Cleaning and Sanitizing
When it comes to cleaning and sanitizing, it is important to remember cleaning and sanitizing are two different things, and cleaning always happens first. Cleaning is the physical removal of dirt and filth, whereas sanitizing is the treatment of a surface to reduce the microbes living on a surface. Dirty surfaces cannot be sanitized. Cleaning always happens first.
21 CFR 112.123(d)(1) states that “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.”
Something worth noting here is that sanitizing is not required in the PSR in all situations. That said, it is strongly recommended in most situations that growers clean and sanitize direct food contact surfaces. This is especially true if those surfaces have feces on them.
There are four steps to cleaning any food contact surface. The surface should be prerinsed to remove soil, washed with soap and water, rinsed of soap and water, then sanitized. If you use disposable, single-use harvest containers, they do not need to be washed and sanitized. If you use any reusable, cleanable containers such as plastic lugs or buckets, they should be clean prior to being filled with produce.
Under FSMA, sanitizing harvest containers is mandatory when switching between excluded produce and covered produce [21 CFR 112.111(b)]. Regardless of FSMA coverage, GAPs include cleaning and sanitizing all direct food contact surfaces before contact with produce.
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