On 13 July 2026, FDA renewed its call for stronger ingredient and supply-chain oversight in infant formula. The equipment-project implication is clear: packaging cannot correct an unacceptable ingredient, and neither visual cleanliness nor a single finished-product test establishes hygienic safety. At the time of this review, FDA's January 2025 sanitation guidance for low-moisture ready-to-eat foods remains labelled as a draft; it must not be described as a newly effective mandatory rule.
Existing 21 CFR 117.35 requires food-contact surfaces used for low-moisture foods to be clean, dry and sanitary before use. Following wet cleaning, they must be sanitized when necessary and thoroughly dried. The FDA draft also distinguishes cleaning from sanitizing: dry residue removal alone is not adequate remediation following pathogen contamination. The following are DOT's project-engineering recommendations, subject to approval by the customer's food-safety team. Infant formula has additional product-specific regulatory requirements; these must not be applied indiscriminately to all nutrition powders.
Hygienic changeover should extend from bag tipping, sieving, conveying, buffer hoppers and auger dosing to filling nozzles and the sealing area. The URS should map product-contact routes, disassembly boundaries and inspection points. Reviews should examine the backs of seals, folds in flexible connections, auger roots and valve cavities. Consistent with the cleanability requirements in 21 CFR 117.40, installation must also allow cleaning and maintenance of adjacent spaces. A polished surface is no substitute for access to hidden locations.
Routine residue removal, allergen changeover and pathogen-contamination response need separate procedures. DOT recommends evaluating controlled dry cleaning suited to the product and equipment. Removable parts requiring wet cleaning can be handled in a segregated area and returned only after drying confirmation and protection from recontamination. If clean-in-place is selected for the installed equipment, coverage, drainage, drying and reassembly risks should be addressed during design. Wet cleaning should not be added informally to a dry-processing machine without assessment.
The line concept must also define material and data boundaries. Changeover checks should cover upstream residues, recovered powder, dust-extraction interfaces, containers in transit and downstream unsealed packs, with clear responsibilities for segregation, line clearance and disposition. The HMI can provide authorized steps for cleaning completion, component reinstatement, recipe selection and first-off approval, linked to ingredient lots, operators and timestamps. An electronic confirmation does not replace physical inspection, and the equipment supplier cannot release production on behalf of the customer's quality function.
FAT should use a representative, difficult-to-remove formulation or an approved surrogate. Record the time required for disassembly, cleaning, inspection, drying and reassembly, and verify access to challenging locations and correct seal reinstatement. SAT should confirm performance with the factory's personnel, environment and sanitation procedures. Residue-test methods, sampling locations and acceptance criteria should be agreed in advance. Actual pathogens must not be introduced into routine equipment trials; microbiological studies belong with appropriately qualified specialist facilities.
Restart acceptance must go beyond running an empty machine. Confirm lane-by-lane weight, dust release during filling, powder entrapment in seals, checkweigher rejection and batch linkage, while recording losses before the first conforming output. DOT recommends evaluating changeover time alongside residue results, start-up rejects and unplanned downtime, supported by seal spares, illustrated disassembly instructions and a field-service response plan. The objective is repeatable hygienic operation that protects product and stable output—not a shorter cleaning time purchased at the cost of hidden risk.