Food Safety Modernization Act: The Zone Concept

The produce safety rule requires the inspection, maintenance, cleaning and, when necessary and appropriate, sanitizing of all food contact surfaces on equipment and tools used during pre and post-harvest farm activities to protect against contamination of produce intended or likely to be eaten raw covered under the rule. 

Non-food contact surfaces tools and equipment must also be maintained and cleaned, when necessary, to prevent contamination of produce. The "Zone Concept" is a term used in the food industry to divide food packing and process operations into four zones based on the level of risk of contamination that each is exposed to.

Food contact surfaces, called Zone 1 surfaces, are at the highest risk for product  contamination while non-food-contact surfaces that are farthest from the product are designated Zone 4.

The use of the Zone Concept is highly recommended in order to better target cleaning and sanitation efforts in the packinghouse according to the risk they represent. Let's take a look at each zone that can be found in a packinghouse environment.

Zone 1

Zone 1 surfaces includes all food contact surfaces and utensils. These surfaces have contact or are exposed to produce during the farm's normal operations. Cleaning and sanitizing practices in Zone 1 surfaces should be a priority in order to reduce the risk of cross contamination. Examples of Zone 1 areas in the farm include:

• Conveyor Belts
• Rollers
• Brushes
• Table tops where produce is handled
• Workers' hands
• Reusable plastic containers and storage bins
• Sinks
• Knives
• Bucket elevators

Zone 2

Zone 2 includes surfaces which are not in direct contact with produce but are in close proximity or adjacent to food contact surfaces in packing areas. Although they were not designed to have contact with food, they can still become a source of contamination. These areas are immediately adjacent to Zone 1, and as such need to be cleaned and sanitized with a sufficient frequency to prevent them from becoming a source of cross contamination. Some examples of Zone 2 areas include:

• Outer parts of machines
• Framework
• Walkways
• Sidewalks
• Pumps and engines
• Chill units
• Tools and cart wheels
• Machinery control panels

Zone 3

Zone 3 includes Non-Food Contact Surfaces. Surfaces that under normal operating procedures do not contact surfaces of the food or container. These are the areas adjacent to Zone 2 such as floors, trash cans, and storage areas. Other zone 3 areas that can contribute to cross contamination if not properly cleaned include:

• Restrooms
• Storage areas
• Drains
• Catwalks

Zone 4

Zone 4 includes Non-Food Contact Surfaces in remote areas beyond the packing area. These are remote areas outside of the packing area that generally do not contribute to direct product contamination. Zone 4 areas include: 

• Hallways
• Restrooms and locker rooms
• Cafeteria and break room
• Offices
• Coolers, freezers, storage rooms
• Maintenance shop

Remember that cleaning and sanitizing are two very important activities that if conducted properly will help the farm to minimize the risk of product contamination. 

For more information, please visit the Penn State Extension FSMA section.

This program was developed by Food Safety CTS, LLC, for Penn State Extension. Supported by a USDA NIFA Food Safety Outreach Program grant titled "Bilingual Produce Safety Educational Programming for Hispanic/Latino Fresh Produce Growers and Farmworkers in Pennsylvania," USDA NIFA Award number 2017-70020-27236