Color Coding: Adding Discipline to a Food Processor’s Preventive Control Program
The U.S. Food and Drug Administration (FDA)’s Food Safety Modernization Act (FSMA), the most sweeping reform of our food safety laws in more than 70 years, was signed into law by President Barack Obama on January 4, 2011. It aims to ensure that the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it.
The 1986 vintage Current Good Manufacturing Practices have been updated and clarified in 21 C.F.R. Part 117 Subpart B. All permissive terms like “should” have been removed and “shall” replaced with “must.” Some of the previously nonbinding provisions, such as education and training, are now binding.
• Management is required to ensure that all employees who manufacture, process, pack or hold food are qualified to perform their assigned duties.
• Such employees must have the necessary combination of education, training and/or experience necessary to manufacture, process, pack or hold clean and safe food. Individuals must receive training in the principles of food hygiene and food safety, including the importance of employee health and hygiene.
• Supervisory personnel have the additional responsibility for ensuring compliance based on their education, training or experience (or a combination thereof) to supervise in a manner that will consistently result in the production of clean and safe food.
As per the Food Safety Preventive Controls Alliance (FSPCA), FDA requires in its official Preventive Controls for Human Foods training, the following:
• Allergen Cross-Contact: The unintentional incorporation of a food allergen into a food
• Cross-Contamination: The unintentional transfer of a foodborne pathogen from a food (where it may occur naturally) or insanitary object to another food (where it may present a hazard)
The more aggressive enforcement efforts by FDA to assess actual and potential cross-contact (allergen-based) and contamination (other than allergens) is best demonstrated by a review of the Preventive Controls regulations, which uses the term “allergen” 59 times, “cross-contact” 35 times and “contamination” 54 times.
Allergen cross-contact and general raw material, ingredient, in-process product and finished product contamination occur for many reasons, all of which are preventable. Proper handling and storage of raw materials, ingredients and packaging is one requirement to ensure that the food safety program is effectively implemented. Food processors need as many tools in their food safety tool box as possible to minimize allergen cross-contact and general contamination.
One of more fundamental and very effective ways to achieve high-level sanitation in a food processing plant is through the use of color-coding of uniforms, cleaning utensils, hygienic zones, etc. Color coding, if used in a food processing plant, should be consistent so the processing staff can easily understand that certain colors always indicate higher levels of cleanliness and hygiene, and other colors represent lower levels of cleanliness and hygiene. All processing employees should be trained on the color-coding scheme used by a food plant to the point where they have the color-coding memorized. After all, it is a fundamental food safety program to keep the movement of people and utensils minimized, so allergen cross-contact and general contamination do not “walk their way” from a low-hygiene zone into a high-hygiene zone.
Color-coded utensils are one tool that can help prevent both cross-contact of allergens and general contamination from the environment, raw materials, ingredients, packaging or people. The use of color-coded labels, smocks, hairnets, gloves, paddles, bins, buckets, tables, mats, etc. can also be used to help prevent microbial cross-contamination.
One example of a color-coding system that has been adopted by some food processing plants is shown below:
Colors mentioned are those commonly found in a number of the food processing plants that the author has assessed or audited; however, the color scheme can be changed and tailored to meet the individual needs of any facility. The important part is to document the program, train your employees on the “how’s” and “why’s” of a color-coded hygienic scheme, ensure that the colors are used effectively and establish an accountability program to reinforce usage.