Are You Overlooking Important Food Safety Issues?

By Cliff Coles


With food safety, the little things matter. While a facility may seem clean overall, successful sanitation and prevention of foodborne illness is about paying attention to the minute details—details that are easily overlooked. Microbes like Salmonella, E.coli and Listeria don’t always find their way into processing facilities through obvious, glaring sanitation problems. From a closer, microscopic viewpoint though, a good food safety audit can point out the little things that could cause big problems. While at first some of these details may seem a bit overly cautious, it’s always important to err on the side of safety when it comes to protecting the health—and the lives—of your customers.

Setting Up a Food Safety Audit
A food safety audit needs to be a meeting of the minds between the auditor and the facility management. Both parties need to understand the ultimate goal of the exercise: to ensure the highest level of food safety possible. The facility management would usually prefer to get the audit over with as painlessly as possible without a list of fixes that break the budget. While the auditor needs to respect financial constraints—let’s be perfectly clear—there should be no compromise for food safety. There may, however, be more than one way to achieve it.

Regardless of an individual’s auditing technique, the auditor must be able to provide a virtual tour of the facility through the written word. If the audit is intended to be shared with others, it’s essential to pick and choose those words carefully, realizing that the reader may have never been in that processing facility, let alone any processing facility. The auditor needs to be part microbiologist, part process engineer, part production manager, part maintenance person, part salesman and counselor to all departments. Auditors have an obligation to teach and to share their experiences seen through other audit situations. This position also requires the ability to call it like you see it and to be firm on the must do’s and creative when it comes to should do’s. The auditor should provide common sense options as to how the facility can meet the expectations of the audit and as well as the regulatory requirements for providing safe food.

There are certain fundamentals that must be addressed in every audit, yet these are often overlooked. At a minimum, an audit should take a close look at the physical plant and grounds, equipment, process and storage environments, water, drain and waste systems and pest control.

Outside the Facility—The First Line of Defense
Upon arrival at many facilities, several issues are immediately apparent before you even enter the doors. These issues are often overlooked because they are outside the facility—however, some situations actually invite pests to come feed right at the very areas you are trying to protect. Better to have the first line of pest defense at the fence lines and a second line at the building. Having stacks of dirty crates, empty cans, old decommissioned equipment in the yard and collections of things that serve no purpose in remote areas that are unattended will only provide comfortable living quarters for pests. Even the pretty trees close to the loading dock can harbor birds, which pose a multitude of food safety hazards. While removing a tree may not be something management wants to do, the problem can also be addressed by adding colorful foil strips that move with the wind, also called “daddy long-legs.”

From management’s perspective, pest control represents more overhead and a big expense. However, it’s important to know that a lack of pest control could potentially affect the product’s conformance to regulatory Defect Action Levels—the levels of food contamination from sources such as insects, rodents, and other “foreign matter.” It can also adversely affect microbiological levels in the product.

Equipment located outside the facility can also create food safety issues. For example, upon examination, an outdoor produce-washing system was found to have hollow framework with open ends which can harbor insects and microbes. Additionally, the single conveyor belt on the washing system was severely frayed. Frayed belts can never be thoroughly cleaned and can create a microbiological issue as well as a foreign material concern for the finished product. Sitting above the washing system was a motor with no oil-drip collection pan. Furthermore, the motor and some food-contact equipment had been painted quite some time ago and the paint was now flaking intermittently into the wash tank. The frayed belt, drip pan and the flaking paint pose what seem like obvious maintenence issues, but sometimes it takes a set of outside eyes to see what others who walk by every day miss.

Keeping It Clean Inside
Preventing outside contaminants from coming inside is of highest importance, yet systems are often not set up with this in mind. First, it’s essential to be able to distinguish employees assigned to outside non-process functions and raw material handling from those assigned to indoor processing responsibilities. Cross-contamination by employees that are out of the assigned work station is a common occurrence. Management needs to be able to identify at a glance any employee that is “out-of-place” and the easiest way to accomplish this is through color-coding. The color-code policy incorporates specific uniform colors or color-coded hairnets to identify workers by their specific
assignments.

Another way outside contaminants make it inside is the drain system. In one facility, spent wash water from the initial produce cleaning was being conveyed through a pipe and into open drains within the process room. One particular drain ran along the floor a few feet beneath the conveyor that discharged the washed fruit into clean baskets.

Besides rerouting the drain, there are other less costly alternatives for situations such as this. One is drain sanitation. All drains have a P-trap that is constantly filled with water to prevent sewer gas from escaping back into the atmosphere. The water in the P-trap is by definition stagnant, and stagnant water is a source of all types of bacteria. Air currents caused by pedestrian traffic, forklifts and pallet jacks will cause the atomization of the water droplets containing the bacteria to become airborne and contaminate the environment. A simple solution to the P-trap issue would be to place quaternary ammonia rings (quat rings) in the drains. However, the things we take for granted in the United States don’t always exist outside this country. Fortunately, chlorine bleach is usually universally available and despite its corrosive nature, a quick flush of the drains daily will go a long way to minimize cross-contamination.

Other Often Overlooked Food Safety Tips
Prevent Contamination from Employee Accidents. Sharp knives and workers doing the same task for hour after hour can lead to a dangerous scenario. It is important to find out if: a) there is a plan in place for what to do with the product, the equipment and immediate environment in the event that a worker becomes seriously injured and bleeds at the work table and b) do the employees know what this plan is? Having the plan posted in a high-use area tends to keep everyone aware.

