By Lisa Lupo
The processing environment can be a primary source of food contamination. Because of this, FDA published draft guidance with recommendations for written sanitation procedures for cleaning equipment and floors.
While the guidance is focused toward control of Listeria monocytogenes in ready-to-eat (RTE) food facilities, the recommendations are applicable to all food and beverage processing plants as the foundation of a step-by-step environmental cleaning program.
To illustrate the application of the guidance in the processing facility, this article provides expert insights for each of the steps FDA recommends be identified in the written sanitation procedures for cleaning equipment and floors.
1. EQUIPMENT & AREAs
The type of food produced in the facility will have a direct impact on the equipment and floor sanitation needs. Some foods support growth of pathogens, while others do not; different foods deposit different types of soils; and factors such as pH of the product, the process it follows, and whether or not it will undergo further processing will all determine risk and cleaning needs.
“Different soils are removed by different chemistries,” said Sterilex Field Sales Director Katie Moore. “So sanitarians can optimize their cleaning through choosing the correct cleaners/sanitizers for the environment and soils present.” For example, she said, the way you would clean peanut butter from a surface may be different than how you would remove flour. And if the product is RTE, it will automatically have higher standards for cleaning and sanitation because the food will be consumed without the consumer performing a kill step, Moore said.
Additionally, the soil loads of dough, produce, and meat are very different, and even within a category such as protein, there are many different soil loads, explained Best Sanitizers National Account Manager April Zeman-Lowe. Types of soils include inorganic (such as hard water, metallic, or alkaline deposits) and organic (e.g., animal fats, vegetable oils, carbohydrates, and food residues) — each of which will impact the specifics of cleaning.
As relates to floors, Tennant Company Marketing Manager Ian Alexander explained that the floor type, square footage, and area to be cleaned will have an impact on cleaning and sanitizing decisions and equipment to be used. For example, he said, “If a single machine is being used across different food production lines, that machine should be cleaned before its next use to avoid cross-contamination.”
2. EQUIPMENT DISASSEMBLY
Because liquid, crumbs, bacteria — and pests — can get into the cracks and crevices of production equipment, it should be disassembled as necessary to make all parts accessible for cleaning and sanitation. “If the equipment can be disassembled, it should be done at each sanitation to prevent any harborage of organisms or food soil build-up,” Moore said.
Before disassembling any equipment, the tools you will be using should be cleaned and sanitized. Once equipment is disassembled, all visible matter should be removed and all areas cleaned. Some soils may require agitation or physical removal by manual or mechanical action, Zeman-Lowe added. Once completely clean, all parts should be rinsed and inspected, with a recleaning and rinse of any areas that were found to have been missed. Next, she said, “Sanitize using appropriate EPA-registered surface sanitizer spray or foam, or soak in containers with sanitizer for the recommended time and at the appropriate concentration. No-rinse, highly evaporative surface sanitizers might be appropriate for water-sensitive areas.”
Before reassembly, hands, gloves, and tools should be cleaned and sanitized, then the equipment reassembled and a visual inspection, swabbing, and documentation conducted for validation and verification.
In some cases, it will be necessary to periodically disassemble the cleaning equipment itself. For floor-cleaning equipment, Alexander recommended that the tanks be rinsed and drained after every use, but noted that the brush and squeegee components do not need to be thoroughly cleaned as frequently. But, he added, “If low-foaming detergents or caustic sanitation chemicals are being used, the frequency of rinsing and cleaning the machine components should increase.”
3. CLEANING FREQUENCY
There is no one-size-fits-all answer for how often sanitation should be conducted, Moore said. “The real answer is that sanitation should be conducted however often is necessary to produce safe, quality food products. Safety is determined by a number of factors, but a robust environmental and food product-sampling program can be one way that processors ensure they are well enough, and often enough.”
Zeman-Lowe sees daily cleaning as needed. “Every 24 hours a plant runs product, they should be cleaning and sanitizing food contact surfaces,” she said. “If risk assessment determines a more frequent schedule, follow accordingly.” She gave the example of a plant which cleans and sanitizes food contact surfaces and lines twice a week, with a compressed-air blow-off for cleaning and sanitizing on the other days. “The days that do not include chemical cleaning of food contact surfaces increase the risk for bacteria to colonize,” she said, adding, “Sanitizing in the presence of organic matter is ineffective, which makes daily cleaning essential so that sanitization is effective.”
Alexander advised a similar schedule for floor cleaning. “The recommended cadence for floor cleaning is daily or at the end of each shift,” he said. “This will help move the facility to a higher floor-care standard by more effectively removing embedded soils, cleaning chemicals, and residual water from the floor.”
4. CLEANING TOOLS (Type and color coding)
“Brushes, pads and scrapers are all necessary tools, but should be color coded for the application, so a floor brush, for example, is not used on a food contact surface,” Moore said, adding that processors also should have a program to properly sanitize and maintain cleaning tools.
Additionally, chemicals in primary and secondary containers need to be properly labeled, with color-coded hang tags on secondary containers, and appropriate secondary labels on foamers and sprayers for chemical and sanitizer use. “Designating a different color to each zone will help prevent cross-contamination, and having all cleaning tools properly labeled and coded correctly is a best practice,” Zeman-Lowe said, recommending that this be reinforced with signage, training, and retraining for new or temporary staff.
To maintain cleaning equipment, foreign chemicals should be rinsed from tanks, brushes, and squeegee components, Alexander said. “Over time, exposure to these chemicals could expedite the wear and tear of different parts and consumables needed to clean floors efficiently and effectively.”
5. CLEANING SOLUTION (Type, concentration, pressure, time and temperature, and flow rate/velocity, as applicable)
Time, action, concentration, and temperature elements work together, Zeman-Lowe said, so a reduction of one element will lead to an increase in another. For example, using a higher water temperature can increase the chemical activity on a surface, so an increase in temperature can result in a decrease in concentration. Additionally, she said, “Cleaning chemical selection can be driven by the type of soil, water characteristics, how the cleaner will be applied, to what areas of the plant the product(s) will be applied, and who will perform the cleaning and sanitizing.”
The cleaner or sanitizer should be designed for the purpose for which you are using it, have the application you are conducting listed on the label, and be EPA registered. “Concentrations and contact times will vary by product, but should be stated on the label,” Moore said. “In general, higher water temps are better at removing soils,” he said, but following the labeled instructions is key, as temperatures that are too high in temperature can bake on soils or break down cleaning chemicals, while those that are too low can make chemicals ineffective or reduce their ability to remove soils.
A CULTURE CHANGE. “The biggest change that often needs to be made may also be the hardest...and that is one of culture,” Zeman-Lowe said. There needs to be top-down support of cleaning and sanitation plans and procedures. Additionally, changes will require a departure from current practices that may include increased costs for chemicals, equipment and energy, along with water and effluent considerations, education and training, and an increase in hours allotted for cleaning and sanitation. “To ensure effectiveness, verification and validation of these practices must also be incorporated into the equation, and personnel and resources allocated.”
“In addition to having the proper chemicals and procedures,” Moore said, “I think plants need to recognize that it is not a perfect world. You will never eradicate Listeria.” Rather, he said, it is a constant process of monitoring and control — recognizing areas of risk and proactively putting procedures in place on a preventive maintenance basis.
The author is Editor of QA and can be reached at firstname.lastname@example.org.