Cleaning and sanitizing have always been considered important aspects of a complete food safety program. But the critical nature of these practices, and risks of nonconformance, have been considerably increased with the inclusion of “insanitary conditions” among the 76-count PCA felony indictment which brought prison sentences as high as 28 years for the peanut-production company’s executives (see The Indictment below). While it is unlikely (and unlawful) for a food plant to not have a cleaning/sanitation program at all, it can be relatively small things that are overlooked that cause the greatest problems. As such, this article provides a range of hints, tips, advice, and best practices from cleaning and sanitation suppliers—those who look at food and beverage plants from the outside in on a regular basis. If even one of these gets your team thinking about a practice that could be improved, QA has fulfilled its purpose.
Monitor and Verify
The quality manager’s mantra that’s been repeated time and time again is “you can’t manage what you don’t measure.” FSMA verification and validation requirements echo this sentiment. Food processors who are not monitoring the effectiveness of cleaning procedures by this point are falling behind the curve.
In-house sanitation monitoring and environmental monitoring test kits for microorganisms and pathogens are now so easy to use and affordable that many processors find it more efficient to bring environmental swabbing for Salmonella, Listeria, and indicator organisms in-house to get ahead of lab results and cut down those costs. Headlines like the PCA sentencing make it harder for processors to ignore the reality of consequences when you turn a blind eye to sanitation basics.
In the case of the United States of America vs. Stewart Parnell, Michael Parnell, Samuel Lightsey, and Mary Wilkerson filed February 15, 2013, the indictment included the Grand Jury charge of conspiracy, as follows:
Count 1: Conspiracy. The defendants … did knowingly and willfully combine, conspire, confederate and agree with each other and with others to … defraud PCA’s customers and to obtain money by means of false and fraudulent pretenses, representations and promises. Among the manner and means by which the defendants and others conducted, participated, and assisted in the affairs of the business and the schemes to defraud were the following …
… The defendants and others represented PCA in a company brochure to be “The Processor of the World’s Finest Peanut Products,” with “a remarkable Food-Safety record, developed in an environment committed to continuous training and state-of-the-art Food Safety techniques”; however, the defendants and others produced and caused to be produced peanut products under the following insanitary conditions, which they knew were conducive to Salmonella contamination, including, but not limited to, the following:
- Roof leaks were not adequately repaired;
- Adequate measures were not taken to prevent rodent and insect infestation;
- Adequate measures were not taken to prevent possible cross contamination between raw and finished product after the roasting process; and
- Proper cleaning and sanitation procedures were not followed.
Despite warnings from industry experts, the defendants and others continued to produce and caused to be produced peanut products under the above conditions. The numerous tests which were confirmed positive for Salmonella were consistent with these manufacturing conditions, but the defendants and others concealed those results from their customers, failed to correct the causes of the Salmonella contamination, and continued manufacturing and selling their products under the same conditions.
(Excerpted from http://1.usa.gov/1QeaXK0.)
The best defense is a good offense. A robust environmental monitoring program typically includes ATP sanitation monitoring, pathogen testing, protein-residue allergen screening, and indicator-organism monitoring. Verifying HACCP plans and SSOPs with easy-to-use test kits not only verifies that procedures are being completed, but assures that they are being completed thoroughly and effectively, which is the key to keeping sanitation procedures in check.
Correctly sizing your brush is critical for optimal cleaning. When selecting the diameter of the brush used to clean the interior of tubing, pipes, drains, valves, etc., keep the following tips in mind:
The key to efficiency is maximum tip contact to the surface—the tips of the brush are what provide proper cleaning. Select a brush with an outside diameter exactly the same as the inside diameter of the pipe.
- A larger diameter brush will bend when it is placed into the pipe providing less effective cleaning as the bristle tips will not contact the surface. This also will cause extra wear and tear on your brush, and may result in the brush getting stuck in the pipe.
- A smaller diameter brush will require additional passes and may result in missed areas.
The handle of your brush should reach the entire length of your pipe or tubing for quick and effective cleaning.
—Nelson Jameson, nelsonjameson.com
In-shift Cleaning AND Sanitizing
The drier your facility, the easier it will be to control microbial growth. In-shift cleaning and sanitizing is becoming more common, so speed of application and drying time must be considered when evaluating new interventions. Because alcohol kills microorganisms rapidly and evaporates, it can be used to sanitize during breaks, changeovers, and clean-ups without rinsing.
