How to Clean and Sanitize Reusable Bakery Distribution Trays

Cleaning and sanitizing are two different steps. Cleaning removes soil: crumbs, flour, residue, and film. Sanitizing is a separate treatment applied to a cleaned surface, where the operation requires it, to reduce microorganisms. A tray washing workflow follows the same order every time (sort, clean, sanitize where required, dry, inspect, store), but the frequency, equipment, detergent, sanitizer, concentration, contact time, temperature, and rinse or dry steps come from your governing rules, your written food-safety program, and the labels and instructions of the products and machines you actually use. This article gives the structure; it does not supply a universal recipe.

Start With the Operation and the Governing Rules

Before writing a procedure, answer three questions.

1. Does food touch the tray directly? Unwrapped rolls or loaves on the tray floor make the tray a food-contact surface. Bagged bread on the tray puts the bag between food and tray. The level of cleaning and whether sanitizing is needed follow from that answer and from your food-safety program.

2. Which setting are you in?

• Food manufacturing. For facilities covered by 21 CFR Part 117, 21 CFR 117.35 requires that cleaning compounds and sanitizing agents “be free from undesirable microorganisms and must be safe and adequate under the conditions of use,” and that food-contact surfaces “be cleaned as frequently as necessary to protect against allergen cross-contact and against contamination of food.” It also requires that cleaned and sanitized portable equipment be stored “in a location and manner that protects food-contact surfaces from allergen cross-contact and from contamination.”
• Retail and foodservice. FDA’s Food Code 2026 is a model “offered for adoption” by state, local, tribal, territorial, and federal jurisdictions. Its provisions apply to a store through the code that store’s jurisdiction has adopted, which may be an earlier edition.
• Transportation. FDA’s sanitary transportation rule (21 CFR Part 1, Subpart O) applies to covered shippers, loaders, receivers, and carriers. Its definition of transportation operations in 21 CFR 1.904 excludes “activities associated with the transportation of food that is completely enclosed by a container except a food that requires temperature control for safety,” among other listed exceptions. The same section names “an open wooden basket or crate” as an example of a container for food not completely enclosed. Where the rule applies, 21 CFR 1.906 requires transportation equipment to be “adequately cleanable” and maintained in sanitary condition, and 21 CFR 1.908 requires covered carriers with sanitary responsibility under a written agreement to have written procedures that “Specify practices for cleaning, sanitizing if necessary, and inspecting vehicles and transportation equipment.” Falling outside this rule does not remove other facility or state obligations.

Three short scenarios show how the answers combine:

• A food plant covered by the applicable provisions of Part 117 puts unwrapped rolls directly on trays: the trays are food-contact surfaces, and which subparts apply depends on the plant’s activities and status.
• A retail store displays bagged bread from trays: the store’s adopted retail code and its own procedures apply.
• A carrier moves bread in vented bags or open trays: the transport rule can apply, because the food is not completely enclosed; the same bread fully sealed and not needing temperature control falls outside the rule’s definition of transportation operations, but other obligations remain.

3. What does your written program say? The facility’s food-safety plan, sanitation procedures, and customer requirements turn these rules into specific steps. The workflow below is a template to fit into that program.

Process Flow With Control Points

RETURNED TRAYS
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   v
[1] PRE-SORT AND INSPECT ----- CP1: visibly damaged trays removed to hold area
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   v
[2] SOIL REMOVAL ------------- CP2: loose debris and residue removed
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   v
[3] WASH (manual or machine) - CP3: approved detergent, method per label and washer instructions
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   v
[4] RINSE (as required) ------ CP4: no detergent residue
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   v
[5] SANITIZE (where required)  CP5: approved sanitizer verified for concentration, contact time,
   |                                temperature, and compatibility with the tray
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[5a] POST-SANITIZER DECISION -- per the product label and site procedure:
   |                            drain and air-dry without rinsing, OR rinse only if the label requires it
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[6] DRY TO RELEASE CONDITION - CP6: dry as your procedure defines it; thoroughly dry where required
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   v
[7] RELEASE INSPECTION ------- CP7: pass, rewash, or hold
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   v
CLEAN STORAGE (separate from dirty flow)

