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.

ABC’s of Manual Cleaning Part VI: Regulatory and Standards Expectations Regarding Manual Cleaning

Part VI

Part five of our blog series focused on allocating various manual cleaning responsibilities, and on how to create a robust hygiene and sanitation culture within an organization. In this blog, we’ll look at the U.S. regulatory requirements, key industry, and global standards, and the integrated sanitation best practices that would support a manual cleaning operation.

Understanding the U.S. Regulatory Context

Cleaning and sanitation are key regulatory requirements in the food industry. According to recent FDA estimates, about 1 in 3 U.S. food recalls may happen because of poor sanitary practices, and a significant proportion of these relate to Salmonella and Listeria monocytogenes cross-contamination incidents within a food plant.

The 21CFR 117 FDA regulations are clear about the importance of regular cleaning to prevent allergen cross-contact and cross-contamination of food products. Section 117.35 on “Sanitary Operations” clarifies that the food-contact surfaces of equipment must be cleaned and sanitized as necessary, and that non-food contact surfaces must be cleaned regularly.

Moreover, FSIS legislation based on Federal Meat Inspection Act, Poultry Products Inspection Act, and Egg Products Inspection Act also emphasizes proper cleaning and sanitation to ensure the sanitary conditions necessary to produce safe food. Cleaning surfaces in these establishments will need some efficient and effective form of mechanical agitation using manual cleaning tools to remove rigid soils, e.g. surface biofilms.

Industry and Global Standard Expectations

GFSI-based certification standards have provided a series of benchmarks for harmonizing global food safety programs to an agreed-upon level of industrial expectation. The common standards focus greatly on using the right types of cleaning tools, as stated:

  • According to BRC Global Food Standard – Food Safety, Section 4.1.1.6, “Cleaning equipment shall be hygienically designed and fit for purpose, suitably identified for intended use (e.g. color-coded or labeled), cleaned and stored in a manner to prevent contamination.”
  • SQF Code, Section 10.2.9.8 states: “All equipment cleaned after use or at a frequency to control contamination and stored in a clean and serviceable condition to prevent microbiological or cross-contact allergen contamination.”
  • FSSC 22000 – ISO 22002 Prerequisite Programs on Food Safety – Part 1: Food Manufacturing, Section 11.2 on ‘Cleaning and Sanitizing agents and tools’ states: “tools and equipment shall be of hygienic design and maintained in a condition which does not present a potential source of extraneous matter.”

As explained in part one of our blog series, during the sanitation process, manual cleaning of surfaces and equipment becomes inevitable, since, according to 3A-SSI Standards, if the food-contact components of equipment are not designed for CIP or other automated methods of cleaning, these parts should be cleaned and sanitized manually.

Embracing an integrated sanitation approach

Sanitation is not just about cleaning and sanitizing surfaces and equipment but is a holistic risk-based methodology aimed at significantly minimizing or preventing allergen cross-contact and/or microbiological and foreign material cross-contamination incidents within a facility. Illustrated below are the components of an integrated sanitation approach:

 

In a nutshell, here is a good list of industry best practices that may be integrated into a sanitation program:

  • Color-coding – Use total-color tools to differentiate between hygienic zones, or allergen zones, or to distinguish between tools used for cleaning food-contact and non -food contact surfaces.
  • Hygienic Zoning – Implement a good zoning approach that separates raw and finished products, allergen products from non-allergen products, and thus prevents, or significantly minimizes, cross-contamination incidents. Proper zoning standards also support environmental monitoring and control programs.
  • Hygienic Design – Facility surfaces, equipment, utensils, and tools of a hygienic design and construction are more quickly and easily cleaned after use and pose less risk of contaminant harborage and transfer.
  • Process Flow Management – Manual cleaning and tools streamline processes because, in part, proper selection, storage, cleaning, and care of tools prevent contamination incidents in a food plant.
  • 5S – Workplace organization methods that incorporate elements of Sort, Straighten, Shine, Standardize, and Sustain into a manual cleaning program will be of benefit.

Summary

Manual cleaning, as an inevitable part of FDA FSMA Sanitation Control; FSIS-USDA regulatory requirement; and global and industry standard expectations, provides a proactive measure that should not only prevent or minimize food recalls, but also go a long way towards avoiding or reducing site inspection violations and foodborne illnesses.

 

Selected References: