How to manage allergens in confectionery production

This article, written by Remco’s own Amit Kheradia, first appeared in Candy Industry on June 16, 2017. It has been updated for 2021.

For customers with food allergies, the simple pleasure of consuming a confection could have disastrous effects. Individuals with food allergies can rapidly develop symptoms of fever, vomiting, asthma, skin rashes, and hives, or they may even enter mild-to-severe anaphylactic shock. Compounding the problems of allergic reactions for consumers, there is a good chance they are allergic to more than one confectionery ingredient. The best way for consumers to prevent a reaction is to avoid products with declared allergens. However, consumers have no control over undeclared allergens, and that’s why manufacturers must recognize and separate common allergens in confectionery production.

According to Food Allergy Research and Education, up to 15 million Americans have food allergies, and the economic cost of children’s food allergies in the United States is about $25 billion each year. Undeclared allergens are also one of the most common reasons for food recalls. In 2014, undeclared allergens were behind half of the FDA’s fourth-quarter recalls. Moreover, according to the 2009-2012 FDA Reportable Foods Registry, about 90 percent of all reports involved three hazards: Salmonella, Listeria monocytogenes, and undeclared allergens, with undeclared allergens accounting for essentially the same number of reports as Salmonella (34 percent and 36 percent respectively).

An allergen is a type of antigen that, in specific individuals, produces an abnormally vigorous body response in which the immune system fights off a perceived threat that would otherwise be harmless to another person. These body responses are called allergies. Any protein-based product has the capability to elicit allergic reactions in humans at varying levels of severity. However, the following eight foods account for 90 percent of all food allergies: milk, eggs, peanuts, tree nuts, wheat, soy, fish, and shellfish.

So, how can we manage allergens in the confectionery industry?

Above all, the personnel preparing and handling confectionery products must be trained on allergen awareness and shown through proper demonstration how to prevent allergen cross-contact. This training should include identifying the various allergens in a facility, zones of production, material handling procedures, and appropriate sanitation practices.

The first line of defense starts with receiving raw ingredients. It is important to identify and separate different allergen-based products from each other, and from other non-allergen-based ingredients to avoid cross-contact. One helpful practice, for example, may be using white color-coded tags to identify milk-based ingredients, and green color-coded tags to denote peanut ingredients. This aids in tracking ingredients and helps avoid accidental mix-ups. The same concept could apply during storage and handling, as well as during other operational processes.

In storage areas, especially if allergen cross-contact is a significant hazard, additional precautions should be taken. One sample recommendation is storing wheat flour bags and soy flour bags side-by-side rather than one on top of the other. This reduces the chance of accidental cross-contact. During handling, care should also be taken not to pierce ingredient bags, as cross-contact between different ingredients may occur.

Material accountability through proper recordkeeping is another important part of training. For instance, if an operator is supposed to use 250 lbs. of milk powder in making a certain batch of product, and eventually ended up using 275 lbs., he/she must account for where the additional 25 lbs. was used. Was it wasted, spilled, or used in another product? Good recordkeeping subsequently strengthens the traceability and recall program for the facility.

Beyond training for allergen identification and material handling, training workers on sanitation practices reduces risks in the facility. When cleaning in high-risk areas, using hygienically designed tools helps mitigate the risk of cross-contact or cross-contamination. Specific color-coded sanitation tools can also be used in the presence of different allergens to further reduce risk. To verify the effectiveness of sanitation, a mere visual check may not be sufficient, and ATP swabs or specialized allergen swabs should be used. As an example, there are fast and reliable peanut detection kits that provide accurate and rapid results within minutes, and similar test kits are available for other common allergens.

A qualified and competent group of personnel should supervise employees to ensure that the allergen management program is effective. Oversight is one way is to confirm that employees are washing their hands and changing their protective equipment when moving from one allergen processing zone to another. Visual cues such as color-coded hairnets, gowns, smocks, aprons, or gloves may also assist in proper identification and segregation of employees working in a facility.

Apart from proper identification of the unique allergens and separation of ingredients, the key operation to focus on is processing. Production runs should be scheduled so that products with no allergens are processed first, followed by the product with least number of allergens, then second most, and so on (i.e., milk and wheat, followed by milk and wheat and soy products). After processing products with allergens, there must be a rigorous sanitation run before switching over to products with fewer, different, or no allergens. For instance, if you process a peanut-based confection and want to switch to a non-peanut-based confection, you must first clean and sanitize the food contact surfaces (equipment surfaces, conveyors, etc.). Then, you should sufficiently clean surrounding areas until no trace of the allergen is left.

