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Romaine Calm: Breaking Down the Produce Safety Rule Cleaning and Sanitizing Food Contact Surfaces

April 3, 2019

By Tucker Diego, VT Agency of Agriculture, Food & Markets

This is the fourth article in our series “Romaine Calm: Breaking Down the Produce Safety Rule.”

Let's talk about cleaning. Keeping equipment, tools, and other food contact surfaces clean is crucial to maintaining the quality of your produce, the safety of consumers, and the integrity of your business. There are a number of key requirements in the Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR) related to cleaning. In this article we discuss one specific requirement found in Subpart L – Equipment, Tools, Buildings, and Sanitation, which states:

112.123(d)(1) You must inspect, maintain, and clean and, when necessary and appropriate, sanitize all food contact surfaces of equipment and tools used in covered activities as frequently as reasonably necessary to protect against contamination of covered produce.

Visit this URL for the full text of Subpart L: (case sensitive)

First, it's important to recognize the differences between cleaning and sanitizing. You'll notice that cleaning is always required, whereas sanitizing is required "when necessary and appropriate."

There are four basic steps to an effective cleaning and sanitizing routine. Cleaning involves (1) the physical removal of dirt and debris from the surface, (2) the application of an appropriate detergent (e.g., soap) in order to break down hard-to-remove debris, and (3) rinsing the surface with clean water. (See Figure 1.) Sanitizing is an additional step (4) that involves the application of a sanitizer to an already cleaned surface in order to reduce the presence of microorganisms. Sanitizers are considered anti-microbial pesticides that must be approved for use on food contact surfaces and used according to their label requirements. Depending on the sanitizer's label you may need to wash down the surface with clean water afterwards. Finally, all surfaces should be allowed to dry thoroughly. Microorganisms love wet environments, which makes drying a crucial final step that is especially important for porous surfaces, such as wood, that cannot be adequately sanitized.

It's also important to note that you cannot sanitize a dirty surface. Sanitizer cannot be used as a substitute for cleaning because sanitizers are not designed to break down dirt and debris in the same way that detergents can. Furthermore, the anti-microbial properties of sanitizers become much less effective when applied to dirty surfaces. This same reasoning applies when washing your hands; sanitizers are not effective substitutes for soap and water. If your hands are covered in dirt, applying only a sanitizer will achieve very little.

With this in mind, when should you use a sanitizer? If used in conjunction with effective cleaning, sanitizers are good at reducing the presence of microorganisms and preventing the build-up of biofilms*. Therefore, consider applying a sanitizer as the final step in your cleaning routine on food contact surfaces that are used frequently, process large volumes of produce, process different types of produce, or to establish a clean break to prevent cross contamination between lots. Think of sanitizers as an extra defense against bacterial and viral pathogens, and consider using a sanitizer whenever there is a significant risk of cross contamination.

At this point it's worth noting that not all detergents are created equal. Some are general purpose, while others are designed to break down proteins or fats. When designing a cleaning and sanitizing routine for a food contact surface, make sure to use detergents designed to clean the dirt and debris commonly associated with that surface.

Next, let's discuss frequency. You'll note that the PSR does not set any required cleaning or sanitizing frequencies. Instead, it's up to you to determine what frequency is necessary and appropriate. Here are key issues to consider when determining frequency:

What's practical?

It’s important to establish a routine that is practical and easy to follow for those performing the cleaning. If cleaning materials are not readily available, or are not kept stocked, it will be very difficult to maintain a frequency despite the best intentions.

What's necessary?

Generally speaking, before and after use are the most critical times to clean, and frequency largely depends on how often a piece of equipment is used. For equipment used every day you may decide to clean at the beginning of the day, between lots, and again at the end of the day. It may also be necessary to do deeper cleans as needed throughout the growing season.

Inspect, maintain, and monitor

Don't forget to periodically inspect, maintain, and monitor equipment and tools to ensure they remain in good sanitary condition over time.

Train, train, train

The best part about cleaning is that you can train someone else to do it. Train staff to follow written cleaning routines and make sure to update routines and retrain as needed. Staff should have the appropriate materials, equipment, and time to do an adequate cleaning job.

Developing cleaning routines and frequencies that work for your farm can take time and careful consideration. However, once you find a routine that works, it will soon become second nature.

Lastly, don't forget to keep records! Farms that are covered under the PSR must establish and keep documentation of the date and method of cleaning and sanitizing of equipment used for covered harvesting, packing, or holding activities. Records must be dated and signed or initialed by the person who performed the activity.

Not sure if your records meet these requirements? Contact the Vermont Produce Program for a cleaning record template at or (802) 828-2433. Visit for additional produce safety resources.

*Not all microorganisms are bad. However, sanitizers can be effective at reducing the build-up of specific microorganisms that pose a significant threat to public health and can cause severe illness or death (e.g. E. coli O157:H7, Salmonella species, and Listeria species).


Figure 1: Illustrations developed by E.A. Bihn, G. Wall, and M. Kogut and published in Bihn, E, Wall, G, Fisk, C, Humiston, M, Pahl, D, Stoeckel, D, Way, R, and Woods, K. 2017. Produce Safety Alliance National Curriculum. Version 1.1 Produce Safety Alliance, Cornell University.