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/

 

Being a Food Safety-Minded Consumer

As a consumer with a passion for food and cooking, I know a thing or two about food safety in the kitchen. In my time at Remco, I’ve learned a lot more and have become acutely aware of all the considerations for the safety of our food as it moves from farm to fork. I am amazed at how much food safety professionals need to know in order to perform their daunting jobs.

Lettuce greens and food safetyI try to be aware of basic food safety guidelines in my kitchen. I use a meat thermometer to be sure the food is within the safe range, but also because I prefer not to overcook it. I avoid the cans with dents at the grocery, because the good ones stack better in the pantry—but also because some dents may compromise the integrity of the product. I clean my grill tools before flipping food if they’ve come into contact with raw meat, and I always use a fresh plate to bring food back inside.

Now that I’ve worked closely within the food industry for over three years, I’m starting to think a little differently about my own food safety. My new awareness goes beyond my own kitchen. Lately, I’ve started to wonder about the food safety efforts at the facilities that produce the food I buy. And I’ll tell you, when I hear about a producer going above and beyond for food safety, it sticks with me.

A great example is Earthbound Farms—a California salad greens grower and packager. I read recently that they are BRC validated, which requires very rigorous third-party audits. As a consumer, the fact that they have pursued food safety validations above and beyond requirements tells me that they really care about the safety of their consumers. And they are very transparent about their food safety program. They’ve gained a loyal consumer in me.

With that being said, food safety in my kitchen now starts with getting to know a little bit more about where my food comes from—not just the temperature it arrives at when I’m done cooking it. I now seek information about the food safety programs of producers I purchase from, and I’m willing to spend a bit more if I know that they are diligent in their efforts.

10 Things To Know About Color-Coding: Communication is Key

Essential to an effective color-coding system is a well thought-through communication plan. With the proper communication channels in place, your color-coding system has the best chance for successful adoption—in turn helping you to mitigate the risk of cross-contamination. Communication should start at the top of the company, and go down to each and every employee. When all employees are knowledgeable about the new or changed program, the chances of success are even higher.

HACCP Plan for food safetyThe initial employee training communications must be clear and concise to ensure everyone is on the same page. When starting, or even revising, a color-coding system, employees must understand the reason for the change. Dealing with the threat of cross-contamination is serious, and the need to establish barriers to those threats is critical. The better every employee understands this, the more effective the color-coding system will be when put into practice.

Communicating with employees on how color-coding can help with tool storage is also very important. Establishing procedures for storage can help with tool inventory management. If employees are taught the proper procedures for tool storage right out of the gate, this will go a long way in preventing any loss of tools or time. One particular way to help encourage proper storage is to use custom shadow boards that integrate outlines of the tools so that there is no question where tools belong. Some facilities might use the 5S system to maximize organization. The use of color-coding is a great way to enhance the 5S philosophy. 5S is a Japanese workplace organizational system which uses five phases: sort, set in order, systematic cleaning (or shine), standardize and sustain. Along with using shadow boards, 5S helps encourage employees to properly store tools, maximizing their usable life.

Green color-coded wall bracket with rubber clips for sanitation Red color-coded wall bracket with rubber clips for sanitation Blue color-coded wall bracket with rubber clips for sanitation
Zone 1 Zone 2 Zone 3

Daily communication to employees is essential to the longevity of the program. Daily communication starts with good signage. Clearly written instructions, bilingual if necessary, are essential to providing employees with instructions on the color-coding program. It may even help to include visual or graphic representations on the signage for each zone; for example, a picture of a peanut on the sign designating the color of tools intended for use with peanuts. In addition to written instructions, daily verbal communication is also vital. Any changes or revisions to the color-coding plan must be clearly communicated to all employees, from the top down.