Some allergen hazards extend beyond the production environment and should be considered by manufacturers. One potential hazard to consumers is that many do not know the scientific names listed on food labels. Because of this, product labels must explicitly list every allergen in the product. As an example, some products contain sodium caseinate, and many consumers are unaware that it is a milk-based ingredient. Therefore, apart from providing the scientific name, the label should explicitly state that the product contains milk. In addition, certain flavorings, spices, condiments, and preservatives may contain hidden allergens – for instance, tasty Cajun sauce might contain peanuts.

Another important point to note is that certain countries may recognize a wider array of allergens than those recognized in the United States. For example, Canada recognizes mustard and sesame seeds as allergens. These international differences are especially important to consider when importing or exporting products.

With the projected global confectionery market projected to reach $275.8 billion by 2025, the cost of recalls due to allergens will be an ever-increasing issue. Manufacturers can reduce the risk of these costly incidents by instituting a preventive allergen management program that runs across their production facilities and training the workforce on that program.

Celebrating FSMA’s 10th Anniversary: What have we achieved, and what’s to come in 2021?

blue workstation

Ten years ago, on January 4th, President Obama signed into law the Food Safety Modernization Act (FSMA). This act enables the FDA to better protect public health by focusing more on preventing food safety problems rather than simply reacting to them. Looking through a decade of U.S. regulatory challenges and achievements, so far, seven FSMA Final Rules and several guidelines have been published, and most food industries are already complying with the relevant requirements. Other FSMA compliance date deadlines to look out for are as follows:

FSMA Final Rule

Applicability

Compliance Date Deadline




Produce Safety

Other Produce – Small Farms (remaining water requirements)

Jan. 26, 2021

Other Produce – Very Small Farms (remaining water requirements)

Jan. 26, 2022

Small Farms – Non-sprout agricultural water requirements

Jan. 26, 2023

Very Small Farms – Non-sprout agricultural water requirements

Jan. 26, 2024

Intentional Adulteration

Very Small Businesses

July 26, 2021

 

For more current information on FSMA compliance requirements, visit the FDA’s website.

The battle is still far from being won – allergen labeling and management remains the top cited cause for product recalls, and contamination by Listeria monocytogenes and Salmonella continue to be the leading causes of foodborne illness outbreaks. These trends indicate that regulatory agencies, industry stakeholders, and allied groups should continue to make a concerted effort in providing safe and wholesome food to consumers. In light of increased hospitalizations during the ongoing pandemic, controlling for allergens and contaminants are even more critical as we face an already strained healthcare system. 

This year should see significant activities centered around strengthening industry requirements toward FSMA compliance. The following are some of the recent developments to potentially keep track of:

  1. Collaboration and Integration within Agencies: Expect more open communication among North American regulatory agencies such as the FDA, FSIS, and the CFIA and stakeholders. One such collaborative initiative that has been spearheaded by these organizations is on Salmonella reduction efforts in meat, poultry, and produce to meet Healthy People 2030 global targets. 
  2. Digitization of Food Safety Processes and Systems: To meet increasing record-keeping requirements, industries will make a greater effort to move away from physical paperwork and towards digitization and the use of AI and Data analytics technologies. Companies should be able to take advantage of real-time, block-chain, or predictive capabilities to help in hazard prevention, but these systems must also meet the 21 CFR 11 requirements on electronic record-keeping.
  3. Preparing for a New Era of Smarter Food Safety: The FDA’s Blueprint was launched in July last year as the agency’s masterplan towards creating a more digital, traceable, safer, and FSMA-based food network system that should help bend the curve of foodborne illnesses in the U.S. We should expect more developments for this initiative in 2021.
  4. Traceability as a Preventive Approach: The ability to trace and track the source of foodborne illnesses to be able to better prevent future outbreaks has become one of the FDA’s priorities. This year we look forward to the finalization of FSMA’s proposed Rule for Food Traceability, which should mandate additional record-keeping requirements for certain high-risk foods.
  5. Enhanced Focus on Sanitation Controls: With sanitation being elevated to one of the hazard analysis risk-based preventive controls, there should be an increased industry focus toward an integrated sanitation approach. Such an approach should also include the selection, cleaning, storage, and maintenance of cleaning tools, as such equipment can also become vectors of contamination in a food plant.

For more updates on the FDA’s Viewpoint on FSMA progress and the path forward, visit the FDA’s website.

