The requirements for the storage of cleaning and maintenance materials depend on if the materials are being stored in a building or not.

It is NOT mandatory for cleaning and maintenance materials to be stored in a building.

According to the CanadaGAP manual, the definition of building is:

Any structure where product or market ready packaging materials are handled and/or stored, and any structure where agricultural chemicals, commercial fertilizers, etc. are stored (e.g., packinghouse, storage areas, hydro-cooling/washing/grading areas, etc.).

Cleaning and maintenance materials are included in this definition (under ‘etc.), since it is impossible to have an exhaustive list of everything found in a building. The building itself could be a variety of structures (e.g., a house, shop, garage, etc.).

If cleaning and maintenance materials are stored in a building:

  1. The operation must accompany first time visitors and have a Form L (Visitor Sign-In Log) for that area.
    • NOTE: In some cases, this might not be an area where visitors would go, so the visitor sign-in log would not actually be actively used. However, the auditor would still expect to see the sign-in log in this case.
  2. The area where the materials are stored must be controlled-access. A controlled-access area is: An area within a building that only authorized persons are allowed to enter (e.g., packing/repacking area, storage area for market ready packaging materials, product or cleaning and maintenance materials). Access must be controlled to those designated areas (e.g., signs are put up, walls are in place, etc.).
  3. Pest control may be required for that area/building
    • NOTE: Use the important note at the beginning of each section in the manual to do a risk assessment. If there is going to be a food safety impact on the product or potential for cross-contamination, then the pest control requirements must be followed. However, in many cases pest control requirements will not be required (e.g., there would be no risk with a bottle of cleaner, etc.)
  4. Section 9.3 Cleaning and Maintenance Materials – Storage requirements apply

However, as stated above it is NOT mandatory for operations to store cleaning and maintenance materials in a building. An example of this would be a case where an operation brought a tote/box out into the field with them. In this case, where the cleaning and maintenance materials are not stored in a building, the only requirements that would apply from the list above would be the Section 9.3 Storage requirements.

April 28th, 2023 at 02:30 pm