July 01, 2009
by Kimberlie Clyma
The goals of environmental compliance and a food-safe processing facility are complimentary. You know your business better than the government, and 95% of the time if your business is run cleanly and efficiently, you will conform to current regulations. The American Institute of Baking International (AIB) published and excellent guide to prioritizing the work called the "AIB International Consolidated Standards for Inspection." It can be accessed at www.aibonline.org.
A 3-ring binder with scanned copies of all documents is an easy way to manage the permits, plans and associated paperwork. This system can help a plant manager quickly respond when visited by an inspector. When an activity is referred to as permitted in this article, it means that you need a piece of paper that is a permit; not that you have permission to do it. Many of the regulations referred to require annual reporting. If you don’t have the paperwork for all this, fines can be very steep, beginning at $25,000 a day per violation with variable jail times.
Take a deep breath, this is dense material. And local, state and federal requirements not only vary but may be contradictory. Here’s a quick synopsis:
• Air permits to construct, modify and operate a facility using yeast fermentation are usually issued for five or 10 years but must be renewed six to nine months before they expire.
• Air control devices for ovens such as catalytic oxidizers and dry ingredient silo baghouses used for flour are permitted.
• Permits may also be required for odor and outside visual emissions such as the "smoke" that may be part of a diesel startup.
• Boilers, steam-generating units and emergency generators are permitted.
• Refrigeration systems maintenance, refrigerant disposal and documentation are regulated. In addition, ammonia systems require emergency response plans as well as an US Environmental Protection Agency (EPA) Risk Management Plan and an OSHA Process Safety Management plan.
•Hazardous chemicals such as code and date stamp inks and oven lubricants probably need to be reported for air permits, the Toxic Release Inventory Reporting and the EPA Hazardous Chemical Inventory.
• Dust and noise limits inside the building are regulated by local fire codes, EPA and OSHA.
• Flour and air compressors are critical checks for particulate concentrations.
• Asbestos is regulated. Radon testing is required in certain areas.
• Mold is bad; think food contamination and worker safety.
• Pesticides are regulated.
• Permits are required for the discharge of water from food processing, sanitary wastewater, boiler blow down and storm water. A spill plan is required to prevent any ingredient such as vegetable oil and flour, oil from the parking lot, material stored on-site or any other delivery from reaching a storm drain. Flour on the roof is bad; think cost of flour, bugs, birds and a stormwater violation.
• The testing of drinking/processing water and discharge water is often required. Reuse of gray water is becoming more common, and the rules are variable.
• Truck washing on-site is a regulated or an illegal activity.
• Above-ground and underground storage tanks are permitted, and the management of leaks is regulated. Locks, berms and security fencing may be required.
• Hazardous substances require special storage and disposal. Documentation is critical.
• Disposal of electronics including lighting, air conditioners, cell phones, computers and just about anything with a chip is regulated and often permitted. Fluorescent lights often are returned to the manufacturer. PCBs are a particular concern.
• Disposal of cleaning solvents, used oils, paints and other hazardous substances must be documented. Disposal of materials that go to landfills, incinerators or for animal feed must not be exposed to storm water and the disposition of the materials should be documented.
For more information, visit www.epa.gov for guidance documents including "Multimedia Environmental Compliance Guide for Food Processors" and other documents and resources available at http://cfpub.epa.gov/clearinghouse/index.cfm?TopicID=C:10:900:311:
Rules for OSHA worker safety, DOT fleet management, USDA for meats, FDA food safety, Homeland Security can be found at the respective Web sites.
This article can also be found in the digital edition of Baking & Snack, July 1, 2009, starting on Page 13. Click here to search that archive.