How much work you have to do to clean up after you prepare a meal at home depends on how many people you served. The more people you served, the more dishes you have to wash, generally speaking. You may only need to load a couple of dishes into your dishwasher, or you may need to roll up your sleeves and spend some time scrubbing pots and pans at your sink. Now, consider how much work it takes to clean up for the average food manufacturing or packaging facility, which produces enough food to serve hundreds, if not thousands, of people every day. Cleaning up at the end of the day for these manufacturers and packagers is more involved than running a dishwasher or getting out the sponges and brushes.
Sanitizing food manufacturing equipment is a much bigger responsibility than washing up after preparing a meal at home, as well. That’s because manufacturers and packagers have an enormous responsibility to keep their equipment clean. The potential for foodborne illnesses is something that all manufacturers and packagers need to guard against at all times. Meaning, they must follow strict food safety protocols that include cleaning and sanitizing all equipment every night. This is essential not only because it keeps them compliant with food safety regulations, but also because consumers put their faith and trust in them. An outbreak of foodborne illnesses that originates at one of these manufacturers or packagers means that trust is violated, resulting in severe consequences beyond the legal repercussions they may suffer. For these companies, keeping their equipment clean is more than a matter of good hygiene — it’s also good business.
Food manufacturers and packagers must follow a detailed, complicated series of steps to ensure that every component and element of their equipment will be safe to use in the next day’s production cycle. However, because of the complexity of the process, it can be difficult for employees to adhere to the process every time. Sometimes, certain steps may be forgotten or overlooked, which is why it’s necessary to keep a reminder of the proper protocols around at all times.
The following checklist details all of the necessary steps food manufacturers and packagers should follow to stay in compliance with food safety requirements. The responsibility they have is immense, so there’s no margin for error.
As much as food manufacturers take precautions to avoid all types of contaminants, there can still come a moment when you realize that your best efforts have failed. Maybe you find a broken blade or a missing wire during a sanitation break, but the product has already gone through your inline inspection machines—and nothing was detected.
This is the freak-out moment that no plant manager or quality assurance manager wants to have. Knowing that there’s possible contamination of your food product (and not knowing where that contaminant might be) creates a hailstorm of possibilities that your plant works hard to avoid. And you’re probably wondering how this could have happened in the first place.
Understanding How Contaminants Get Past Detection
To prevent physical contamination from occurring, it’s important to understand the reasons why it happens. In-house inspection systems often fail to detect contaminants for the following reasons:
The equipment isn’t calibrated to detect contaminants to a small enough degree, or the contaminants are materials that aren’t easily detected by the in-house machinery (glass, rubber, plastic, etc.)
The machines aren’t constantly monitored
The speed of the production line doesn’t allow for detecting small particles
Metal detectors are the most commonly used inline inspection devices in food manufacturing, and they depend on an interference in the signal to indicate there is metal contamination in the product.
Despite the fact that technology has progressed to deliver fewer false positives, the machines can still be deceived by moisture, high salt contents and dense products that could provide interference in the signal. When that continues to occur, it’s common for manufacturers to recalibrate the machine to get fewer false positives—but that also decreases its effectiveness.
Another limitation of the metal detector is that, as the name indicates, it can only find metal. That means contaminants like plastic, glass, rubber and bone won’t be found through a metal detector, but will hopefully be discovered through some other means before the product is shipped out.
Oftentimes, contamination or suspected physical contamination is discovered when a product, such as cheese or yogurt, goes through a filtration system, or when a piece of machinery is inspected during a sanitation break.
If the machinery is found to be missing a part, such as a bolt or a rubber gasket, the manufacturer then has to backtrack to the machinery’s last inspection and determine how much, if any, of the product manufactured during that time has been contaminated.
What To Do When Contamination Occurs
Once a food manufacturer discovers that it may have a physical contamination problem, it must make a decision on how to handle the situation. Options come down to four basic choices, each of which comes with its own risks and benefits.
