From Feed Plant To Food Plant: What Will It Take?

Departments - Practical QA Solutions

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August 7, 2018
OLE DOSLAND, QA & Food Safety Consultant, Certified Instructional Designer/Professional Instructor

What does it take to transition an older feed or pet food (or people food) plant into a sanitary food plant?

Compliance with the Food Safety Modernization Act (FSMA) is being discussed in many board rooms, and some companies are facing this question for their pet food or small animal food production facilities which face new requirements under FSMA. A transition into a sanitary operation with higher food safety can be overwhelming and typically begins with some design concepts. Following are 10 concepts that will help facilities assure a higher level of food safety, provide better microbial control, and enable greater compliance with FSMA:

  1. Crossover microbial contamination of the primary microbial control area (PMCA):
    • Inadequately cooked pet or small animal food at the kill step (e.g., pellet mill of high incoming microbial load) makes implementing a successful PMCA impossible. Multiple conditioning cylinders or extrusion technology may be necessary for a reliable pathogen kill step.
    • If a feed plant is to produce safe pet food, it must have an effective microbial control program.
  2. Need to establish process segregation:
    • Segregating raw material from cooked pet food is critical to establishing an effective PMCA.
    • Separate these with walls to control air and traffic for microbial control and eliminate co-mingling of ingredients with flavor enhancement and packing supplies.
  3. Need to provide access for cleaning equipment:
    • Design and build equipment access especially for cleaning of Zones 1 and 2 within the PMCA.
    • Target problematic areas: leg boots and caps, flavoring application, coolers, and conveyor transitions. Prioritize these by problematic “hot” areas as indicated by a microbial swabbing program.
  4. Need to improve overall cleaning program:
    • A master sanitation program must be established for all zones, with zones 1 and 2 on a frequent schedule and zones 3 and 4 on a lower frequency.
    • The cleaning program and procedures (SSOPs) should be developed with science and data history to maximize efficiency, effectiveness, and overall performance.
  5. Need to improve plant air flow:
    • Air going into the kill step area or beyond should not be sourced from an ingredient, raw material, or other “dirty” area and should be filtered adequately.
    • An air-flow study with corrective action based on the results will improve air quality.
  6. Need to improve traffic patterns:
    • Contamination from shoes (of employees, visitors, contractors) and wheels (of forklifts, pallet jacks, carts and dollies) must be controlled to prevent microbial and foreign matter transfer.
    • Utilize shoe and wheel baths strategically positioned with approved sanitizer to reduce microbial transfer. Poor traffic patterns allow a microbial issue to become a bigger problem.
  7. Need to improve process temperature verification:
    • Product temperatures should be measured to verify that process temperatures are sufficient to kill Salmonella or other pathogens.
    • Assure that cooling of the product is sufficient to prevent condensation inside equipment. Product temperature should be within 20°F of the adjacent equipment temperature.
  8. Lack of effective insect control (especially flies):
    • Insects are a symptom that something is not right with exclusion, sanitation, and/or air flow.
    • Flies in the packaging room are unacceptable; one fly is one fly too many.
  9. Lack of effective cleaning organization and utilization of human resources:
    • Establishing an effective cleaning program requires directional leadership, SSOP development, employee training, supervision, and timely evaluation.
    • Reduce the plant to manageable zones with each having a food safety leader reporting to the chief food safety officer for efficient utilization of “production” labor.
  10. Lack of control of process leaks and airborne dry material:
    • Many leaks create many hours to clean, which can be seemingly neverending and unnecessary. Some leaks create microbial and insect activity concerns magnified with moisture.
    • Identify specific equipment leaks or lack of dust control to center on the best overall solutions.

If considering a transition to a higher level of food safety with better microbial control, action is required. Older facilities were not designed for optimal microbial control. To implement a successful microbial control program, one should examine these 10 concepts to identify solutions for short-term action and long-term budgeting.

The best long-term action might be an old building shutdown replaced with a new building with a new process designed the right way.