Last year, Dr. Doom and Ms. Gloom offered tips for facility maintenance and repair to assist facilities in being prepared for the selection of targeted sampling by USDA’s Food Safety and Inspection Service (FSIS) and/or Food and Drug Administration (FDA). We hinted that the agencies would target sampling on areas of poor design or in need of repair. In addition, we mentioned that sites related to flow and poor employee practices would also be on the radar screen for the agencies.
Flow
Traffic patterns should be designed to eliminate movement of personnel, product containers, product, ingredients, pallets, and refuse containers between raw and finished product areas.
It is “best case” if employees do not work in both raw and RTE areas. If this is not possible, then the employees must change outer and other soiled clothing, wash and sanitize hands, and clean and sanitize footwear when moving between areas. A commonly overlooked “employee” is the supervisor that goes from raw to RTE areas. All personnel – sanitors, visitors, maintenance, production employees, quality assurance, and supervisors need to ensure that they take into consideration the concern with going from the raw to RTE area.
The same is true for equipment. If it must go from the raw to RTE area, then special care must be taken to ensure that cross contamination does not occur. Consider, for example, squeegees that touch the floor. These have been demonstrated to be a high risk piece of equipment, yet we have noted many times that this simple piece of equipment can “magically” go from raw to RTE – ceiling to floor. These should be color coded for the area they belong in and not be removed from that area. Fork lifts have also been identified as a major culprit as many establishments can not afford separate lifts for each area. While establishments may only be able to afford one forklift, they should consider means to stop the lift at the RTE door and take product from that point into the room. Equipment used to actually process or package product should not be used for both raw and RTE product unless you have validated the equipment is clean with rigorous testing before use.
Employee Practices
Employee hygiene and sanitary practices are essential for controlling Listeria in the food processing environment. Handwashing and sanitizing is a critical step for all employees. Employees should wash hands each time they enter the processing floor and after using the restroom. If the establishment requires that gloves are worn, then the employees should dispose of the gloves anytime they touch something other than a food contact surface or product.
All employees should wear clean coats and hair covering when entering the processing area. Coats should be a different color for the raw and the RTE area. The coat should be removed when exiting the RTE area. Captive footwear is recommended, but if not possible, then footwear must be cleaned and sanitized prior to entering the RTE area.
Employees should not wear any garments or footwear from the RTE area into the breakroom or rest room or outside. All equipment must remain in the RTE area.
Sanitors that clean the raw area should not be responsible for cleaning the RTE area. Specific attention should be given to the timing of drain cleaning. The employee that cleans the drain needs to recognize the high probability of cross contaminating other equipment both during and after the drain cleaning process. Additionally, the rain gear worn by sanitors must be cleaned and sanitized! This means using detergent – not just spraying the jackets and pants off and hanging to dry.
Maintenance employees should have separate – and cleanable – tools for the RTE area. If this is not possible, then the tools should be completely cleaned and sanitized prior to entering the room.
Doom and Gloom cannot stress enough that Listeria does not just randomly appear in an establishment, and more importantly, it does not grow legs and walk around. Employee and equipment sanitation and flow are critical factors in ensuring that there is not a concern at the facility. The regulatory agencies will observe these practices when determining high risk sites on which to conduct sampling.
About “Dr. Doom”
Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters. Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator. During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations. While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health. Dr. Masters issued the initial Federal Register Notices for a systematic approach to humane treatment of livestock and poultry.
Dr. Masters was involved in the drafting of the training of inspection personnel on the Hazard analysis and critical control points (HACCP) and Sanitation Standard Operating Procedures (SSOP) regulations. She was the lead of the FSIS HACCP Hotline. In addition, Dr. Masters provided technical review for establishment’s hazard analysis, HACCP plans and supporting documentation. She started her career at FSIS as a public health veterinarian that had responsibilities for ante-mortem inspection, sanitation inspection and all post-mortem inspection responsibilities. She has a good understanding of what happens at the in-plant location, because she has spent many of long days working there.
About “Ms. Gloom”
In the attorney ranks at OFW Law, there is only one attorney who would raise a hand if all were asked if they had any “hands-on” experience in the operation of a Townsend “Frank-O-Matic” hotdog maker, producing bean sprouts for use in egg rolls or in managing a food facility sanitation crew. In fact, there are probably no attorneys out there who could raise their hands except Jolyda Swaim.
Prior to law school and OFW Law, Ms. Swaim spent years in the food industry, beginning as a microbiologist and Quality Assurance technician. In these years, she had direct charge of quality assurance, production, sanitation and consumer affair departments at various companies producing products from pickles, sauerkraut and barbeque sauce, to various meat and poultry products, to frozen entrees, egg rolls and pizza to spices and spice blends. Her last position at Sara Lee as Director of Food Safety had her auditing its facilities in the United States and Mexico to ensure facilities producing ready-to-eat products were following best practices in sanitation and product handling.