Option 1: Dispose of the full production run
The one advantage of disposing of a full production run is that it entirely eliminates the possibility of the contaminated product reaching consumers.
However, this is an expensive solution, as the manufacturer has to pay for the cost of disposal in a certified landfill and absorbs the cost of packaging, labor and ingredients. It also presents the risk of lost revenue by having a product temporarily out of stock.
Option 2: Shut down your production lines for re-inspection/re-work
Running the product through inline inspections a second time may result in finding the physical contaminant, but there’s also a risk that the contaminant won’t be found—and now the company has lost money through overtime pay and lost productivity.
If the inspection equipment was not sensitive enough to find the contaminant the first time around, it may not find it the second time, which puts the manufacturer back at square one. The advantage to this method is that the manufacturer maintains complete accountability and control over the process, although it may not yield the desired results.
Option 3: Risk it and ship the product to retailers
There’s always a chance that a missing bolt didn’t make its way into the product. Sometimes, if a metal detector goes off and the manufacturer can’t find any contaminants upon closer examination, they will choose to ship the product and take their chances.
The advantage for them is that, on the front end, this is the least expensive option—or it could be the costliest choice of all if a consumer finds a physical contaminant in their food. In fact, the average cost of a food recall is estimated at $10 million; lawsuits may push that cost even higher and result in a business being closed for good.
Option 4: Use third-party X-ray inspection
X-ray inspection is the most effective way to find physical contaminants. In addition to metal, X-ray systems can find glass, plastic, stone, bone, rubber/gasket material, product clumps, container defects, wood and missing components at 0.8 mm or smaller.
When a food manufacturer has a contamination issue, it can have the bracketed product inspected by a third-party X-ray inspection company and only dispose the affected food, allowing the rest of the product to be distributed. This option allows the manufacturer to maintain inventory and keep food deliveries on schedule while still eliminating the problem of contamination.
X-ray inspection can find what other forms of inspection cannot, because it’s based on the density of the product, as well as the density of the physical contaminant. When X-ray beams are directed through a food product, the rays lose some of their energy, but will lose even more energy in areas that have a physical contaminant. So when those images are interpreted on a monitor, the areas that have a physical contaminant in them will show up as a darker shade of gray.
This allows the workers monitoring machines to immediately identify any foreign particles that are in the food, regardless of the type of material.
Detection is Key to Avoiding Contamination Issues
Handling contamination properly is vital to every food manufacturing company. It affects the bottom line and the future of the company, and just one case of a physical contaminant reaching the consumer is enough to sideline food companies of any size. As X-ray technology continues to evolve, it remains an effective and efficient form of food inspection.
Educating plant managers and quality managers on what to do if inline inspection machines fail to detect contaminants should include information on how X-ray technology can be a food company’s first line of defense. While physical contaminants can’t always be avoided, they can be detected—and the future of your company may depend on it.
Preparation is the key to success for any ongoing endeavor. In an industry where your enemies are fighting for survival at the expense of your business, you must be ready for anything. Your opponents are crafty, adaptable and more prevalent than you think.
No, I’m not describing your competitors. I’m talking about pests—a major threat to the integrity of food products and a threat to any facility’s bottom line. Whether it’s stored product pests contaminating inventory or rodents spreading pathogens as they skitter across equipment, pests are a risk that should be minimized.
With FSMA in full effect, preparation is more important than ever. FSMA mandates a proactive approach to food safety, and by extension, pest management. It’s important that the pest management program is exhaustive and integrates seamlessly into the overarching food safety plan.
Most, if not all, food processing facilities currently use an integrated pest management (IPM) program to help minimize the chance of pest problems, but FSMA puts more emphasis on being proactive to keep pests far from products at all times. Naturally, this doesn’t mean that a pest sighting in a facility is the end of the world, but it means that it should be resolved quickly, investigated and documented to help prevent such an occurrence from happening again.
Specifically, FSMA has numerous stipulations that trickle down to pest management.
