How can we ensure the cleaning of food companies is carried out in a way that is both safe for workers and compliant with food safety standards? Two cleaning experts share their honest struggles and the dilemmas they face when cleaning production lines in the food industry.
An accident can happen in the blink of an eye. “In the food industry, it’s not uncommon for debris, like a piece of meat, to get stuck deep inside a machine or between conveyor belts,” explains Jan van der Heijden, Commercial Manager at cleaning company Kleentec. “Spraying alone doesn’t release it. I know that sometimes our employees resort to creative, even risky, measures to remove it—simply because they want to do their job well. Most of the time, it works out fine. Until the one time it doesn’t.”
Cleaning companies are expected to comply with regulations set out by the Labor Inspectorate. “Of course,” Jan agrees. “Protecting our employees is always our top priority. We emphasize this in our training and instructions. But we also realize that we often need to protect our employees from themselves because incidents usually happen due to their dedication. We can’t control everything.”
In 2021, a tragic accident occurred in which an employee lost part of a finger. “It confirmed something we had long known,” Jan continues. “Our work, carried out near operating machinery, is inherently risky—even with all the preventive measures, instructions, and supervision in place.
Following this incident, we engaged extensively with the Labor Inspectorate to evaluate the event thoroughly. The goal, of course, was to prevent similar incidents in the future. Beyond the human tragedy, there are also business consequences to consider: from steep fines to potential temporary shutdowns. You want to avoid that at all costs. It forces you to critically assess your processes and operations.”
“But the fines are exceptionally high,” adds Hans van der Steen, Business Manager at HDN. “As a result, there’s a risk that companies may avoid reporting incidents—either to protect their image or out of self-interest. This leads to unsafe situations going unnoticed, creating a false sense of security. When hazardous conditions don’t receive the attention they deserve, necessary measures aren’t taken. That’s a serious problem—it affects everyone involved in building, operating, and cleaning these systems.”
“That definitely doesn’t happen at Kleentec,” Jan assures. “We report everything. Failing to report goes against our collective goal,” he emphasizes. “The iceberg theory shows that reporting all accidents and unsafe situations helps prevent major incidents—especially when appropriate measures are taken immediately after a report. Reporting increases safety awareness. That’s a proven fact.”
Following the incident, Kleentec underwent an intensive period of consultations with the Labor Inspectorate. Jan recalls: “This gave us the opportunity to showcase our preventive measures. Our risk inventory and evaluations were reviewed and deemed ‘thorough,’ as was most of our overall approach.”
However, the Labor Inspectorate also offered critical feedback: “They told us, ‘You think you know how to clean these machines, but you’re not certain because you don’t request the machine manuals, which include the cleaning protocols.’ That prompted us to request all machine manuals from our over 100 clients operating across approximately 130 sites. Let me tell you—it caused quite a stir,” he chuckles. “We cataloged the manuals and compared our actual cleaning practices with the instructions provided. Based on this information, we adjusted our methods at several locations. This collaborative effort with the Labor Inspectorate produced valuable insights. Interestingly, we found that the cleaning guidelines provided by machine manufacturers aren’t always clear or logical.”
“That brings us to a third challenge,” Hans continues. “Creating practical cleaning instructions. Sometimes, they’re missing altogether. Every manual—whether for a machine or a floor drain—should include a clearly defined section explaining how cleaners can achieve the desired result for the client.” HDN’s methodology is based on European standards and guidelines for designing, building, and installing machines and process systems in the food industry. HDN ensures that installations in food production and processing comply with European regulations. “One of the stumbling blocks is the lack of clear definitions: What exactly does ‘clean’ mean? When is something ‘clean’? And what does a cleaner need to know, be capable of, and do to achieve that?” Hans explains. “There are countless interpretations. What’s needed is a clear understanding of the technical measures required to achieve the desired level of hygiene—and vice versa. We also believe the craftsmanship required to implement these measures properly should be recognized. This applies to cleaners as well.”
Jan explains that the real dilemmas arise because the Dutch Working Conditions Act (Article 7.5, Section 2) stipulates that cleaning must be done ‘without energy,’ meaning machines must be unplugged. If this isn’t possible, ‘effective measures’ must be taken to ensure work can be carried out safely. “But it is unclear what those ‘effective measures’ are,” he says. “Machine manufacturers often include cleaning protocols in their manuals, requiring cleaning to be done while the machine is powered down to avoid injury risks. According to these manuals, cleaning should only occur when the machine is stationary.
However, in the food industry, dirt often accumulates in moving parts of the machine or production line during operation. Leaving it there is not an option—it poses a massive food safety risk. Just look at Listeria outbreaks. If you don’t control them, things can go disastrously wrong, resulting in victims as well. It’s impossible to thoroughly clean every part when the machine is completely stopped. The only way to remove debris lodged in a moving line is to clean it while it’s running. The Labor Inspectorate and machine manufacturers prioritize worker safety, pushing the risk associated with cleaning onto the NVWA (Netherlands Food and Consumer Product Safety Authority) and cleaning companies. The latter are then faced with a ‘devilish dilemma’: it’s their job to deliver a clean line to the client and the NVWA.”
