This is the second in a series of articles to help you quickly get up to speed on food safety and ensure you invest in the most important details when planning and during construction or revising existing production and processing facilities in Oregon.
By Rachel Montgomery
While non-food-contact surfaces are critical to the form and function of a facility for edibles, food-contact surfaces are at the frontline of food safety. Equipment purchases have to ensure hygienic design and permit efficient disassembly for cleaning, scrubbing, inspecting and sanitizing.
Planning and investing in food-contact equipment with an eye to effective and efficient cleaning is not only key to passing an initial inspection by the Oregon Department of Agriculture and being able to produce product for sale, effective cleaning is also essential to protecting your brand for the long haul by preventing contamination of your products.
Take a peek at recall statistics and reports from the FDA Reportable Food Registry for products similar to those marketed as edibles, and you will see that microbial contamination and undeclared allergens top the list. Ineffective cleaning can make edibles vulnerable to the presence of pathogenic microbes and to the carry-over of allergens, such as wheat, soy, tree nuts, peanuts or milk, from ingredients used on the same equipment, leading to recalls.
Investors may complain that hygienically designed equipment is too expensive of an investment, but excessive time for cleaning inappropriate or damaged surfaces, downtime for equipment repairs or replacement and any actual recalls will be more expensive and potentially damaging to your company and brand’s reputation.
Smooth and Easily Cleanable: Food-Contact Surfaces
Food-contact surfaces include all equipment and utensils that are used in producing or packaging food.
Closure/sealing of all junctures to prevent harborage and allow cleaning is part of the “smooth surface” and “easily cleanable” approach and more details are in the ODA checklist and the Food Safety Plan review document. Also, materials which are smooth and easily cleanable are the basis of hygienic design for food contact surfaces and essential to following the Food Safety Plan requirements issued by the ODA’s Food Safety Division, and new federal rules under FSMA which ODA references on its website.
Good Manufacturing Practices under FSMA specify that food-contact surfaces of equipment and utensils must be corrosion-resistant and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds, sanitizing agents, and cleaning procedures. Note the “must” terminology above, which is upgraded from “should” in the prior Good Manufacturing Practices.
Preventing allergen cross-contact is another new requirement, and smooth, easily cleanable surfaces are essential to preventing allergens from remaining on a surface and being introduced into another product not intended to contain allergens.
Equipment Vulnerabilities and Product Characteristics
Purchasing equipment with corrosion-resistant surfaces such as stainless steel is the first step to ensuring surfaces remain smooth for efficient and effective cleaning. Consider your product characteristics and formulation, including pH and salt concentrations, to ensure that the equipment can withstand product contact over time — inquire with equipment suppliers to determine equipment vulnerabilities to products as well as equipment requirements for cleaning chemicals, temperature and physical scrubbing.
Go ahead and consider all formulations you may produce and how difficult it will be to remove your particular edibles from equipment in the cleaning process. Viscosity and other product characteristics, including protein and fat composition, make cleaning more difficult. Will inclusion of specialty chemicals such as enzymes provide product removal without harsh impact on surfaces? Ask chemical cleaning suppliers to evaluate their products against your product and equipment surface material.
The evaluation is done by first placing your product on surfaces under extreme conditions of time and temperature for your process. Cleaning agents are then tested to determine the effective conditions for removal of your product without damage to the “smooth surface” of your equipment. Vendors will want to work with you to determine optimal concentrations, time, temperature, and other factors, to ensure you will choose their cleaning products for purchase initially and continue with them long term.
Also ensure “smoothly bonded seams” and “closure/sealing of all junctures” as mentioned in the regulations. Purchase equipment with hygienic design and the ability to be easily taken apart for cleaning, scrubbing, inspecting and sanitizing. Having easy to disassemble equipment precludes involvement of maintenance personnel and thus reduces downtime. Equipment operators should be able to perform routine disassembly and troubleshooting.
Again, investors may complain that hygienically designed equipment is too expensive of an investment, but hygienic equipment is one of those “pay me now or pay me later” scenarios. Equipment designed for easy and thorough cleaning makes for efficient process turn-arounds day in and day out from the first production run. If equipment is not cleanable, you’ll face costly production downtime for issues of microbial contamination or allergen cross-contact.
Since there are other requirements to consider for an ODA inspection and product recall prevention, the next article in this series will focus on best practices for placement of areas within a facility to ensure the best flow, prevent contamination and ensure compliance with cleaning and maintenance requirements.