Hazard analysis. First, a comprehensive inspection should be done to identify the high-risk areas in your facility where pests may take residence. Entry points, potential food and water sources and harborage areas should all be noted.
Preventive controls. Include regular facility maintenance reviews and a strict sanitation regimen in your food safety plan to help minimize the use of chemical pest management treatments.
Monitoring. Use devices and employees to keep tabs on pest activity and conducive conditions to ensure preventive controls are working and executed across the facility.
Corrective actions. Implement and enforce pest management solutions such as exclusion strategies (e.g., weather-stripping, door sweeps, vinyl strip doors), traps (e.g. pheromone traps, insect light traps, bait boxes), air curtains and repellants to help manage pest activity.
Verification. Schedule regular service visits with your pest management professional to verify corrective actions are working to reduce pest problems over time. These visits should include an annual facility assessment and pest trend analysis, both of which help determine potential areas of improvement over time.
6. Record keeping and documentation. Document every action taken to prevent pests. That includes corrective actions and their results to prove that your written IPM and food safety plan has been implemented and is effective in helping to manage pests at the facility.
With these key components accounted for, it will be easier to be prepared for pests. But, even still, the real-world implementation of these tactics might not be abundantly clear. That being the case, let’s take a look at what food processing facility managers can start doing today to help protect their facilities and demonstrate a proactive approach to food safety.
So, what’s the best way to be more proactive in preventing pests?
Well, that question has a plethora of possible answers, but four of the most important are sanitation, exclusion, staff training and monitoring.
Perhaps the most important of all, sanitation helps to eliminate two key attractants—food and water—that draw pests inside a facility. Any spot where food particles or moisture is collecting, pests will be looking to find.
But sanitation shouldn’t seem daunting. Here are some actions you can start doing today to step up your sanitation program:
Wipe down equipment regularly to break down the buildup of organic materials.
Wipe off countertops and sweep floors in common areas where food is present, then sanitize with an organic cleaner afterwards to eliminate any remaining odors.
Take out the garbage at least daily, and keep dumpsters at least 50 feet away from the building to avoid giving pests a harborage location nearby with an easy path to get indoors. Make sure to cleanse garbage bins and dumpsters regularly, or they’ll become attractive to pests, too!
A big part of preventing pests from getting inside a facility is simply blocking them out using exclusion.
During an inspection, a pest management provider will walk around the interior and exterior of the facility and look for any potential entry points for pests. They should recommend you seal any cracks and crevices they notice, as many pests can fit through extremely tiny gaps. For example, mice can fit through a hole the size of a dime. Gaps should be sealed with a water-resistant sealant to keep pests and moisture out.
In addition, make sure to keep windows and doors closed as much as possible or use screens to block pests. Automatic doors can help in this way, especially when paired with an air curtain to blow flying pests away from entrances. Pests can often come in through the biggest gap of all: The front door!
It’s always better to have a team behind you. Training employees on the basics of an IPM program and what they can do to help will take some of the weight off your shoulders.
Many pest management providers offer free staff training sessions, which can help employees understand what to look for around their work areas and what to do in the case of a pest sighting. Consider creating your own pest sighting protocol to make it clear what employees should do if and when a pest is spotted. They’ll need to record when, where, how many and what kind of pest(s) were seen at the time to give your pest management provider the best chance to create a customized solution to resolve the issue. If you can catch one of the pests in a container for future identification, that’s even better.
While employees can help by keeping an eye out for pests, it’s important to have ongoing monitoring techniques to measure pest activity around the facility.
Monitoring devices are a great way to do this, and your pest management professional can help you place them strategically around the hot spots in your facility. Fly lights, bait stations, pheromone traps and more can capture pests and serve a dual purpose. First, they’ll reduce pest populations around the facility, and, second, they’ll allow you and your pest management provider to see how many pests are present in certain areas.
