Background & Links

An important aspect of the new Food Safety Modernization Act (FSMA) is “transparency.” The term refers to the requirement in the Act that every company involved in the production or manufacturing of human (and animal) food maintain a detailed record on every company with which it does business as part of the production and distribution process. Thus, for example, if Company A makes cereal, it is required to keep close track of every company who supplies it with raw ingredients (wheat, rice, etc.) as well as the supplier of the cereal boxes, and the companies that ship the cereal to grocery stores. It also must know who keeps its cereal-making equipment in good working order, such as conveyor belt manufacturers as well as suppliers of industrial chemicals and lubricants used to keep production lines running and clean.

The following is a white paper on how FSMA expects the makers of manufacturing chemicals to detail how these chemicals are to be used and stored:

Equipment & Maintenance Chemicals

Statement of Intent

This document offers companies that use equipment and maintenance chemicals to manufacture food with a step-by-step overview of the new Act’s regulation of these products, how companies can gain and maintain compliance, and suggestions on ways to improve current good manufacturing practices.

MRO Overview

The use of maintenance, repair and operational (MRO) chemicals is an essential component of manufacturing. Chemicals are classified by their intended use, as well as by toxicity. For food manufacturing operations, MRO chemicals can be approved or disallowed depending upon their potential for contact with the food product being manufactured.

The classifications are provided by the National Sanitation Foundation, which evaluates chemicals by their toxicology, odor potential and compliance with FDA, USDA and EPA regulations. For example, products classified as A1 (a general cleaning agent) can be used on all surfaces in a manufacturing setting, as long as food and food packaging is protected. Another group of chemicals, C3, is a paint remover for plant areas where food is not present or manufactured. The intended goal of these product classifications is to prevent, as much as possible, the accidental contamination of food during production.

MRO chemicals and their intended uses apply equally to human food and animal food.

The new FSMA regulations address overall plant production programs with a special emphasis on preventing food contamination. In pursuit of that goal, maintenance and equipment chemicals such as lubricants and cleaning compounds must meet certain standards. These can be classified as follows:

  • No contact with food or food processing is allowed;
  • Incidental contact with food is allowed as long as the lubricant is “food grade.” This category is generally recognized by the H2 Code of the NSF;
  • Direct contact with food in production is allowed. This category is 3H.

FSMA compliance requirements

The Food and Drug Administration, which oversees food safety, is currently rolling out implementation rules and guidelines for the food industry. The official documents where this information is available runs to nearly 1,000 printed pages, with more to come. At its core, the FSMA regulations require food manufacturing firms to conduct a hazard analysis of known or “reasonably foreseeable” problems from microbiological, chemical or physical contamination, followed by the preparation of written procedures and employee training to prevent contamination from happening. Because of its emphasis on preventative measures, the FDA’s watchwords for the food industry might be summarized as “watchful, careful and thorough.”

The following is a short list of current requirements under FSMA related to chemicals and lubricants used in the food plant:

  1. Written procedures
  2. Hazard analysis of materials used and production process
  3. Preventative controls for identified hazards
  4. Storage of chemical and lubricants
  5. Record keeping requirements
  6. Employee training
  7. Verification and monitoring
  8. Validation

Best Practice Solutions

Even though full FSMA compliance is not due until October 2016, various aspects of the regulations have been published and have the force of law.  Food manufacturers can get a head start on compliance by taking several proactive actions as implementation proceeds. Such actions might include:

  • Management and organizational education; learning the do’s and don’ts of FSMA;
  • Trade association seminars and webinars;
  • FDA meetings;
  • Use of the NSF Nonfoods Chemical listing as a resource in chemical classifications for MRO chemicals to achieve compliance with FSMA
  • MRO Chemical Compliance Manual or Notebook
  • Implementing an internal (and external, customer-focused) implementation program to ease compliance.

Note to readers: One such implementation program already on the market is offered by CRC Industries, an industry leader in the manufacture of MRO chemicals.  Its StopLight™ program is a color-coded shop floor management system intended for front-line production and maintenance workers who use MRO chemicals.  StopLight™ includes workplace posters, training modules and related services designed to help food manufacturers understand the importance of safe handling of MRO chemicals.  Most importantly, StopLight™ is tailor-made for FSMA implementation.

 More information is available at