With the advent of the 2011 Food Safety Modernization Act (FSMA), the U.S. Food and Drug Administration shifted its focus from response to prevention of food safety problems.
FSMA requires food facilities to conduct a comprehensive Hazard
Analysis to determine where potential food safety issues could arise
and then implement risk-based preventive controls to guard against
known and reasonably foreseeable food safety hazards. For a number of facilities, color-coding has become one of the preventive controls to protect against direct and cross-contamination.
A facility’s color-coding plan can be based on different allergens
or risk levels for contamination. For example, black is the recommended choice for drain-cleaning tools, and tools used on wheat
may be blue.
The Preventive Controls for Human Food rule recommends the
following best practices:
• Color-coded uniforms, smocks, and footwear to identify employees working in high-risk areas and minimize the spread of
• Color-coded containers to identify and separate waste from
• Color-coded equipment in hygienic zones to keep tools from
spreading one type of contamination or allergen to other areas in
• Color-coded facility maps to differentiate hygienic zones.
Evaluating the Applicability of Color-Coding as a Control
To evaluate the applicability of color-coding as a preventive control among the given food safety control options, the motive of the
control must be established. Why is such a control necessary?
In the case of color-coding, it could be that you’re trying to keep
allergens separate. Or, perhaps you need to distinguish between raw
and cooked products. Colors can also be used to identify tool storage
stations, equipment, utensils, and personnel. Color-coded hygienic
maps and zones, along with color-coded tubs, may also be used to
separate processes and products.
Food Safety Control Strategies and Color-Coding
There are three main ways color-coding could be presented as a
food safety control strategy:
1. As part of the Standard Operating Procedures: A color-coding
plan can specify the colors used for scoops for handling different products within allergen Standard Operating Procedures (SOPs), or cleaning brushes to be used for different surfaces within a Sanitation SOP.
2. As a preventive control within a food safety plan: For this, the
plan must be validated or justified, monitored, verified, and reviewed
as a food safety control.
3. As a standalone color-coding plan: This could reference other
procedures and can also become part of the food safety plan.
The facility may decide to reference color-coding within their
Good Manufacturing Practices (GMPs), preventive controls, or best
practices as long as there’s consistency and a clear process of justify-
ing, verifying, and reviewing the program.
Including a Color-Coding Plan as Part
of the Food Safety Plan
The format of the color-coding plan
can be similar to a typical food safety
plan, so it requires the same standard
steps to prove its efficacy. Let’s consider a
critical step within a standard food safety
plan, where soy and wheat are used to-
gether while preventing cross-contact in
the main supply of each allergen product
The Material or Step is adding soy leci-
thin to wheat flour.
The Hazard is a chemical, and more
specifically, allergen cross-contact between wheat and soy supplies.
The Control Type used is allergen control through product handling and personnel practices and sanitation control
by cleaning lines between changeovers.
As a justification, color-coding can also
be used because of its role in preventing
As a Monitoring Action to ensure that
the color-coding plan is followed, the
supervisor ensures that trained operators
use blue scoops for handling wheat and
red scoops for handling soy.
If the scoops do get switched, the Corrective Action steps would likely be:
i) Stop production.
ii) Separate affected product from the
good batches and safely dispose of it.
iii) Thoroughly clean scoops and the af-
iv) Start production.
v) Document the action.
vi) Find the root cause and prevent fur-
ther cross-contact between allergens.
As part of the Verification Action, quality control can take allergen swabs before
production to check if surfaces are clean
and if the operators are following the appropriate procedures.
The color-coding plan is generally
reviewed annually or whenever there are
significant changes in sanitation, allergen
handling, and processing activities.
There are many benefits to using color-coding as a preventive control. It acts
as a visual cue—most people can identify
different colors. Moreover, colors are a
universal language in plants where workers can have different linguistic backgrounds. Color-coding is also relatively
inexpensive—it achieves a lot of visual
impact for less, while at the same time
promoting a culture of food safety among
Color-Coding as a