Over time, this will give you a feel for which pest issues have been resolved and which continue to be a problem. That can determine the corrective actions taken and the long-term food safety plan, which will demonstrate a commitment to constant improvement. That’s a great thing to have on your side, especially when an auditor happens to stop by.
I know, I know—this wasn’t one of the four “answers” listed, but it’s still incredibly important! Documentation helps ensure you get credit for being so prepared.
It’s recommended that facility managers keep a few documents on hand to keep things simple. The food safety plan, annual assessments, sighting reports, a list of service changes over time, a list of monitoring devices and proof of your pest management professional’s certification are all important documents to keep updated and ready to go. That way, you can rest easy knowing you’re prepared at a moment’s notice.
It is never too early to start preparing. Pests aren’t going to stop searching for a food source anytime soon, so don’t stop your proactive efforts to keep them at bay. Your financial department will thank you.
Sanitation in a food processing plant is a large-scale effort that many organizations see as an added cost of doing business. Yet, it’s essential and can have costly consequences if done improperly.
Because time is money and facilities want to avoid any necessary downtime, the window for completing proper sanitation procedures is small. Many food processors simply put more people on the job while requiring them to work third shift, hoping to get things done faster.
Automating certain sanitation procedures in your plant can provide real benefits, many of which will help reduce the costs associated with food safety and keeping your facility clean. Here’s a look at the three main ways food plants can save by implementing automated sanitation solutions.
1. Resource Management
When you invest in sanitation automation, one of the biggest advantages is the increased understanding of how resources are being used. This knowledge and improved visibility gives you control of how resources such as water and chemicals are used during sanitation.
Perhaps the most significant area in which facilities experience savings is through reduction of water usage. Automated solutions improve the efficiency of rinse cycles while ensuring appropriate water pressure is being used. Every plant has unique water needs, but you should expect water savings between 30% and 50%, depending on the solutions that are applied.
Sanitation automation will also lead to a reduction in energy costs. Using less water means less energy is required to heat that water. Advancements in sanitation technology have made certain solutions more energy efficient. Features such as multi-stage pumps for full alternation, motors that allow pumps to ramp up and down as needed, and flow switches that send pumps into “hibernate” mode help reduce electricity usage.
Waste water from food processing also needs to be treated before it goes down the drain. Less water treatment means fewer chemicals are needed.
Food processors that introduce automated sanitation solutions will use cleaning chemicals more efficiently. Automation ensures chemicals are dispensed precisely where they are needed at the correct concentration, without any over spray. Again, while every situation is unique, most facilities can expect a 20–30% reduction in chemistry costs.
In the end, you will have a very clear picture of the amount of water and chemistry needed to complete sanitation, and you’ll know the amount of time it should take. That means you can plan for more uptime.
Overall, not only can automation help food processors make efficient use of resources, it also makes them more sustainable.
2. Labor Costs
Labor is yet another resource that can be more effectively managed when there’s an investment in sanitation automation. The labor market is tight, and it is becoming increasingly difficult to hire the people needed to carry out sanitation work.
Sanitation often involves menial and tedious tasks that also require attention to detail. It usually entails working overnight when production stops, and certain responsibilities can be dangerous. At the same time, minimum wage is rising, and many organizations are looking to reduce labor costs.
Introducing sanitation automation can certainly cut labor expenses and remove the need to hire more people, but more importantly, it can make the workers you do have more productive. Automation should be used to eliminate menial tasks from sanitation workers. For example, instead of a person standing in front of a conveyor belt and spraying it down with a hose for hours on end, the job could be easily automated.
We worked with a brewer who was having two employees take as long as three hours to clean a filler. By automating that task, they turned it into a 45-minute job and allowed those employees to refocus their efforts. Plus, the before and after pictures of the equipment show a visible difference in cleanliness.
You can trust an automation solution to do a consistent job, and it will never call in sick.
Still, you’ll always need to have “boots on the ground” and human eyes evaluating sanitation. Automating certain sanitation practices will free up employees to work on more important duties that add value and keep them engaged in their work.