References:

2020 Food Safety Development Recaps in Anticipation for 2021 and Beyond – The Future is Now!

With the COVID-19 pandemic raging on, it’s essential for the global food supply and food safety systems to keep delivering safe and quality food to consumers. Notably, the message from the FDA has been clear: “There is no evidence, as yet, regarding transmission of COVID-19 through food and food packaging.” 

However, out of an abundance of caution, we recommend that the industry and public-at-large keep abreast of relevant regulatory changes and follow science-based experts’ guidelines. Furthermore, as we all look forward to the progress on the vaccines, CDC/WHO/Public Health guidelines on minimizing the virus transmission and spread will still need to be followed.

This has definitely been a year of challenges for the food industry; however, let’s take a moment to recall some of the significant developments in food safety that should positively influence the North American food safety landscape in the years to come:

  • On July 13, the FDA unveiled its blueprint on the ‘New Era of Smarter Food Safety’ on creating a more digital, traceable and safer food network system to help reduce food illnesses in the U.S.
  • On August 22, the FSIS-USDA held a virtual public meeting to launch the “Roadmap to Reducing Salmonella” for meat, poultry, and egg products, and also to meet part of the Healthy People 2030 goals.
  • On November 18, the FDA released a new outbreak investigation tool that shall tabulate all foodborne outbreaks in an effort to initiate an early response from the FDA’s CORE (Coordinated Outbreak Response & Evaluation) team.

During the last quarter of this year, the FDA cited an inspectional violation to a manufacturing facility because of poor cleaning tool storage and use that led to RTE product cross-contamination. This reinforces the point we have been making for years that tools are vectors of contamination and so they need to be properly selected, used, cleaned, stored, and maintained.

Here is a list of key food safety-related developments to look out for in 2021:

  1. The FDA has just released the Proposed Rule for Food Traceability to provide the basis for additional traceability recordkeeping for certain foods based on Section 204 of FSMA. In 2021, we should expect a finalization of the rule and more guidelines, specifically on the Food Traceability List.
  2. SQF Edition 9 Code books were published during the latter half of 2020. In a nutshell, the new codes now reflect a more sector-specific approach, and with an emphasis on food safety culture. The new codes shall be aligned to the newest GFSI Benchmarking Documents Version 2020. SQF Edition 9 is expected to become the auditing standard from May 24, 2021 onward.
  3. GFSI version 2020 has also incorporated two new scopes of recognition on Hygienic Design i.e., JI and JII. We should expect more food safety system requirements regarding hygienically designed facilities, equipment, tools, and utensils in the very near future.

Important Company News:

  • In order to effectively serve grocery stores, our parent company, Vikan, has launched the Food Retail line of products and solutions. To download the guide, click here.
  • Remco now stocks high temperature resistant tools that can be effectively used for cleaning ovens or other heated surfaces. 
  • Our SQF practitioner-qualified, HACCP- and PCQI-certified Business Development Managers are now capable of conducting virtual site assessments. To request a site visit, contact us.

Remco, as a supplier of color-coded, high-quality, and durable cleaning, hygiene and material handling equipment, appreciate and wholly support the role of the food industry and the front-line workers in assuring food safety and sanitation even during these trying times. 

We earnestly look forward to a healthy, prosperous, and stable 2021 for all. Meanwhile, we wish everyone happy holidays and a safe season!

References:







Remco’s Tools are Playing a Critical Role in Covid-19 Vaccine Distribution

Remco has proudly provided tools and guidance to help food manufactures mitigate the risk of Covid-19 in production facilities while maintaining their high food safety and quality standards. Now, Remco’s material handling tools – hand scoops and shovels – are playing a critical role in the distribution of Covid vaccines across the U.S.

In a monumental logistics effort, millions of Covid vaccine doses are being moved from manufacturers to administering sites across the U.S. In this distribution process some vaccines must be transported and stored at extremely cold temperatures. Moving the vaccines through the cold chain and meeting delivery timelines while maintaining these temperatures requires the vaccines to be shipped in specially designed cartons that are packed with dry ice.

Working with dry ice presents a unique challenge to the distribution system in that it can’t be safely handled without tools. This task is where Remco’s scoops and shovels are finding use. Remco’s FDA-compliant scoops and shovels are built to handle the products and conditions often found in food and pharmaceutical manufacturing.

To meet the needs of pharmaceutical distributors, dry ice manufacturers, logistics companies, and front-line healthcare workers, Remco will deliver tens-of-thousands of scoops and shovels across the next several weeks. Remco’s capacity to scale up its U.S.-based manufacturing and distribution is an essential factor in getting our tools into the hands of the people who need them.

We are honored to play a small part in the global fight against Covid and we look forward to our continued role in providing the tools that help keep food production safe.

