The Facility Evaluation Before the Audit

The certified coatings professional will often walk the facility with representatives from the sanitation, engineering, and maintenance departments, looking for any areas of concern. These stakeholders are vital participants, as they are intimately involved in audit and repair processes. Sanitation managers often deal directly with FDA or other third-party auditors and will know what needs to be fixed and by when. Facility engineers and plant managers oversee coatings recommendations, specifications, timing, and budgets. In addition, maintenance managers are responsible for scheduling and completing the repairs.

During an evaluation, this multi-disciplined group may address deficiencies like rusty equipment, peeling or flaking paint, porous surfaces that can harbor bacteria, and improperly sloped drains. For example, a facility won’t pass inspection when peeling paint and rust are evident, so the coatings professional will be watching carefully for even early signs of corrosion. In addition, the professional will examine floors to determine if they are sloped properly to drains to eliminate standing water and reduce slip/fall hazards. It may also be noted where it would be helpful to incorporate a cove base to ensure a seamless transition from floors to walls and thereby eliminate a common harborage point for bacteria.

Preparing Facility-Wide Coatings Repair Specifications

Following an evaluation with a certified coatings professional, a facility will receive a detailed report that includes coatings repair specification recommendations for every area of the facility reviewed, based on that environment’s specific needs. As noted above, the recommended repair specification for patching a floor in a wet processing area will list urethane concrete systems as the materials of choice rather than epoxy systems, which are prone to premature failure in wet environments. Specifications for chemical storage room repairs may include impact- and chemical-resistant coatings, as these environments are prone to damage from forklifts and barrels. Specifications to repair insulated metal panel wall systems found in coolers may list different impact- and chemical-resistant coating systems rated for low temperatures.

Professionally prepared specifications may also include quotes for various levels of repairs based on service life, functionality, cost, and timing expectations, as well as a list of qualified contractors for bidding purposes. Ultimately, repair specification recommendations are intended to promote long-term solutions, not just quick fixes to pass an upcoming inspection. However, it’s helpful for a facility to have a range of good/better/best repair scenarios, along with general pricing so managers can determine the best option based on all the variables in play. For instance, they may choose to make a faster, less robust repair initially to ensure a quick return to compliance during busy times and then opt to make a longer-term repair during scheduled downtimes for maintenance.

From a relationship standpoint, a formal evaluation and specification provided by a coatings supplier can further help with expediting repairs. When a facility is already set up in the supplier’s system, it can reference the repair specification, place an order, and likely address repairs sooner than if the facility needed the supplier to first visit a site and make recommendations before ordering repair materials.

Repair specifications may include recommendations for incorporating cove bases (shown), whichcan provide seamless transitions from floors to walls, to eliminate a common bacteria harborage point.

Regardless of which actions a facility takes to make repairs and return to compliance, the repair specifications provided following a professional evaluation will help the facility comply with FSMA requirements to implement preventive control plans. The specifications establish an in-house plan of action to address deficiencies and audit citations. They also enable the facility to take a proactive approach to addressing repairs as opposed to only making reactive repairs based on audit reports. In addition, a company can extend its repair specifications to other facilities to create standardized preventive control plans across multiple facilities and environments. Doing so can potentially lead to greater efficiencies, including streamlined bid preparations, consolidation of suppliers, pricing reductions, and faster repairs.

Planning for the Official Compliance Audit

Following a comprehensive facility evaluation with a certified coatings professional and the receipt of comprehensive repair specifications, a food and beverage facility will be able to take the guesswork out of which coatings are the most suitable for each environment throughout its operations. The facility will be poised to implement a preventive control plan designed to reduce repair timelines before and after audits. It will also have the benefit of standardized specifications that can be shared company-wide, enabling the parent company to streamline processes for ordering products and maintaining just-in-time deliveries, as well as for proactively identifying approved contractors to expedite repairs. Finally, the facility will have the potential to reduce long-term maintenance costs and reduce downtime by selecting the best repair options and products suited to each environment to promote longevity.