3. Mitigating Safety Risks
The most important thing sanitation automation provides is more peace of mind. No one wants to lose sleep worrying about a failed inspection or the potential for a worker injury. Automation reduces the risk of product contamination and lessens potentially dangerous situations for employees.
For instance, spiral freezers are particularly precarious areas to clean. Automating its cleaning process eliminates the need for a worker to maneuver through an unsafe space, reducing the likelihood of a workplace injury.
Human labor can also lead to human error. But, when sanitation tasks are automated, they become more consistent and easily repeatable. This is especially important for cleaning hard-to-reach problem spots that become harborage areas for bacteria. There may be a tendency among human workers to skip areas they can’t reach, or fail to clean them properly, but a machine cleans everything the same every time.
The monetary risk of contamination inside your facility is significant. For example, if Listeria were to take up residence in a plant, it could cost your business millions of dollars.
According to a study from the Food Marketing Institute and Grocery Manufacturers Association, the average food product recall will have direct costs of $10 million while indirect costs could reach into the hundreds of millions. That’s because you also need to consider the ongoing cost of a damaged brand reputation, not to mention lost productivity from business interruptions and lost profits from disposing of potentially contaminated product.
Sanitation Automation: The Future is Now
There are many reasons to start implementing automation into your food and beverage plant’s sanitation practices. Food processors in Europe have been quicker to adopt these solutions because many of the same issues U.S. manufacturers face, such as wages and resource scarcity, can be even more pronounced overseas.
As the labor market in the United States presents challenges for hiring managers, and drought conditions in some regions make water a scarce commodity, automation presents an opportunity to bring your facility into the future. Add to those concerns the increased regulations from FSMA, and there is even more reason to invest in dependable sanitation solutions.
Food processors need to find trusted advisors who can evaluate operations inside the plant and look for ways to implement automation in ways that make the largest impact.
While there is certainly an upfront cost in automating sanitation, the potential savings and added visibility these solutions provide won’t take long to pay for themselves. In most cases, facilities that invest in sanitation automation will see a return within a year to 18 months. If done properly, you can achieve impressive cost-saving results through automation.
Rose Acre Farms has voluntarily recalled eggs from its farm in Hyde County, North Carolina following an investigation by FDA, CDC and other agencies involving Salmonella illnesses. FDA testing determined that eggs produced from this farm are connected to 22 cases of Salmonella Braenderup infections; the CDC is confirming illness information with state health departments.
The exact amount of eggs recalled totals 206,749,248.
The eggs are sold under several brand names, including Coburn Farms, Country Daybreak, Food Lion, Glenview, Great Value, Nelms, and Sunshine Farms, as well as restaurants.
FDA is advising restaurants and retailers that they should not sell or use any recalled shell eggs. In addition, they should take measures to avoid cross-contamination of the food processing environment and equipment by washing and sanitizing display cases and refrigerators regularly, washing and sanitizing cutting boards, surfaces and utensils, and washing hands with hot water and soap after any cleaning or sanitation process. Consumers are advised not to eat the recalled eggs.
Keeping your food processing facility clean is actually even more important than the food itself. What steps can you take to help keep your food processing facility clean?
1. Cultivate a Clean Culture
Keeping your facility clean is more than just your job. It’s the job of everyone who walks through your doors, whether they work on the factory floor or in the offices. Your first step should be to cultivate a clean culture. Get everyone involved, from the newest hire all the way up to the CEO. Everyone should have their assigned job, but they should also feel comfortable speaking to their supervisors or upper management to report spills, possible contamination and other cleanliness problems.
When you have human employees involved in the production process, there is always a chance the product can become contaminated. Personal hygiene can help to reduce the chances of contamination by keeping your employees clean and safe as well.
Hand washing, for example, is a step that is often neglected but can mean the difference between a clean batch of food and a contaminated one. Good hand washing procedures can also help reduce the spread of cold and flu germs inside the workplace.