These systems also are being used more frequently as a preventive control for sanitizing vectors of cross-contamination. Footwear, forklifts, pallet jacks, contractors’ tools, and equipment wheels are quickly sprayed in transition areas between non-critical and critical zones such as ready-to-eat environments.
QA Traffic Mapping
A new quality control management tool many plants are using includes overlaying traditional “hit maps” with additional maps that represent the traffic flows of people and product through the plant. This map overlay allows quality assurance personnel to correlate the movement of employees, visitors, contractors, fork trucks, pallet jacks, and product flow in relation to where positive organism counts are found.
With this information, the plant can determine the floor sections, traffic intersections, and entry points that are contributing to risk, or potentially contributing to identified positives.
Once risk zones are identified, the plant can implement interventions for floors, drains, and entryways to control the movement of organisms. EPA-registered sanitizers and disinfectants can be used on floors and in floor-containment devices, floor drains, and scrubbers to manage risk and remediate organism growth in a manner that is coordinated with the map overlays.
When inspecting a plant for sanitation conformance or issues, it is important to look at the current employee hygiene procedures as well as placement of hygiene stations.
What is often seen—in a practice that can lead to contamination—are employees not washing their hands properly; not washing at the right location in comparison to the production areas; manual sinks that are not kept clean; usning cold water temperatures for handwashing sinks which often lead to low compliance; and finally, a poor overall food safety culture from upper management down to the plant worker.
In footwear hygiene alone, problems often are found with keeping sanitizers at the 800 ppm-1,000 ppm needed to kill Listeria, having shoe contact time that is too short or non-existent, and the use of high maintenance and messy methods.
Creating good traffic flow, implementing a “cleanroom” type entry, and installing automated hand and footwear washing systems will put quality control where it has been lacking in the past, thus increasing awareness of employee hygiene and improving overall food safety culture.
Dry Clean First
For low-moisture facilities such as peanut roasting, blanching, and further processing, cleaning and sanitizing create a unique challenge in that water is considered the enemy. A dry clean and removal of all organic matter must take place before sanitizing with an EPA registered, low-moisture surface sanitizer.
Many peanut processors rely on alcohol/quaternary sanitizers which are highly evaporative, effective on pathogens such as Listeria and Salmonella, and safe for food-contact surfaces without a rinse. Additionally, processors are implementing new methods for footwear sanitation, which use an alcohol/quaternary formula as a misted spray to the bottom and sides of footwear. Unlike foamers and mats which add water, a footwear-sanitizing spray system applies a fresh spray to employees’ footwear each time it’s used.
—Best Sanitizers, www.bestsanitizers.com
External Belt-Conveyor Equipment
One of the most significant issues in food or beverage plants is the use of external belt-conveyor equipment, which can carry harmful bacteria into the sanitary plant environment. This is especially true with water-cooled conveyor belt presses that are used to join belts. Traditional water-cooled presses have an open tank that must be filled and connected to the press via hoses. During setup, water splashes and/or spills are common. In addition, if the press is brought into the facility by a third party, the water tank, hoses, and other components carry the risk of outside contamination. Plant maintenance should look for a press with a built-in air-cooling system and eliminate the waterborne safety and hygiene issues presented with traditional water-cooled presses. The press a plant chooses should also be portable enough to be stored onsite for quick, sanitary use.
Explain the “Why”
In today’s food production environment the ultimate goal is to protect one’s brand.
Some of the more typical problems and solutions can be:
- Ensure that employees are really trained to do thorough hand washing—for 20 seconds.
- Properly label all sanitation products, including mop buckets, pump-up sprayers, portable foamers, etc. Color-coded training cards can help simplify the process.
- Use of personal protective equipment continues to be one of the greatest challenges when it comes to food sanitation clean-up. People lose sight of the fact that they have one set of eyes. And they don’t realize that having their bare hands involved with sanitation chemicals over the long run can cause their hands to look two to three times older than their real age.
- The hot spot for all food sanitation production workers is making sure they are properly trained. The more they understand the “why,” the more ownership, the more dedication, and the better results they will generate for the team.
—Spartan Chemical, www.spartanchemical.com
The author is Editor of QA magazine. She can be reached at email@example.com.