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Incorporating a Color-Coding Program
by Cristal Garrison
With the signing of the Food Safety and Modernization Act (FSMA), many food processors have been taking a critical look at their production practices and looking for solutions to further enhance food safety procedures throughout their facilities. Many are considering or have already instituted some form of color coding of tools and equipment to help manage their food safety risks.
Color coding can help maintain hygienic standards and mitigate cross-contamination throughout a food processing facility by creating a clear distinction between tools that should be stored and used in designated areas. An effective color-coding system can support a food processor’s current Good Manufacturing Practices (cGMPs) because by assigning tool and location colors, one can easily designate safe, appropriate areas for food contact tools to be stored, cleaned, and sanitized. Color coding may also be outlined in the written food safety plan for the operation.
GMPs, as part of a food safety plan, are outlined by the FDA in Title 21 of the Code of Federal Regulations, Part 110 (21CFR110): GMPs describe the methods, equipment, facilities, and controls for producing processed food. As the minimum sanitary and processing requirements for producing safe and wholesome food, they are an important part of regulatory control over the safety of the nation’s food supply. GMPs also serve as one basis for FDA inspections.
To this end, good organization of tools via color coding not only demonstrates the effectiveness of a food safety plan, but can also make a good impression with inspecting authorities.
Many food processors have gone the extra step to apply color coding in the development and implementation of their Hazard Analysis and Critical Control Point (HACCP) Plans—those plans that manage the analysis and control of biological, chemical, and physical hazards from the time raw materials enter their facilities to when their finished products are completed. Under FSMA, eventually all regulated food companies will be required to have a written food safety plan or HACCP plan.
At the same time, some food processors are borrowing the principles of Lean Manufacturing’s 5S System as a way to organize their workplaces and maintain equipment standards.
Regardless of the system considered, food safety should be of paramount importance in the development or revision of a color-coding system. Simply instituting a color-coding program does not in itself ensure the purity and quality of the finished food products, nor does it assure easy adoption by processing personnel. As with anything, there’s a right way and wrong way to apply color coding to food processing. This article will address some basic color-coding best practices aimed at achieving optimal results.
Determining Critical Food Safety Factors
First, determine the critical factors within your processing facility that should be controlled with color coding. The core objective of color coding within a food processing facility is to clearly establish areas where tool and equipment control is critical in maintaining sanitary conditions, and to clearly and effectively communicate the use areas of tools and equipment for personnel to control food safety risks throughout a facility. Thus, the first step in developing an effective color-coding program is to determine those factors that are critical in maintaining a safe food operation.
For example, in a facility where raw meat is processed and cross-contamination is a concern, one would not want the tools that touch raw meat to also be used on the final ready-to-eat product. One food manufacturing facility may be concerned with controlling the risk of pathogens (e.g., Salmonella, E. coli, Listeria, etc.), while another processor may worry about cross-contamination of common allergens (e.g., peanuts, eggs, milk, soy, etc.) within their processing facility.
That’s why color coding is often applied to a food processing operation based on sanitation zones. It is critical that the cleaning of a production environment be effective and that the movement of ingredients, personnel, and materials be controlled throughout the environments in a facility. Sanitation zones are defined as: Zone 1—Food contact areas (e.g., utensils, conveyor surfaces, people’s hands/feet, hoses, and items that can come in contact with Zone 1); Zone 2—Non-food contact areas (e.g., equipment panels, aprons, conveyor rollers); Zone 3—Non-food contact areas adjacent to food contact areas (e.g., processing area drains, equipment frames, table legs, and floors); and Zone 4—Remote and/or non-food processing (e.g., non-processing area drains, doorways, walls, and hand-wash stations).
Under this zone-based scenario, let’s suppose there’s a color-coding program for a candy manufacturer. The area of the facility that produces chocolate bars may be designated red, while the area that produces peanut clusters may be designated blue. Then, within each designated area, there may be color assignments based on sanitation zones. For instance, in the chocolate bar area, the equipment and tools within each zone could be: Zone 1—Red (same as area zone color), Zone 2 —Yellow, Zone 3—Green, and Zone 4—Orange. Note, the color assignments mentioned in this article are strictly examples to demonstrate the concept of color coding. Color assignments are not standardized, as each company will choose colors that best suit their product, process, facility, and company objectives. For example, a meat processor for use in direct food contact areas may select white tools, while a processor of flour or white gravy would likely choose a different color, such as blue.
Second, make sure your color-coding system is intuitive. This may be the most important advice in developing an effective color-coding program. Too often food processors will designate a different color for every tiny aspect of their food operation, resulting in a myriad of colors. The key is to keep your color-coding assignments simple. Do not over complicate your system with too many colors.
