What the sanitation rules actually ask of a building
Most compliance conversation is about procedure. A smaller part of it is about walls, floors and ceilings, and that part is ours.
Article
Food-safety regulation is mostly about what people do. But a few lines of it are about what the building is made of, and those lines decide things an operator lives with for twenty years.
The clause that describes our product
USDA's sanitation regulation for inspected establishments says walls, floors and ceilings must be built of durable materials impervious to moisture, and be cleaned and sanitized as necessary to prevent adulteration of product or the creation of insanitary conditions. It requires those same surfaces and every outside opening to be constructed and maintained to keep vermin out. And it requires ventilation adequate to control odors, vapors and condensation.
FDA's preventive-controls framework comes at the same problem from the process side: sanitation controls are the procedures and processes that keep a facility in sanitary condition and minimize hazards including environmental pathogens.
Neither is a specification for a panel. Both are a description of what the panel has to survive.
Three places a plant discovers the difference
Impervious to moisture is about the face, and about the joint between faces. A washable surface with a joint that traps water is not a washable wall.
Cleaned and sanitized as necessary is about the cleaning regime the plant actually runs, not the one in the manual. Caustic wash-down takes apart finishes that look fine on a sample board. This is where stainless earns its cost, and where getting the face wrong turns into a recurring maintenance line.
Control condensation reads like an HVAC requirement and is partly an envelope one. Temperature difference across an assembly, the gap between what is inside and what is outside — is a design input, not a detail. Ignore it in the girt spacing and the span, and the wall tells you about it later.
What we do not claim
The requirements above are placed on the plant operator. They are not an approval that attaches to a supplier, and we will not pretend otherwise: nobody earns compliance by buying a panel.
What a supplier can do is understand the rule well enough to specify an assembly that does not make your job harder. That is the whole of our contribution, and it is worth more than a certificate would be.
Send over the process, the cleaning regime and the inspection requirements you are designing against, and we will tell you what the envelope has to be.
Sources
Every figure above comes from one of these, with its publisher and date so you can check it. Our own experience — the failure modes and the selection decisions — is ours, and is not sourced to anybody else.
- 9 CFR 416.2 — Establishment grounds and facilities — USDA Food Safety and Inspection Service, current
- FSMA Final Rule for Preventive Controls for Human Food (21 CFR 117) — US Food and Drug Administration, current
D.W. Ross Company — Building envelopes that have to hold a temperature, from Cleveland, since 1921. These notes come out of our own projects.
Where this applies
Got a room that is not behaving?
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