Additional information about shipping and handling Covid vaccines:

https://www.freightwaves.com/news/solving-the-dry-ice-challenge-for-covid-vaccine
https://www.usatoday.com/story/news/health/2020/11/18/pfizer-covid-19-vaccine-dry-ice-sales-storage/6281859002/
https://www.cnn.com/2020/11/21/world/coronavirus-vaccine-dry-ice-intl/index.html

How to Keep Cleaning Tools from Becoming Vectors of Contamination

Recently, the FDA issued a warning letter to a food manufacturing facility. One of the critical inspectional violations pointed to the improper use and storage of an unclean broom that spread Listeria monocytogenes from a wet cooler passageway to a ready-to-eat (RTE) production room.(1) Environmental swabbing and microbiological whole genome sequence testing implicated the broom in spreading the bacteria. This is a timely example of how cleaning equipment can be vectors of cross-contamination in plants if tools are inappropriately selected, used, cleaned, stored, or maintained.

According to the CDC, Listeria monocytogenes causes about 1,600 foodborne illness hospitalizations and 260 deaths in the U.S. every year, and of late, a significant number of outbreaks have been associated with inadequate environmental sanitation regimes within RTE deli establishments. These harmful micro-organisms, if not controlled, may eventually persist as biofilms (on common environmental surfaces, such as tools, utensils, and equipment) which could become difficult to eradicate through regular cleaning and sanitization.(2) Other examples of biofilm-producing pathogens of public health importance include Salmonella and E. coli O157:H7.

Moreover, cleaning tool surfaces can also become carriers of key food safety hazards such as allergens and foreign materials. Hence avoiding or minimizing contamination incidents require a proactive, integrated sanitation approach – this may include the following strategies:

  1. Implement a risk-based hygienic zoning program – It’s worthwhile to divide the facility into manageable areas and to separate processes based on risk. With zoning protocols, tools used at raw product cooler storage areas can be separated from tools employed in the RTE production room. Such an approach may be effectively combined with the 5S [Sorting, Setting-in-order, Shining, Standardizing, and Sustaining the tool management system] (3) and color-coding programs (4) to control cross-contamination incidents in plants.
  2. Select high-quality, durable, color-coded tools – Remco provides a range of sanitation tools – such as brushes, brooms, squeegees etc. – for cleaning food-contact and non-food contact surfaces within an area. Tool selection is important in the fight against cross-contamination. For example, black pipe brushes that can withstand harsh chemicals are normally allocated for drains, while, a high-temperature resistant tool of another distinguishable color may be used to clean hot surfaces of baking ovens. Our range of tools is available at: https://remcoproducts.com/products/.
  3. Ensure effective tool decontamination – Tools must be cleaned and sanitized (as appropriate), at least before and after use, and usually at frequencies in-between high-risk operations, as safely and securely, in order to avoid any potential contamination. Tool decontamination using water generally involves effective soil removal from the surface and involves the validation and verification of key parameters like – contact Time, mechanical Action, Chemical concentration, washing Temperature, the use of trained and competent Employees, and appropriate Resources and sanitation aids. (2,5)
  4. Follow proper tool storage, care, and replacement procedures – Cleaned tools should be stored properly on racks with heads down that are off the floor and distant from other tool handles. The tools should be placed in a single row so that condensate from the tool above does not drip and contaminate the tool below. Tools, as environmental surfaces, must be routinely checked and preferably monitored through visual inspection, ATP testing, microbial swabbing and testing, etc. Any damaged, worn-out tool should immediately be disposed and replaced with new conforming tools. (5)
  5. Recommend hygienically-designed tools – A 1990 UK government-funded study showed that 47% of the cleaning equipment sampled was found positive for Listeria monocytogenes, which reinforces the premise that tools are possible vectors of contamination. One of the valid recommendations is to have tools that are free of contamination traps, have a smooth surface, are of one-piece construction, and most importantly, are easily cleanable, inspectable, and maintainable.(6) Hygienically designed tools like the UST Vikan brushes and Ultra-Hygiene Squeegee range of hygienic-design construction are highly recommended for high-risk areas such as the RTE processing rooms.

Remco can help you with the proper selection, storage, care, and maintenance of tools and equipment that are required to effectively clean surfaces and avoid contamination incidences in food plants. For more information about our products and solutions, click here.