Personal protective equipment also falls into this category—gloves, hair and beard nets, shoe booties and other coverings should all be worn to lessen the possibility of contamination.
3. Keep Up With Your Equipment
The exact equipment you need to complete your work will vary depending on the type of food you’re processing, but for most foods that start with raw ingredients, you will need some sort of sifting equipment. These are designed to remove under- and oddly-sized food items or to remove dirt, leaves or other debris that might have come in contact with the food from the field where it was harvested.
Most sifting equipment relies on vibrating or moving sifters that can throw small particles into the air. While necessary, this also creates a new potential source of contamination for your food items. Investing in sifting equipment with a dust hood can help solve this problem. Not only do dust hoods keep your product and facility cleaner, machines with dust hoods reduce air pollution too.
4. Food Storage and Temperature
Food production facilities are at the mercy of temperature. Food that is allowed to get too warm can grow bacteria, making it dangerous to consume. Food that is left for extended periods of time at temperatures between 41 and 135 degrees Fahrenheit are also at risk for bacterial and microorganism growth.
Be vigilant about the temperature at which your food is stored. Food that needs to stay hot is required to be kept at 140 degrees or above, and cold food needs to be kept below 41 degrees.
5. Clean, Clean and Clean Again
Keeping all of your equipment clean and sanitized is an essential step in the maintenance of your food processing facility, but many pieces of equipment are not designed to be disassembled and sanitized separately. This may be tricky when there are cracks and crevices where food particles can get stuck, encouraging bacteria growth. You have two options for cleaning your equipment—clean in place and clean out of place.
Cleaning in place, as its name suggests, involves cleaning your equipment without taking it apart. This includes running sanitizing chemicals through the equipment and cleaning all accessible surfaces.
Cleaning out of place requires shutting down the equipment and disassembling it, allowing you to clean and sanitize all of those hard-to-reach corners. Depending on the piece of equipment, this may require shutting down your entire production line, so be sure that cleaning out of place won’t impact your production deadlines.
6. Cut the Clutter
Clutter in a workspace, even if it’s just boxes of product waiting to be palletized, can contribute to an unclean and unsafe work environment. Clutter allows the collection of dust, which can make its way into both food and equipment.
Take the time to dedicate specific areas to storage, preferably away from the primary production line. Keep your main traffic routes clear to prevent on-the-job accidents and ensure that anything kept in overhead storage is stable with no risk of falling.
7. Keep Covers and Guardrails In Place and Maintained
Open tanks or containers that process food are prone to contamination and are difficult to keep clean. Any tanks or containers that have covers on them should be covered at all times to ensure the product is kept clean.
For places where guardrails are necessary, such as above production lines or other elevated walkways, confirm that the rails provide coverage on all exposed sides. Make sure that there is also no risk of any dirt or other contaminants from shoes or the walkways falling into food or onto the production line.
A dirty production line can cost you thousands of dollars to correct, costing even more if the contaminated product has to be discarded. Take the time to maintain your cleanliness and keep your facility running smoothly.
Earlier this week the USDA’s FSIS proposed to amend inspection regulations, modernizing food safety inspection systems, in an effort to make egg products safer. It would require official plants that process egg products to develop HACCP systems, sanitation standard operating procedures and meet sanitation requirements consistent with meat and poultry regulations.
“FSIS is proposing that official plants will be required to produce egg products in such a way that the finished product is free of detectable pathogens,” according to a USDA news release. “The regulatory amendment also uses agency’s resources more efficiently and removes unnecessary regulatory obstacles to innovation.”
FSIS will also be taking over jurisdiction of egg substitutes.
According to the agency, the financial impact of the proposed rule could be minimal, as it states 93% of egg products plants already have a written HACCP plan that deals with at least one production step in the process.
Once published in the Federal Register, a 120-comment period will go into effect.
FDA’s Office of Regulatory Affairs has released the most frequently cited inspectional observations for fiscal year 2017. Among the items on the spreadsheet are food safety hazards, failure to clean, sanitation records, corrective action plan, and lack of sanitation.
