so humidity controls must also be addressed. Finally, equipment design and specifications must be thoroughly reviewed to see that all equipment can be properly cleaned and will not contain harbor points in which microorganisms could grow.

However, food security includes active and passive physical measures, such as location and design of entrance gates and doors, cameras with appropriate monitoring and recording, and use of badging systems to restrict employees only to areas they need to be to do their work, adds Ziskind.

Facility security is equally as important in executing site safety measures, says Rainbolt. Many recent food recalls have been traced back to incidents involving disgruntled employees tampering with on-site processes. Former employees who have been dismissed for any reason should not have access to the facility following termination (See FE, May 6, 2014). As the first line of defense, employees should be trained how to handle situations involving former personnel attempting to get back into the plant.

With all sorts of access control (e.g., access cards, key fobs and automated entry systems), there needs to be an increased focus on foot traffic plans, as well as restricted access to production related areas of a facility, says Mark Galbraith, co-owner of GALBRAITH Pre-Design. Separate entrances for different types of building users are also very prevalent.

Food Defense plans entail different methods, including a badging system for employees, proper fencing and guard towers, says Rainbolt. It is also important to protect against the possibility of visitors contaminating the plant by bringing pathogens inside with them. A comprehensive training program for visitors will provide a standardized framework to prevent these occurrences. Both employees and visitors must abide by all GMP rules and be well-versed in personal hygiene procedures.

Access to the site should be limited so that even visitors either must be let into the parking lot or at a minimum only allowed into the main entrance of the building, says Tammi McAllister, CRB associate, core team leader. There should be guards to allow trucks in and out of the site. Buildings should be accessed by card readers from appropriate individuals.

Video cameras in conjunction with proximity-activated sensors provide the best validation protection for a facility, says Tyler Cundiff, vice president, business development—Food & Beverage Market, Gray. He says not to think of them so much as preventive measures, but rather those that activate after a violation of standard operating practices.

The facility’s security cameras should be operating at all entrances, and doors leading to all external doors should automatically close, says Rainbolt. In addition, employee break-rooms should be located away from production areas to provide tighter controls.

Biosecurity and COVID-19

COVID-19  Source: CDCIn these days of COVID-19 and other potential and intentional bacterial infections, food must be protected from IA (e.g., anthrax or E. coli STEC), and employees must be protected from communicable viruses and bacteria. Faithful+Gould’s Gregory Franzen, LEED AP, agrifood subsector lead, suggests another key security measure. Today, new biosecurity practices may include a dedicated biosecurity building containing shower/locker facilities and car/truck wash facilities for potential contamination.

While COVID-19 is not a danger to food safety (the virus doesn’t survive in food), we’ve seen what it can do to a business when half the workforce gets sick—or even one or two employees. Therefore, keeping employees where they’re supposed to be and at a recommended social distancing of two meters can be a real challenge. As we’ve already noted above access control can help.

Harlan VandeZandschulp, P.E., president of Gleeson Constructors & Engineers LLC, suggests there should be more access control and security at food processing facilities, for example, scan cards/fingerprints/facial recognition. But, more needs to be done in terms of screening. “We’ve used infrared thermometers to check for employee/owner safety for COVID-19,” he adds.

“The COVID-19 pandemic has added a recent new element that may require features to allow for more distancing of personnel in offices and manufacturing areas as well as temperature monitoring and logging for all entrants into a manufacturing facility,” says Keith Perkey, VP—Food & Beverage Division, The Haskell Company.

“As of mid-February at a couple of plants/projects, temperature testing of every employee has been introduced,” says Tom Wiersma, independent consultant. “This is non-contact testing when employees enter the office or plant with their prox card and/or punch in. My sense is that it will become the new normal at most food plants before the end of 2020.”

The following companies and individuals participated in the 2020 Food Engineering Plant Construction Survey:

A M King

ADF Engineering, Inc.

Alberici Constructors

ARCO National Construction

Big-D Construction

Black & Veatch

Burns & McDonnell

CMC Design-Build Inc.


Dennis Group

EA Bonelli + Associates




Food Plant Engineering, LLC

GALBRAITH Pre-Design, Inc.

Gleeson Constructors & Engineers LLC.


Hixson Architecture & Engineering

Mead & Hunt

Shambaugh & Son, L.P.

SSOE Group


The Austin Company

The Haskell Company

Tom Wiersma, Independent Consultant

Tippmann Group

Woodard & Curran