It is a best practice to include your color-coding program in your official regulatory documentation. Many regulatory bodies require documentation of certain procedures, and color-coding can become a great advantage for your operation. While color-coding is not required for compliance with any food safety regulations, it is looked upon with favor by auditors. Including your color-coding plan in the facility’s Preventive Control or Prerequisite Procedures, which includes GMPs, SOPs, CCPs, and Non-CCPs, will go a long way in ensuring company-wide adoption, consistency, and compliance of the program. For facilities that must comply with HACCP or HARPC regulations, including color-coding on those plans is, again, not required but, a best practice. HACCP, or Hazard Analysis & Critical Control Points, is a food safety management system which helps to identify and control cross-contamination threats. Similarly, HARPC, also known as Hazard Analysis and Risk-Based Preventive Controls, also requires identification and control of risks in food processing facilities.

Here are some important things to remember:

  • Start at the top and go down
    • Communicate with all levels of employees to ensure complete implementation
  • Have good signage
    • Signs should have written and visual cues to identify the zone and where the tools are approved for use
    • Include a printout that gives details for reordering of tools, such as vendor, item number, manufacturer, etc.
  • Keep up with training
    • Consistent training programs for all employees will improve adoption and ongoing use of the program
  • Include color-coding on regulatory plans
    • Color-coding is looked upon favorably by regulatory bodies

10 Things to Know About Color-Coding: Regulators Love It

If your business is food processing, you are no stranger to government rules, regulations, and auditors.  Complying with federal food safety regulations is crucial to the success—or even existence—of your operation.  Keeping the auditor happy sometimes becomes a top priority (like the day before the audit), because no one wants to deal with the time, money, and marred reputation of a production delay or facility shutdown. If you’re looking for ways to strengthen the food safety efforts at your operation, we think you need to know about color-coding—because we guarantee that your auditor does.

An FDA auditor inspects a food processing plant for possible violations

Even though color-coding is not a standard rule or even a requirement, it is a practice that regulating authorities commonly favor. Regulatory agencies, like the Food & Drug Administration (FDA) and the U.S. Department of Agriculture (USDA), exist to provide guidance for food safety procedures and ensure the compliance with laws relating to the safety of the nation’s food supply. One such law is the Food Safety Modernization Act (FSMA) that is intended to transform the U.S. food safety framework from a reactive damage control approach to more of a proactive prevention of foodborne illness crises. FSMA Section 103 requires food facilities to prepare written plans to evaluate hazards and implement effective preventive controls. It stipulates several steps to ensure a true preventive approach to food safety.

Regulating authorities look favorably upon the practice of color-coding because it is a method that can easily be documented and followed by employees. A color-coding program that is written into a HACCP plan essentially becomes part of the facility’s SOPs (standard operating procedures). A HACCP plan is a written outline that identifies potential food safety threats and critical control points. Color-coding adds an extra layer of preventive protection in addition to other food safety efforts such as the hygienic design of buildings and equipment. Programs that are easily documented are also more easily communicated to employees, and the employees’ adoption of food safety procedures is imperative to the effectiveness of those programs.

Visiting authorities and customers will readily notice color-coding programs upon entering a processing facility, which is precisely why the approach is so effective. Segregating zones by colors offers quick visual confirmation that equipment is where it belongs and is not contributing to the unintentional transport of contaminants throughout the facility. When color-coding is utilized as part of a multi-faceted approach to food safety, it will add credibility to the effectiveness of the operation for regulators and customers alike.

With the new laws and proposed guidelines surrounding food safety, prevention is the preferred approach by regulatory authorities. And in the long run, prevention is a better business practice than reactive damage control. The old saying about closing the barn door after the horse is out comes to mind when thinking about recalls; it’s just better for everyone if a recall doesn’t happen in the first place.

News of recalls can travel in the blink of an eye in the rise of social media.  In that time, the success of your facility can be irreparably damaged. To safeguard your operation from the negative publicity of a food safety crisis, it is imperative to prevent recalls before they happen.  Monitoring any sort of cross-contamination threat inside the facility is fundamental, and color-coding is a simple way to keep those risks in check. To learn more about how color-coding can help, see our preventing cross-contamination blog article.

You can also download our checklist to see if color-coding can benefit your facility.