The Food Safety Modernization Act (FSMA) imposes world-class regulations using hazard analysis and third-party certifications to ensure food safety. What’s more, a CDC, FDA, and USDA Interagency Food Safety Analytics Collaboration is currently underway to more precisely pinpoint foodborne-illness origins (including those involving automated machinery) using modern approaches. Expansion of the FDA could boost the organization’s authority to investigate issues, audit food plant records, establish food-contamination limits, and issue mandatory recalls.
Under the FDA’s Food Traceability Final Rule, by 2026 all operations that store, pack, process, and manufacture food will need to comply with new tracking requirements. Connectivity of automated equipment will need to support such traceability — and as always, the construction of automated equipment must and will always need to satisfy hygienic design requirements.
Consider the electrical-component enclosures of such equipment. When destined for especially harsh food-processing facilities, these enclosures must prevent pooling of liquids and debris (at the root of certain types of bacterial growth) with smooth surfaces and sloped tops. Such enclosures must also satisfy the National Electrical Manufacturers Association’s Type 4X rating certified by UL primarily for North America. This certifies the enclosures’ watertightness and protection against water ingress. The latter is especially important where equipment is subject to washdown. Type 4X ratings also certify corrosion resistance — usually because the enclosure is constructed of select polymers or stainless steel.
304 and 316 steel in particular are easy-clean and corrosion-free options even in food-processing facilities subject to aggressive washdown routines involving harsh cleansing agents.
Of course, all equipment components should be constructed of or enclosed in materials that are nontoxic and safe for use near food — or be painted, coated, or sealed in food-safe housings. Portions of automated equipment that directly contact food (or are close enough to allow migration of substances into food) must be constructed of materials that satisfy specific FDA regulations and guidelines to ensure they don’t pose any health risks. Case in point: The use of chlorinated polyethylene (including halogen elements) is currently regulated under FDA’s Title 21 CFR Part 177.1610. While subject to any future changes, the regulation currently specifies that chlorinated polyethylene is safe for use in components that contact with food save for certain fatty foods. Likewise, silicones in food-manufacturing settings must be FDA-approved variations that resist extreme temperatures and maintain nontoxic chemical stability. Some enclosures feature silicone gaskets as silicone’s flexibility allows reliable sealing, though these needn’t necessarily satisfy the FDA’s CFR 177.2600 applicable to sealing elements that make regular contact with food.
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Filed Under: Food + beverage