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Help with understanding SSOP form 9CFR416.12(a)

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Ron Gardner

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Posted 28 September 2022 - 10:53 PM

 9 CFR 416.12(a) states: The Sanitation SOP's shall describe all procedures an official establishment will conduct daily, before and during operations, sufficient to prevent direct contamination or adulteration of product(s).

 

I am being told that this means that there must be a daily operations report during operations to note any issue that are found in the facility. Basically asking for a pre-op in the middle of the day.

 

I am a bit confused. what I read is that FOR YOUR SANITATION you must have SOP's or Standard Operation Procedures documented on what, when, how, where, and who for the sanitation procedures that you do prior to start-up and during operations. Such as, cleaning the equipment after use and sweeping up excess scrap from the floor.  

 

Not that I need a daily operations facility report  for the USDA.

 

Any Help out there?

Thanks.



Tony-C

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Posted 29 September 2022 - 06:12 AM

Hi Ron,

 

My understanding is you need to have:

Documented Sanitation SOP’s that, at a minimum, cover the cleaning of food contact surfaces

A Sanitation Schedule

Checks of the effectiveness of the Sanitation SOP’s

Records of Sanitation including monitoring and any corrective actions taken

 

Kind regards,

 

Tony



Scotty_SQF

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Posted 29 September 2022 - 11:23 AM

When I worked for a USDA facility, we had procedures that documented our cleaning and our Pre-Op check.  We also had to clean up before they took a break. (our line shut down for two 10 minute and one 30 minute breaks)  They had to document that the cleaning was done and it was checked by a lead in order to ensure no contamination.  I wouldn't call it a pre-op, more of a check to make sure that the cleaning before break was sufficient.  It's been awhile since I have worked in a USDA facility, but hope this helps.



Ron Gardner

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Posted 12 October 2022 - 07:49 PM

Thanks for the posts



G M

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Posted 27 October 2022 - 02:58 PM

 9 CFR 416.12(a) states: The Sanitation SOP's shall describe all procedures an official establishment will conduct daily, before and during operations, sufficient to prevent direct contamination or adulteration of product(s).

 

I am being told that this means that there must be a daily operations report during operations to note any issue that are found in the facility. Basically asking for a pre-op in the middle of the day.

...

Any Help out there?

Thanks.

 

Yes.  It doesn't need to be complicated.  We have someone walk through the production areas of the plant three times per shift and write a basic statement about what sanitation deficiencies were observed (90% of the time it just says the time and "no deficiencies") and what was done to bring them back to acceptable.

 

If no product is involved the response is usually pretty simple.  This is where some of the non-conformance and corrective action policies come in to effect.

 

The same Operational Sanitation form also has a routine check for food fraud observation, which is also usually just a 'no'.



TucsonFoods-QA

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Posted 14 November 2022 - 03:39 PM

We do Pre-Op, Op (mid-day), all of our recipes contain a post-op cleaning and sanitation check area (for allergen and non-allergen) after each use. Like GM said, keep it simple.



DeadPresident

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Posted 14 July 2023 - 05:56 PM

I ran into thi

 

 9 CFR 416.12(a) states: The Sanitation SOP's shall describe all procedures an official establishment will conduct daily, before and during operations, sufficient to prevent direct contamination or adulteration of product(s).

 

I am being told that this means that there must be a daily operations report during operations to note any issue that are found in the facility. Basically asking for a pre-op in the middle of the day.

 

I am a bit confused. what I read is that FOR YOUR SANITATION you must have SOP's or Standard Operation Procedures documented on what, when, how, where, and who for the sanitation procedures that you do prior to start-up and during operations. Such as, cleaning the equipment after use and sweeping up excess scrap from the floor.  

 

Not that I need a daily operations facility report  for the USDA.

 

Any Help out there?

Thanks.

 

I ran into the same problem and had the same questions. Basically, we had to do a mid-op inspection which I found to be moot since we are in operations in the middle of the day, so, how can FSIS expect the production room to be clean?



G M

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Posted 17 July 2023 - 04:14 PM

...we are in operations in the middle of the day, so, how can FSIS expect the production room to be clean?

 

Operational sanitation just needs to be clean enough to comply with safety regulation, not spotless like pre-op.

 

Even if your process is generating a mess, you presumably have someone monitoring that it doesn't accumulate to such a degree that it impedes operation.  Odds are you're already doing the check, just not recording it.  

 

See my previous post for an example.



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DeadPresident

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Posted 19 July 2023 - 11:15 AM

Operational sanitation just needs to be clean enough to comply with safety regulation, not spotless like pre-op.

 

Even if your process is generating a mess, you presumably have someone monitoring that it doesn't accumulate to such a degree that it impedes operation.  Odds are you're already doing the check, just not recording it.  

 

See my previous post for an example.

 

 

thank your the response.





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