“These observations, are listed on an FDA Form 483 when, in an investigator’s judgment, the observed conditions or practices indicate that an FDA-regulated product may be in violation of FDA’s requirements.” – FDA
The following are the top five (most frequent) observations.
5. Contamination: Cleaning and sanitizing operations for utensils and equipment not conducted in a manner that protects against contamination of food, food contact surfaces and food packaging materials.
4. Failure to implement HACCP plan procedures.
3. Facility not constructed in a way that enables floors, walls and ceilings to be adequately cleaned; buildings, fixtures and other physical facilities not kept in sanitary condition.
2. Sanitation monitoring: Sanitation conditions and practices not monitored with enough frequency to be in conformance with CGMP.
1. Pests: Lack of effective pest exclusion from processing areas and contamination of foods, and failure to provide adequate screen against pests.
The food industry has been one of the most celebrated and fastest-growing industries over the last decade or so. Which is no surprise, considering how much food is now being consumed, or posted on Instagram, on a daily basis. Pop-up food carts and hole-in-the-wall food places have been a huge hit too and even inspired a number of Hollywood films about the tough competition and revolutionary marketing tactics that have taken over the food industry (see: Jon Favreau’s Chef and Bradley Cooper’s Burnt). It’s good times, for sure. Well, for the most part, I mean.
When did foodborne illness become a major concern in the US?
Unfortunately, it’s not just the revenue that’s on the rise, because food borne illnesses too are making the headlines as of late. Talk about spoiling (no pun intended) the fun, eh? Well, according to the US Centers for Disease Control and Prevention (CDC) in Atlanta, Georgia, the number of foodborne disease outbreaks resulting from imported foods increased during surveillance years 2005 to 2010.
Where are the numbers coming from?
Dr. L. Hannah Gould, Ph.D., a senior epidemiologist at the CDC, revealed those findings during an oral presentation here at the International Conference on Emerging Infectious Diseases in 2012. According to the CDC, 39 foodborne disease outbreaks were reported in which the implicated food had been imported into the United States. These outbreaks resulted in 2348 illnesses, 434 hospitalizations and 3 deaths.
How many are affected?
Though foodborne illnesses are often never formally reported, about 48 million Americans, or one in six, get sick each year from food, the CDC estimates, with 128,000 hospitalizations and 3,000 deaths. In fact, in 2014, 19,542 cases of infection were traced from 15% of the US population being surveyed by CDC.
Why is it on the rise?
The culprits? Chances are, you’ve been storing them somewhere inside your establishment: packaged caramel-coated apples, frozen ice cream sandwiches, fresh peaches and nectarines, frozen meet, etc. Not exactly the answers you were expecting, perhaps?
According to experts, the growing popularity of packaged foods such as pre-cut fruit and prepared sandwiches has heightened the risk of spreading foodborne illnesses. Furthermore, they have identified that contamination can occur between preparation and packaging, or in high-tech processing plants, after heating to destroy harmful bacteria and before packaging. Which means, somewhere in the last decade, we lost our way (or something like that).
What can we do to stop foodborne disease from spreading?
The whole fiasco regarding foodborne illness is a public safety concern and must be addressed by everyone. However, while adjusting individually may not be a problem for most of us, the same cannot be said for food places and restaurants. Just imagine the public relations horror for restaurant managers if any of their customers get sick while dining at their place?
Restaurants must be more strict and thorough when addressing food safety concerns. The entire crew must be trained when it comes to food handling and a food safety manager must also take charge in overseeing procedures in the kitchen. In fact, proper storage and disposal must also be adequately done at all times. With those safety measures in play, establishments will be able to showcase their commitment to adhere with local food standards and basic food handling procedures. That’s a step in the right direction, for sure.