Hans adds, “There’s a lot of attention to improving road safety in society. If I drive to the next village, I have to cross three speed bumps, stick to a 30 km/h limit in residential areas, and wear a seatbelt, not to mention the mandatory helmets for motorcyclists and scooter riders. These measures are well-accepted and entirely justified. But when it comes to food safety regulations, attention is minimal—even though lapses in this area can also result in victims. That’s why we’re working to promote the Hygiene Risk Assessment (HRA), much like the Risk Inventory and Evaluation (RI&E). The HRA identifies the risks and potential consequences for consumers of products made with the same machines. These consumer risks are often less obvious than the direct consequences for an operator or cleaner. Food safety, alongside worker safety, includes both cleaning practices and cleanability.”
At Kleentec, a Risk Inventory and Evaluation (RI&E) is always conducted during the commercial process after a contract is awarded and before any operations begin. Following intensified contact with the Labor Inspectorate, this step received even more attention than before. “We were invited by a potential client to submit a proposal for cleaning their production site. We prepared a quote, mapped out all tasks, and signed the contract. Afterward, we conducted our customary thorough RI&E.
During the RI&E, our safety expert identifies all possible hazards and proposes appropriate measures to control those risks. He identified that some machine manuals had been updated by the manufacturers in the meantime. For instance, in 2016, carousels could still be cleaned while rotating, but by 2023, the manuals explicitly stated that cleaning had to be done without power or pressure—that is, while stationary. We suspected these stricter cleaning protocols were added to avoid legal claims potentially tied to cleaning. From a business perspective, I understand that. But it makes our job significantly harder.” When asked, the machine supplier confirmed these suspicions. Jan recalls, “They said, ‘We have a large legal department guiding us on what we should and shouldn’t include.’”
Kleentec attempted to find an alternative solution for the prospective client by proposing the installation of two hand-operated control buttons on the line. This system would allow the two cleaning staff to see each other and simultaneously press their buttons, causing the line to move one second at a time for incremental cleaning. “However, this solution was also flagged by our safety experts. Despite the ingenuity, they deemed the remaining risks unacceptable, as employees wouldn’t be optimally protected. Ultimately, we had to withdraw from the contract. How valuable would it be to have a dedicated advisory body where you could validate whether your proposed solution meets the criteria described in the Dutch Working Conditions Act, Article 7.5, Section 2: ‘If cleaning without power is not possible, effective measures must be taken to ensure the work can be performed safely.’ That absence is a significant gap.”
Hans is a strong advocate for conducting a hygiene risk assessment before building any machine. “You need to identify all risks that could arise during cleaning. If the requirements aren’t completely clear, misinterpretations occur, and that’s where things go wrong,” he emphasizes. “Machine manufacturers often make assumptions that don’t align with client expectations. In the food industry, for example, alkaline and acidic cleaning agents are frequently used, which corrode the protective oxide layer on stainless steel. If you don’t use the correct grade of stainless steel for the specific situation, problems arise. There are approximately 220 types of stainless steel, so there’s a real chance of getting it wrong. Manufacturers often carefully consider the pipes and plates used but may skimp on bolts and screws. Everyone has their own interests, and profitability always plays a role. Companies do things as well as necessary but as cheaply as possible.”
Fortunately, some machine manufacturers excel in their approach. However, even they can’t prevent everything from going wrong. Machines are built and delivered with CE certification. But as soon as the client replaces parts or makes modifications, that certification becomes void. The Labor Inspectorate will then no longer hold the machine builder responsible in the event of an accident. “The machines clients purchase are often black boxes filled with technical features that, at first glance, seem illogical,” Hans explains. “If you don’t understand why a pipe is angled a certain way or why an odd corner exists, the in-house technical team might modify it during maintenance. The result? The machine can no longer be cleaned properly.”
Hans believes this kind of knowledge must be shared more widely. HDN actively works to achieve this. “Our goal is to simplify and standardize communication between different parties through training programs. We aim to bring these stakeholders together and develop ‘best practices’ to bridge the gap between engineering and technology. Our approach is pragmatic, not theoretical. These best practices are translated into practical learning modules, including e-learning courses and classroom training. We also use these resources to create cleaning-friendly manuals tailored to specific situations and to support training programs for cleaners that better match technical requirements. To establish working groups, we consistently seek input from experienced professionals in the field.”
The message is clear: a joint effort is needed to structurally improve employee safety and guarantee food safety. “We need to determine together what measures adequately address the safety of workers, whether they’re operators, cleaners, or consumers,” Hans concludes succinctly.
Bringing all the parties to the table, however, is easier said than done. Both the NVWA and the Labor Inspectorate want—and need—to maintain their independence, while machine manufacturers avoid formal agreements that could expose them to legal liability. Jan concludes: “Finding a balance between regulations and real-world practices is no easy task. We’re ready to have that conversation with everyone involved.”
Source: Vakblad Voedingsindustrie 2024
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