References:

  1. Food Safety News on food companies warned over violations –https://www.foodsafetynews.com/2020/11/two-california-food-companies-warned-over-violations/
  2. The role of manual cleaning in biofilm prevention and removal –https://go.remcoproducts.com/biofilms
  3. 5S in the food industry – https://remcoproducts.com/5s-in-the-food-industry/
  4. Color-coding toolkit for food processing facilities –https://remcoproducts.com/toolkit/
  5. Optimizing food safety through good cleaning tool maintenance –https://remcoproducts.com/cleaning-tool-maintenance/
  6. The hygienic design of food industry brush-ware: the good, bad and the ugly – https://remcoproducts.com/ust-white-paper/

 

ABC’s of Manual Cleaning Part I: Why is it important?

Part I

This blog series will go over the various ins and outs of manual cleaning and why it’s necessary for the safe production of food. It is essential for food processors to understand that the proper selection, use, cleaning, storage, and care of tools employed can prevent or minimize cross-contamination of food from hazards that are of a public health concern, e.g. microorganisms, allergens, and foreign materials.

 Cleaning and sanitation of environmental surfaces (both food-contact or non-food contact) and food production equipment can be a time-consuming operation in food facilities. Nevertheless, the maintenance of sanitary conditions to ensure product safety and quality is a regulatory, industry, and global food safety standard requirement.

The CDC estimates that every year, 1 in 6 people in the U.S. get sick from eating contaminated food. The use of contaminated equipment and utensils is one of the top 5 contributing causes to foodborne illness outbreaks. The key food safety hazards of public health concern are bacterial pathogens, allergens, and extraneous foreign material – and consequently, the cleaning methods and equipment capable of minimizing the risk of these hazards are required.

Industry cleaning methods may range from being process-specific (e.g. clean-in-place [CIP] for cleaning processing pipework and closed vessels]) to the much simpler, process-agnostic manual cleaning involving the use of brushes, scrapers, squeegees, etc.

Automated cleaning isn’t always foolproof

In contrast to manual cleaning, CIP normally involves the automated cleaning of equipment parts, such as the interior of pipes, vessels, or fittings without disassembly. This is generally done by pumping chemicals at a set concentration, temperature, and pH through the system for a controlled period of time at a flow rate that generates turbulence, which provides the mechanical action required as part of the cleaning process in a closed system. Clean-out-of-place (COP) involves disassembly and removal of parts to a remote automated cleaning system.

Once all the cleaning parameters used by these automated systems have been determined and programmed in, cleaning is as easy as pressing a button. However, the biggest limitation of CIP and COP cleaning is that the poor hygienic design of some equipment doesn’t always allow for a thorough using the automated method. Moreover, poorly designed pipework and equipment can result in contaminants getting trapped in narrow, inaccessible, or dead-end zones of the equipment or surfaces being cleaned.

CIP components like spray balls, and the valves, coupling, and sampling ports of CIP cleaned processing pipework also require regular disassembled and manual cleaning, to ensure the on-going efficiency and effectiveness of the CIP clean.

On an important note, the 3-A SSI industry cleaning standard clarifies that if food-contact components of equipment parts are not designed for CIP or other automated methods of cleaning, these parts should be cleaned and sanitized manually.

Key message: Clean before you sanitize

If the food equipment and surfaces aren’t cleaned properly, certain microorganisms may survive and persist by secreting a slimy, extracellular polymeric substance that can enmesh other organisms, nutrients, moisture, and foreign materials to form a biofilm that can firmly attach to a surface.  According to Moorman and Jaykus (2019), manual cleaning is important for surface biofilm removal because “one just can’t sanitize one’s way out of a persistent biofilm problem within a facility. Biofilm eradication, therefore, generally requires equipment teardown, deep-cleaning and sanitation, and a follow-up verification.”1,2

Proper cleaning of equipment and surfaces, therefore, is the first step toward better overall sanitation in food processing plants. Debra Smith, Vikan’s global hygiene specialist, clearly demonstrates the importance of manual cleaning action and the use of cleaning detergent and potable water to significantly reduce surface biofilm load rather than simply immersing a dirty piece in a chemical solution.Sanitization only follows after appropriate cleaning and rinsing of the surface.

In a nutshell, applying detergents and sanitizers alone cannot make a fundamental difference in removing surface biofilms. Manual cleaning will always be required in addition to other cleaning methods because there will always be hard-to-reach places where biofilms can form and can only be effectively be cleaned using hand tools.

