Food-Grade Container Audit: FSMA 204 Checklist for Multi-Plant Processors
Auditors check containers, not just product records. Use this checklist to prove every bin in every plant is food-grade, clean and traceable.
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TL;DR: A container audit for multi-plant food processors should prove four things for every bin: the resin is FDA-compliant for food contact (21 CFR 177.1520 for HDPE), each container is identified, it has a cleaning and inspection log, and damaged units are retired on record. Keep the same checklist in every plant so FSMA 204 traceability records match. LT Plastics, an authorized Bonar Plastics distributor based in Phoenix, AZ, supplies these containers and speed bumps to US plants and distribution centers.
Quick Facts
| Audit item | Evidence to keep | Frequency |
|---|---|---|
| Food-contact resin | Supplier resin compliance statement | Per purchase lot |
| Container ID | Serial number or color plus number | At receipt |
| Cleaning | Sanitation log by container or batch | Each cycle |
| Inspection | Cracks, gouges, worn drains | Each cycle or weekly |
| Retirement | Damage record and disposal date | When removed |
| Lot linking | Container ID tied to lot code | Each use for FTL foods |
Why Container Records Fail Audits
Most plants can show product records but cannot show which container held which lot, or that a cracked bin was removed. Across several plants, each site keeps records differently and the gap shows up at audit. Start with our food-grade packaging requirements guide.
The Container-Level Checklist
1. Resin compliance on file
Ask the supplier for a written statement that the HDPE complies with 21 CFR 177.1520. File it by purchase lot.
2. Every container identified
Mark each bin with a number. Color coding separates raw, cooked and waste product.
3. Cleaning and inspection logs
Log each wash cycle and inspect for cracks and deep scratches that can hold bacteria. See FDA and food safety topic hub.
4. Retirement records
Remove damaged units, record the date and reason, and keep the record with the container ID.
5. Link containers to lots
For foods on the FDA Food Traceability List, tie the container ID to the lot code at each critical tracking event. Read FSMA 204 traceability for container fleets.
FAQ
Does FSMA 204 require container serial numbers?
FSMA 204 requires traceability lot codes and key data elements. Container IDs are not named, but they make lot linking much easier to prove.
What makes a plastic container food-grade?
Resin that complies with FDA food-contact rules, such as 21 CFR 177.1520 for HDPE, and a surface that can be cleaned and inspected.
How often should food containers be inspected?
Every cleaning cycle in high-risk areas, and at least on a set schedule elsewhere. Remove cracked or gouged units.
Sources
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Part of the topic guide
FDA Food Grade Containers and Food Safety Compliance