40.6.4 Somekey attentionpoints during the audit
Keepingin mind that we intendto assessthe hygiene programme againstthe
backgroundof its primary job description,i.e. to keeppotentially negative
environmental influences well away from the food and from HACCP
consideration,and to support laterprioritisation of improvementopportunities
we maywantto makea distinction between items in directcontactwiththe
food,and primary, secondaryand tertiaryenvironments.
Itemsin direct contact withthe foodincludethe following:
∑ All aspectsof foodcontactequipment (materials used,welds,deadends,
drainability, etc).Followingthe breakdown introduced in section40.3,the
audit teamwillneedto assesswhetherappropriatedesignstandards have
beenapplied, what typeof maintenance (regularly scheduled,preventive,
breakdown) and sanitation are used, whether records confirm the
effectiveness and appropriatenessof the maintenanceprogramme (if an
unsanitary situation has arisenand persistedfor any lengthof timebefore
repairs weremade,this should be raisedas an issueand possibilitiesfor
preventiveaction shouldbe considered).
∑ Chemicalsusedfor maintenance and sanitation,and the residues that may
remain on foodcontact surfacesshouldalso be included.
∑ Workers' handsin directcontactwiththe food;barehandsor glovepolicy,
glovereplacement,handwashing procedures etc.
Primary environmentincludes the following:
∑ Immediatesurroundingof the foodproduction.The audit shouldassessthe
zoning'policies(accessrulesand GMP requirements applyingto people, materials, utensils,vehicles,pallets) applied to the immediatesurroundingof (partially)openfoodproduction areas. Sensitivity of the foodmaterials and processes determines zoning rules. ∑ Potential contactmaterials; safetystatus and managementof thosematerials (lubricatingoils/grease, heating/coolingmaterials)that couldinadvertently come into contactwiththe food. Secondary (the rest of the plant) and tertiary(direct vicinity of the plant) environmentincludes the appropriatenessand management, includingzoning,of designatedareas outside the primaryenvironment. Considerationofdirty' areas
insideor in the directvicinity of the manufacturingsite. The generallayoutof
the facility, in termsof being supportive of appropriate zoning, and potential
routes and mechanisms of contamination should be assessedfromfoodcontact
surfacesto the various environments, including the use of historical data
pointing at actualpossibilities.
Sometopicsfor special attention are mentionedbelow. The list is not meant
to be a quickand balancedguidethroughall applicablehygienemanagementor
equipmentand infrastructuredesign standards,or a reliableapproximationof
`all relevantconsiderations'for a HMS. Ratherit is meant to providea summary
of this author's experiencewithpotentialHMS weaknesses in foodprocessing
692 Handbookof hygiene controlin the foodindustry