 

Selected References:

  • Moorman, E., & Jaykus, L. A. (2019). Impact of Co-Culturing with Pseudomonas aeruginosa on Listeria monocytogenes Biofilm Physiochemical Properties and Sanitizer Tolerance. In IAFP 2019 Annual Meeting. IAFP
  • Remco (2020). The Role of Manual Cleaning in Biofilm Prevention and Removal. Whitepaper Link: https://go.remcoproducts.com/biofilms
  • Vikan (2020). Biofilm Demonstration Workshop. Video Link: http://vikan.com/media/10408/vikan-biofilm-movie.mp4

ABC’s of Manual Cleaning Part II: What does Manual Cleaning Involve?

Part II

In part one of this series, we discussed how manual cleaning involves the use of tools such as brushes, scrapers, and squeegees, along with other sanitation aids. This can effectively remove contamination from surfaces and equipment – and, in numerous instances, there may be no other practical option for cleaning some components or parts, even for the state-of-the-art automated systems. However, is manual cleaning just about, say, an employee using a hand brush to clean the internal surface of a soiled tank? Well no, it’s more than just that!

Understanding the concepts

Cleaning involves the removal or significant reduction of debris such as visible soil and contaminants from a surface. Industry best practices and regulatory requirements have always been to clean before you sanitize the surface.

Cleaning should not be taken as a one-size-fits-all activity, since several factors may influence the formulation of the right kind of parameters required to remove soils from a surface. The cleaning activity may be achieved in many ways, and a single cleaning method may involve overlaps of various cleaning activities:

As shown, manual cleaning may or may not involve the disassembly of the parts of equipment. Moreover, it is important to define the ‘level of clean’, which is a risk-based decision generally dependent on the type of contaminant (mainly microorganisms, allergens, and foreign material) to be removed from a surface. Some of the factors influencing the level of clean are as follows:

  • Whether the contaminant/hazard present is required to be eliminated or minimized to an acceptable level through the cleaning process.
  • Whether the cleaning activity itself should minimize the spread of the contaminant.
  • Whether the cleaning activity will have a negative impact on the surface being cleaned.
  • Whether the prevailing regulations, standards, and best practices will be met through the cleaning activity.

Choose the right cleaning activity

The choice of cleaning activity is crucial since we do not want to sacrifice effectiveness for the sake of efficiency. As shown below, certain cleaning activities may increase the risk of contamination spread, hence they are deemed high-risk.

As illustrated, hosing, especially at high pressure, is a high-risk activity compared to vacuuming. The former will generate liquid aerosols and droplets that will spread over a considerable distance, carrying with them contamination from the surface being cleaned. However, other common manual cleaning techniques, like scraping, scrubbing, or sweeping, are generally classed as medium risk, requiring some caution in their performance. For instance, scrubbing dirty parts using a brush is better done submerged under the water to minimize the spread of droplets generated by the scrubbing action.

Select the right tool for the right job

The selection of manual tools is vital, since this can greatly influence its cleaning efficacy and durability, and its subsequent cleaning maintenance and storage. Some useful tips on tool selection are provided below:

  • Choose the right bristle type for brushes and brooms. Stiff bristled brushes may scratch and deteriorate sensitive surfaces, while very soft bristles may be ineffective in removing rigid soils from surfaces but are good for sweeping up fine powders.
  • It is best to use total-color tools that are easily identifiable, trackable, and manageable in their respective hygienic zones at a site. Color-coding may also be used to separate to food-contact and non-food contact tools. This goes a long way in reducing cross-contamination in food plants.
  • Where higher temperatures are encountered in operations, use tools capable of withstanding high temperatures.
  • Evaluate whether special application tools will be required, say, for conducting deep cleaning, detailed cleaning, or high- or low-level cleaning.
  • Hygienically designed tools normally have smooth surfaces, rounded edges, and no crevices where contaminants can accumulate and be difficult to remove. Remco’s one-piece construction scoops and shovels, and Vikan’s UST brushes and Ultra-Hygiene squeegees are great options for hygienic tools to use for food manufacturing facilities processing high-risk products.

 

Selected References

ABC’s of Manual Cleaning Part III: How does Manual Cleaning Work?

Part III

In this part, we address the key question: how is the manual cleaning process typically implemented? A robust manual cleaning program is generally an integration of the best of science and management – which go into developing Sanitation Standard Operating Procedures (SSOPs) that should be well-understood by the employees implementing the program.

Assess the TACTER Parameters

The TACT circle was originally developed by Dr. Herbert Sinner in 1960. This model lists the parameters needed to remove soil from a surface. Remco has added two parameters, “Employees” and “Resources,” to make it a holistic model for effective cleaning. Please refer to the comments I made on the TACTER section notes in the 5S White Paper:

Where a thick layer of allergens, foreign matter, or biofilms build up on a surface, the TACTER requirements are intensified, such as a worker needing to do intense manual scrubbing to remove such contaminants.