Once you develop a draft of your color-coding plan, it’s a good idea to take a step back and look at the color assignments with fresh eyes. Better yet, ask someone outside of your development team to review the plan and see if they understand where each color should be used. If the system doesn’t immediately make sense, you run the risk of it not being successful.
When considering a color-coding system, it’s also suggested to involve key managers and personnel within your organization to help with its development. A typical team may include plant manager, quality assurance manager, engineering manager, line supervisor, maintenance manager, sanitation manager, and shipping and receiving manager. In addition, if you have someone in charge of maintaining your HACCP plan, then that person may also be included. Don’t discount the importance of gathering input from production line employees who will actually be using the color-coded tools. Their input can be invaluable in helping to identify colors that should or shouldn’t be used (e.g., taking into consideration employees who may be color blind and/or not capable of differentiating between certain colors).
Assuming your color assignments are easily understood, it’s important to properly communicate the details of your color-coding system to your employees. Employees should be instructed on why the program is important and how it should work. They also need to be trained on what to do when a breach in the system occurs. The entire company should be on board with your program’s objective and support it in daily practice.
Here are some other common-sense tips for an intuitive color-coding program:
- Contrast the food being produced. For example, a processor of tomato sauces would most likely want to stay away from using red tools in direct contact with food products. Should a red hand tool, for instance, fall into a mixing vat or tank of tomatoes being processed into spaghetti sauce, it would be difficult to quickly identify it and ensure the tool, in its entirety, was retrieved from the food product.
- Maintain consistency. Be consistent with how you apply your colors. Tools and equipment, as well as walls, floors, and clothing should be considered. If different departments implement more than one color-coding scheme without consultation with each other, it is likely that all of the schemes will fail due to confusion. The application of each color selected should be unique and identify the areas in a process where the risk to be controlled is apparent. The color should be acknowledged by all color-coding schemes and used consistently regardless of the time or place the color may be encountered.
- Match storage unit and tool colors. Mitigating cross-contamination within a food processing facility is further enhanced with proper tool storage. It’s recommended that color-coded storage racks coordinate with the color of the tools stored in each area. Proper tool storage also means tools should not touch walls or floors to maintain sanitary condition and further mitigate cross-contamination and assure food safety.
- Reinforce your color-coding program with proper signage. The more you can communicate with your employees to assure that color-coding standards are followed, the more effective the program will be.
Accessing Proper Tools
Third, choose the right equipment and tools for your color-coding program. As you embark on developing a color-coding program, you shouldn’t have to go it alone. You should be able to lean on your suppliers to help develop and implement a color-coding plan and supply the proper tools. Look to suppliers who have a track record of developing successful color-coding programs for food processors. Seek out companies with the expertise and an extensive product line to partner with you in implementing a color-coding system tailored to your specific operation. Similar to the consultative approach taken by many chemical companies, expect your tool supplier to also provide a certain level of service and advise you on the proper use of their products.
As you procure color-coded tools and equipment for your facility, note that not all color-coded implements are the same. Look for tools and equipment that are hygienically designed and made for the specific tasks within your facility. Most important, consider tools that are intended for a color-coding program in a food manufacturing environment. These are tools that are all one color (with matching blocks and bristles) to help avoid any confusion among employees. (Note, labeling or painting tools as a way of identification is not recommended as these additions introduce new hazards into the manufacturing process.)
Your color-coded tools should also carry proper documentation showing that they are made from materials that meet FDA standards for food contact. A tool supplier should be able to provide this documentation. Ask your tool supplier for the appropriate documentation and if they can’t provide it, you may want to consider another supplier who can.
Fourth, review your color-coding program regularly to assure its effectiveness. Implementing a color-coding system is one thing. Maintaining its effectiveness is quite another. Review your food safety program on an ongoing basis, which should include your color-coding designations. Whether it’s once a month, once a quarter, or every week if necessary, diligent maintenance of your food safety program is paramount in minimizing food safety risks. This means regularly replacing tools when they start to show wear (i.e., tools that are discolored to the point that they are no longer matching your color-code scheme, have worn or poorly maintained bristles, etc.). It might also include reinforcing your program with ongoing employee training. Your color-coding team may also wish to regularly convene to reevaluate color assignments whenever something changes (e.g., you add a new piece of equipment that crosses sanitation zones).
Color coding can be a successful system used to assist companies in conforming to food safety regulations and ensure the quality of processed foods. By following these best practices, food processors can ensure proper hygiene and reduce the risks of cross-contamination. In the end, the best color-coding systems are all about keeping it simple, clean, and maintained with tools that carry proper documentation.
Garrison is director of training and development for Remco Products Corp. She is a member of NEHA, IEHA, IAFP, AFDO, and holds certifications from the National Registry of Food Safety Professionals, International HACCP Alliance, and AIB. Reach her at firstname.lastname@example.org.