Pre-Sort and Inspect

• Knock out or scrape off food residue at a station away from the clean area.
• Pull any tray with cracks, broken edges, or missing structural features and send it to a hold area. Cleaning does not restore damage, and the decision to keep or retire a damaged tray belongs to the damaged-tray decision process.
• Keep dirty and clean flows physically apart, with separate carts or racks and a one-way path.

Clean

• Soil removal first. A pre-rinse or dry scrape where the procedure calls for it.
• Detergent. Use a detergent approved for the surface and the operation, at the dilution and temperature on its label.
• Wash method. Brushing, soaking, spraying, or a tray washer, as your procedure specifies. Pay attention to corners, ribs, drain holes, and handle pockets, where soil collects.
• Residue removal. Rinse when the detergent label or procedure requires it, so the sanitizer is applied to a clean, residue-free surface.

Sanitize When Required

Selecting a sanitizer is a documented decision, not a habit. For each sanitizer, confirm and record:

• that it is approved for the intended use and surface under the rules that apply to you;
• the concentration, checked with the test method the label or supplier specifies;
• the contact time stated on the label;
• the temperature range stated on the label or in the procedure;
• compatibility with the tray material, from the tray manufacturer or the chemical supplier;
• whether a rinse or drain is required afterward, per the label.

Do not copy concentrations or times from another facility or from a generic chart. The label of the product you use, and your approved procedure, set them.

Dry, Store, and Release

• Dry trays to the release condition your procedure defines. “No pooled water” is a minimum, not a release standard. In facilities covered by Part 117, 21 CFR 117.35(d)(1) states that surfaces used for low-moisture food “must be in a clean, dry, sanitary condition before use” and that, when wet-cleaned, they “must, when necessary, be sanitized and thoroughly dried before subsequent use.” Stacking or nesting wet trays can trap moisture between them.
• Where allergens are handled, include allergen-control verification in the site procedure; a visually clean tray is not by itself evidence that allergen controls worked.
• Store cleaned trays off the floor or in a designated clean area, protected from splash, dust, and traffic.
• Release each batch with a pass/fail inspection: visibly clean, no residue, no odor, dry, undamaged.

Manual Versus Automated Washers

Cycle settings for a washer come from its manufacturer and your validation, not from this table.

Customizable Log Template

Fill the “approved parameters” for your site into the procedure that sits beside this log, and record measured values in the log itself. Where your program requires allergen control, add four columns: previous product or allergen class, cleaning method, the verification method your site has approved, and the result with any reclean. Cleaning removes soil and allergen residue; sanitizing reduces microorganisms. One does not stand in for the other.

Troubleshooting

• Residual soil after washing. Check soil removal before washing, wash coverage of corners and ribs, and detergent dilution.
• Chemical odor on dry trays. Check rinse requirements on the label, dosing, and drain time.
• Scratched or roughened surfaces. Rough areas can hold soil. Check for abrasive tools and route heavily scored trays to inspection.
• Incomplete drying. Check stacking during drying, airflow, and whether drain holes are blocked.
• Incorrect segregation. Clean trays found in the dirty area, or the reverse, mean the flow layout or training needs correction; rewash any tray that may have been recontaminated.

Food-contact suitability of the tray material itself is a separate evidence question, covered in what makes a reusable plastic tray suitable for food contact.

Approving Your Own Parameters

Use the flow, control points, and log as a frame, then fill in each parameter from the label of the chemical you use, the tray and washer instructions, and the rules that apply to your operation, and have the person responsible for your food-safety program approve them. A procedure becomes yours when each blank has a documented source and a recorded check.