Evaluate Cleaning Program Considerations

The SAVER2 model was developed by Remco to assist with understanding the points necessary to build a comprehensive cleaning and sanitation program:

The following important questions are taken into consideration:

  • What type of Surface is being decontaminated?
  • What is the nature of the Soil being removed or reduced to an acceptable level?
  • What is the Aim of the decontamination action?
  • What step-by-step decontamination Activity is being implemented?
  • Is the decontamination process Validated?
  • Is the decontamination process adequately Verified?
  • How Effective is the decontamination activity?
  • How Efficient is the decontamination activity?
  • Are the processes supported by valid scientific, technical, or credible References?
  • Are Remedial actions being put in place to correct or prevent anything significant that could go wrong?

Cleaning decisions must be risk-based

Depending on the nature of the soil, surface, and other cleaning considerations, the site may decide to conduct dry-cleaning, wet-cleaning, or controlled wet-cleaning:

                                                                                      

Dry-cleaning, where little or no water is used, is normally practiced in environments where low water activity foods (e.g. flour, milk powder, biscuits, etc.) are manufactured. This is because the introduction of water could provide a medium for microbial growth. However, care is taken not to aerosolize allergen ingredients in the process, as this could create cross-contact issues.

In wet-cleaning, water is used for removing soluble or emulsified soils from the surface. This is the most common method in operations processing high water-activity foods (e.g. meat, beverages, etc.). The biggest drawbacks faced in such environments are problems related to condensation and waste-water issues.

However, in several food plants, controlled wet cleaning at a separate sanitation station is conducted to avoid any contamination or aerosolization occurrences. This may be done to clean small equipment pieces or even large, dismantled tanks.

 

Document and implement the cleaning steps clearly

More importantly, employees implementing and maintaining the cleaning program must be well-educated and trained on the cleaning tasks. For a wet-cleaning operation, the following are the cleaning steps:

  • Secure equipment, disassemble, and dry-clean to remove gross debris.
  • Pre-rinse equipment surfaces with potable water, from top to bottom.
  • Apply detergent and foam, and scrub from bottom to top.
  • Post-rinse with potable water and conduct self-inspection (by the operator).
  • Conduct a formal post-sanitation inspection (usually done by QC).
  • Sanitize (with approved sanitizer) and assemble the equipment.
  • Dry equipment and let a supervisor verify as part of the pre-op inspection.

 

Using the right detergents and approved sanitizer concentrations is critical to ensuring cleaning effectiveness.

 

Next Steps

In our next blog, we’ll discuss how to set the frequency and locations for manual cleaning. Stay tuned!

 

Selected References:

ABC’s of Manual Cleaning Part IV: Where and When to Manual Clean?

Part IV

Part three briefly explained how to implement a typical manual cleaning process. In this part, we will explain the basics of how to identify the locations or areas that require cleaning, and how to determine how often they’ll need cleaning. These steps are very important for the establishment of the consistently sanitary environment required for safe food production.

Keeping your master cleaning schedule up to date

Every possible area, spot, or location that could potentially create an unsanitary or unhygienic food production environment if left uncleaned should be systematically accounted for. This denotes the concept of risk-based cleaning.

Generally, a typical cleaning schedule is used to document the provision of effective facility, fixture, equipment, tool, utensil, clothing, amenity, and external area cleaning. An illustration of the elements is provided below:

Any changes to the schedule should be clearly justified and be reflected in the procedures, training programs, and reviews.

 Revisiting the ‘level of clean’ for environmental surfaces

It is essential to verify whether cleaning has been carried out effectively, and normally, the ‘Level of Clean’ of an environmental surface falls under one or more of the following classifications:

  • Sanitary: The surface must be free of pathogens. In the interest of public health, the FDA sets a zero-tolerance level for foodborne illness causing microorganisms. Micro-swabbing accompanied by testing the surfaces is generally conducted.
  • Micro-clean: Apart from keeping surfaces pathogen-free, spoilage organisms should also be significantly reduced. This not only enhances food quality, but also improves the hygienic condition of the environment.
  • Allergen-clean: This involves cleaning surfaces to remove allergens. Rapid detection allergen test kits are available to verify the presence or absence of specific allergens on the surface after cleaning.
  • Quality-clean: Here, surfaces are cleaned to remove debris, dirt, or soils from the surface, which may affect product quality. Post-cleaning verification using ATP rapid detection swab is common. Acceptable ATP thresholds need to be established and records maintained for inspection by auditors as evidence of assuring a quality-clean.