Summing up, foodborne illness is definitely a manageable concern and will likely not become a factor that will hinder the overall growth of the food industry. However, the fact that it can be controlled and yet still recurring means that there’s still a fair amount of work needed to be done to improve the industry in other aspects—and that isn’t necessarily a bad thing (at least not yet).
Proper sanitation plays a crucial role in the FSMA Preventive Controls rule, and FDA is paying more attention during facility inspections. However, many companies currently have deficient sanitation programs, according to Bill Bremer, principal at Kestrel Management, LLC. “It’s a key aspect of FSMA and requires that you have key personnel or a qualified sanitation manager either at each site or over each site (if it’s not local). That’s in FSMA,” he says. “In most cases, and for high-risk companies, sanitation must be supported by validated environmental testing programs (i.e., the typical swab-a-thons that FDA has done under FSMA). Sanitation chemicals that are used must be diligently approved for use and validated. In addition, chemicals must be appropriately applied, which is a big issue. These areas are key inspection points for FDA under FSMA, as well as for customer requirements. Sanitation has been elevated with FSMA and Preventive Controls, and it has to be addressed at a higher level—and for the most part, it isn’t.”
Bremer was invited by DNV-GL to discuss the importance of sanitation as a goal of FSMA in a Q&A with Food Safety Tech.
Food Safety Tech: Let’s first talk about the importance of a proper sanitation program. What are the factors at play here and what are the deficiencies with current sanitation programs?
Bill Bremer: We’re starting to conduct major sanitation program process improvements or process assessments for companies big and small. What we’re seeing in some of the key areas is that chemicals are not validated with the chemical provider. That includes the fit for use for them as well as the training of the people using them (i.e., if it’s liquid, it has to be diluted at right level and confirmed at right parts per billion).
Before you sanitize, you’re supposed to clean (in some cases it’s called debris removal). You can’t sanitize unless surfaces that are being sanitized are clean. We’re finding that cleaning isn’t done appropriately and thus companies are sanitizing over dirt, and you can’t sanitize over dirt or debris.
We’re also running into cases where the cleaning is done, and because it looks clean, a company is not sanitizing, so you run into another issue with those missed steps. And, this entire process needs to be validated and you must have records on it. You also have to support it with environmental programs, especially for high risk. So that means swabbing to make sure that once you clean and sanitize, you prove that the activities have ultimately removed any bacteria, germs or allergens from the process.
This is a high-profile area for FDA to inspect.
Some of the common deficiencies are with the program itself and the documented procedures to follow. It’s a weak area. Sometimes, a company will have different cleaning and sanitation programs documented (e.g., shift-by-shift or site-by-site), which leads to people who do the cleaning not following a standard set of instructions. It really gets down to both the programs and lack of qualified supervision and management of the cleaning and sanitation process.
Food Safety Tech: What methods should companies employ to meet FSMA requirements?
Bremer: This is an area where a diligent documentation program review is not always conducted. It’s assumed that we see the cleaning process—you see the foaming up of the cleaner, the sanitizer is all good—and we may see the cleaning record, but it’s not an SSOP, or standardized sanitation operating procedure.
However, when you look deeper and look at the documented programs, there very weak and unclear, and they need to be updated. That is one of the first things that we would investigate for a company. It’s also the qualification and training of the people—whether at the lower level or the management level, you have to be trained appropriately and the training has to be current.
Then we look at the physical process: Are they really doing debris removal in the cleaning process prior to sanitizing to make sure there’s no residue left for sanitation to be effective?
We also look at the environmental programs: Do they have a well-developed environmental program swab test? Are they using a third-party lab to validate their results? Today there are automatic test readers [that enable in-house] results. If you perform this in house, you need to have qualified people do it—and you should be checking those results with a third-party laboratory or service.
A proper sanitation program is an imperative. It’s an area where FDA is going to be investigating companies, even if they don’t have any record of products being recalled. If you look at the Blue Bell case, the big issue was that they didn’t do a good job of sanitizing their drains for Listeria, which got out of control and then it spread through the air system and to their suppliers, as well.
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