Choose Safe and Easily Sanitized Processing Equipment. Some materials used in processing are more challenging to sanitize and pose more safety concerns than others. For example, some drying facilities use wood trays that are held together by screws and use screening material similar to what is used for home screen doors. Loose screws and frayed screening pose obvious issues, and wood is known to harbor microbes. In fact, in an ABC News segment aired earlier this year, “Pallet Wars: Wood vs. Plastic for Food Safety,” researchers found that as many as 43 percent of the wood pallets in one study contained E. coli, Salmonella and Listeria. The fact is that a dirty plastic pallet probably contains about the same amount of microbes, but that plastic pallet can be cleaned much easier and may not break as easily as the wood pallet. Realistically, replacing all the wood pallets in a facility will never happen, but using only slip-sheeted pallets for storage and keeping wood pallets out of standing water will go a long way to mitigate microbiological problems.

With the produce drying facility, plastic was not an option because it would melt, yet the cost of switching from wooden drying trays to stainless steel was overwhelming. However, everyone needed to step up and realize that it costs money to be compliant and this was not one of the issues where compromise was possible. To solve this issue, one import buyer worked with the facility management to negotiate a very modest price increase to cover the cost of replacing a few wood trays with stainless trays each month. There was a clear understanding that all of the wood trays would be eliminated from the operation sooner than later. As the wood trays were being replaced by stainless steel, the remaining wood trays were examined and their condition documented before each use (after the stainless tray inventory was exhausted). By assigning accountability for documenting the condition of the wood trays, the risk of contamination was greatly reduced and the management was satisfied with the solution.

Be Enlightened on Your Lighting. First, all lights within a food processing facility should be enclosed in plastic in case one breaks. Glass shards and other contaminants such as mercury from lighting systems can cause huge problems. Also, look at where spare bulbs are stored. In one facility, a supply of the mercury-filled lights was stored in an uncontrolled area of the production plant, sitting precariously on empty jute bags that would eventually be used for shipping the product to the importer.

Keep Up on Ladder Sanitation. Look at the extension ladders that are used in every facility. Invariably, they are dirty. Most have never been cleaned since they were brought into the plant and the ladders are used throughout the plant. The problem with ladders, regardless of size, is that most people will climb a ladder by placing their hands on the steps—the very steps where dirty shoes have been previously. Every ladder needs to be assigned a stenciled number and be on a master sanitation list.

Additionally, the facility has to have a contractor ladder and shoe policy that requires contractors to have their ladders cleaned and sanitized by plant personnel before bringing them into the facility or to use a clean and sanitized ladder provided by the facility. Contractor shoes need to be at least cleaned (and hopefully sanitized) before they have access inside any facility. I have personally seen contractors enter facilities with ladders that had clearly been used on dairy farms, based on the debris clinging to their ladders and shoes.

Make Sure Chilling Units Are Not Hotbeds for Contamination. Another item to never overlook is the chill box and any condensate collection pan associated with it. The condensate collection pan in a chilling unit will be one of the single largest reservoirs for Listeria any food operation will have. Most collection pans are not pitched correctly, allowing the water to pool and become stagnant. Then microbes are spread throughout the atmosphere of the facility by fans. Regardless of whether the unit is properly pitched or not, inspect the drain line to ensure that it is being properly routed to a drain and not sitting on the floor behind the chill boxes. The condensate drip pan is another good area to place either a quat ring or powdered sanitizer once the pan has been taken down, cleaned and sanitized. A water sample from the drain line will be helpful in assessing if Listeria is a problem and a visual examination of the back of the cooling unit will indicate how frequently, if ever, the unit has been cleaned.

Mitigate Microbes with Your Maintenance Crew. One last overlooked cause for microbiological cross-contamination is the maintenance workers and their tools. Maintenance employees and their tools usually have unrestricted access throughout the entire process facility. Because of this, maintenance personnel have to be included in the food safety program and must be aware of their responsibility in preventing microbiological contamination. It’s essential that maintenance employees understand that the same wrench they are using to fix a piece of food-contact equipment was not previously used to fix a toilet fixture or sewer pipe. Instituting a program that requires the wiping of all the tools with a disposable alcohol swab prior to and after each use will mitigate microbial contamination and will not cause rusting.

In Conclusion
The auditor needs to look up, look down and look around 360 degrees when auditing. There really is no one-size-fits-all audit template that can be used. The auditor needs to rely on the “sixth sense” that comes from experience and previous situations.

Overall, the food industry around the world does a lot of things right. It has managed to feed the masses with very few glitches despite a very complicated and regulated system. All indications point to the continued growth and expansion of the organic food industry bringing more demands and regulations that will require more creative and cooperative ideas. However, the food industry needs to be more pro-active in sharing the experiences that highlight food safety with the growing population of smaller organic manufacturers. A well-conducted, constructive audit can accomplish just that. The words spoken by the scurrying Queen of Hearts to Alice in Wonderland are just as applicable to the food industry: “We have to run this fast just to stay in place.”

Cliff Coles is the founder and president of California Microbiological Consulting, Inc. He has authored and co-authored several publications related to quality control and microbiological issues in the food industry. He conducts food safety audits throughout the world for many nonorganic and organic companies, including Multiple Organics and Earthbound Farm and is a certified GMA-SAFE auditor. He is a member of several corporate food safety committees and is the process authority for the Almond Board of California and a participating expert in FDA-sponsored food industry surveys. He can be contacted at cmlkcoles@aol.com.