It is not generally acceptable to conduct “as-needed” or “emergency cleaning”. Instead, scheduled cleaning of food contact (FCS) and non-food contact surfaces (NFCS) should be the norm, with FCS (e.g. equipment surfaces) being regularly cleaned and sanitized before and after use. Equally important is cleaning NFCS (e.g. drains, ceiling fixtures, wall junctions, equipment bearings, etc.) since contaminants can easily transfer from these areas to food and food contact surfaces.

For the control of pathogens, like Listeria monocytogenes, a site can adopt a Seek and Destroy approach that has been reflected in the FDA Listeria Guidance for RTE Foods. Here, the goal is to find Listeria in locations where you’d least expect to find them and use appropriate controls, like deep cleaning, scrubbing, and biofilm removal strategies, to eradicate any micro-harborage areas.

 

Creating your Manual Cleaning Plan

Cleaning is not a “one-size-fits-all” approach, as different locations may require the use of specialized tools, as illustrated below:

What’s next?

To get the best outcomes from manual cleaning, allocating responsibilities and accounting for the effectiveness and efficiency of the tasks is crucial. In our next blog, we’ll focus on understanding the people or departments responsible for planning, conducting, reviewing, and maintaining cleaning programs and tasks.

Selected References:

  • Remco (2020). The Role of Manual Cleaning in Biofilm Prevention and Removal. Whitepaper Link: https://go.remcoproducts.com/biofilms
  • S. Food and Drug Administration. (2017). Draft guidance for industry: control of Listeria monocytogenes in ready-to-eat foods. Fed. Registrar, 82, 4803-4805.

ABC’s of Manual Cleaning Part V: Who is Responsible for Manual Cleaning?

Part V

Part four covered critical locations and the frequency of manual cleaning in those areas. In this part, we are going to briefly focus on understanding the relevant departments involved during the cleaning and sanitation process within a food facility.

Not a one-person job

Developing, implementing, and maintaining cleaning programs within a food plant is no small feat. Such an important activity cannot be left solely to the facility sanitation manager–it requires close and coordinated collaboration between many departments. Food safety and quality assurance, production, maintenance, and purchasing, to mention but a few, should all be part of the process. It involves the scheduling of tasks, selection and evaluation, usage, storage, care, and re-ordering of sanitation aids such as chemicals, tools, etc.

Part of the cleaning and sanitation tasks could be outsourced to third-party contractors, who may perform third shift or after-hours sanitation, and are therefore considered part of the food safety and sanitation team. Valuable input or feedback from regulatory inspectors; certification auditors; suppliers of cleaning tools, equipment, and chemicals; subject matter experts; and even customers, are also an essential part of a successful program. Furthermore, the intricacies of a robust cleaning program will depend on what is required to ensure that food products are free from disease-causing organisms and other contaminants that significantly impact on food safety and quality.

Accounting for manual cleaning responsibilities

Defining, implementing, and maintaining a Master Cleaning Schedule can become an intensive exercise.

If we look at the Master Cleaning Schedule shown below, it requires additional independent and trained personnel to develop the programs; monitor the progress; and verify or audit the process, and requires that responsibility for each of these be allocated, along with proof of documentation that these actions happened.

Toward a Hygiene and Sanitation Culture

The entire organization, from top management to every employee, needs to be committed to the production of safe food under sanitary conditions, as cleaning comprises an important component of a food safety and quality management system.

As Frank Yiannas, FDA deputy commissioner, rightly points out: “Food Safety Culture is about creating a behavior-based food safety management system.” Hence, an all-inclusive integrated sanitation approach (as we’ll discuss in Part 6 of this blog series) becomes a key aspect of the site’s education and training programs, which should be seamlessly embedded into the overall organizational culture.

Some ways of improving hygiene and sanitation culture when using manual cleaning tools may be as follows:

  • Use of FDA-compliant, color-coded, hygienically designed, durable, and high-quality cleaning tools.
  • Education and training of employees on the why, what, where, when, how, and who of tool selection, care, cleaning, storage, care, and maintenance.
  • Motivation of employees through transformational leadership and learning opportunities.

What’s Next

In our next blog, we’ll understand the key regulations, standards, and industry best practices that support a manual cleaning program for a food facility.

Selected References:

  • Smith, Debra (2017). Optimizing Food Safety Through Good Cleaning Tool Maintenance. Whitepaper Link: https://remcoproducts.com/cleaning-tool-maintenance/
  • Yiannas, F. (2008). Food safety culture: Creating a behavior-based food safety management system. Springer Science & Business Media.