A 10-Baton Relay

In the March/April issue of QA magazine, we discussed red flags that wave for auditors as related to pest management. In this issue, we again focus on red flags, providing 10 tips for identifying and correcting sanitation discrepancies.

Because a recall can ruin your name, “a plant’s sanitation program is one of the most important parts of a product’s and business’ existence,” said Adel Makdesi, corporate senior microbiologist for Zep Inc.

In fact, Kent Bruns, DCS Sanitation Management director of quality assurance, has seen a rise in companies’ attention to their sanitation programs as a result of the increased publicity of recalls, particularly in relation to the breaking down of equipment by ready-to-eat food plants.

“Instead of looking at sanitation as an expense, they may also look at it as an insurance cost,” said DCS President Tom Murray, noting that the increased focus on GFSI standards and audits are also having an impact. However, companies should not let such reaction play out in quick fixes, rather they should be conducting internal audits of their full program for gradual, but continual improvement.

Start with the areas that are most deficient, resolve those immediately, then diligently work toward those where there is some activity but results are not as effective or efficient as they could or should be, Murray said. “All you have to do is get better.

“It’s a marathon, it’s not a sprint, because you still have to get the plant clean every day,” he added. “It’s managing the business every day, then taking a step back to figure out how you can improve on a regular basis.”

A 10-Baton Relay. With the tips provided by Zep and DCS, this marathon can be thought of as a 10-pass relay, with the baton passing through:

1. Leadership. “Every effective sanitation program starts with plant leadership,” Murray said. “The person in charge of the facility needs to be playing an active and/or significant leadership role in the sanitation practices.”

Managers should be visible in the plant on a regular basis, Makdesi agreed. They should periodically sit in on sanitation meetings, visit the plant during downtime sanitation, understand what the sanitation team does, and ensure they have enough time to do what is needed.

Plant leaders also need to actively encourage suggestions for improvement, even though they may not always like what they are hearing, Murray said. For example, if the sanitation team doesn’t have the time or resources it needs, these workers and department managers need to feel comfortable saying so. “Bad news is okay as long as we do something about it.”

2. Written Procedures. Every plant is different, thus their sanitation procedures and chemicals will be different. As such, the master cleaning schedule should not only be maintained, but also regularly validated and updated. In addition to outlining of procedures for basic cleaning, written documents should include procedures for breakdown of equipment, including what needs to be broken down, how to do it, and how often it should be done.

“Are your master cleaning schedule items and frequency as good as they should be?” Murray asked. If it is monthly, does it need to be weekly; or if weekly, could it be monthly instead? In addition, managers should periodically audit the schedule to verify that the items are being completed properly.

When working with third-party sanitation companies, it is particularly important that plant workers follow their recommended SSOPs, Makdesi added. Too often, workers will continue to do things as they always have rather than follow a new program customized for them.

3. Education. Plant managers should ensure that their sanitation teams understand not only the how of cleaning but also the why. “If they don’t understand why we do something, they won’t do it,” Makdesi said. “But if you make them understand what happens if we don’t do it, then they will.” Makdesi cited the example of using black light to show the germs that remain on people’s hands after an incomplete washing. Even though their hands look clean, microbes remain. “You need to make people see it in their minds,” he said. “They need to see and understand why they need to do it; to understand the root cause of why we clean and sanitize.”

4. Equipment Breakdown. Is your equipment being broken down thoroughly enough and frequently enough? Are you getting into all the niches and harborage areas? In ready-to-eat food plants, Bruns said, “The detail and intensity of equipment teardown has increased significantly.” If it had previously been done quarterly, he is now seeing it done monthly; monthly has become weekly; and weekly, daily. “Now plants are tearing down to the bare bones even on a daily basis,” he said.

5. Cleaning. To audit your regular cleaning processes, Bruns said, start by looking at teardown of equipment, then move on to the basic steps of cleaning: dry pick up; first rinse to knock down the solids and soil load; foaming inside and outside equipment; scrubbing of heavily soiled areas; application of sanitizer; rinsing; and a final pre-operation inspection.

To regularly validate your process, continuous improvement audits should be conducted at least quarterly. “Then assign a champion who is in charge of the things that were identified on the audit, and making sure it happens,” he said.

6. Outside the Box. When auditing your plant for cleanliness and sanitation, Makdesi said, “look outside the box; that’s the main thing.” Look in unusual, out-of-the-way places, niches, and hollow areas. “All quality control managers should have a flashlight,” he said. “Don’t wait for problems to occur. Be proactive. Use a flashlight and look under equipment, in cracks, behind walls. Look anywhere you can’t see when you walk through the plant.” One example Makdesi gave was a ceiling cooling unit. Too often, a worker will look up from floor level, see that the unit appears clean, and sign off on it. Instead, he said, get a ladder. “You truly have to go up and verify it.”

When trying to locate the source of a persistent problem, Bruns said, it is critical to spend most of your time “looking up” and “looking under” to find the source. “Take the blinders off and look around,” he said. “You have to be open minded because you don’t know what you are looking for.”

7. The Right Chemicals. If you are not using the right chemical or the right amount of a chemical, you could be introducing hazards through your cleaning program. Not using a high enough concentration of a chemical can make a microbe resistant to it, Makdesi said. “It will wake up the microbes to say, ‘This is not killing us,’ so it will multiply and make babies that are resistant to it.”

Another example Makdesi gave is that sanitation personnel are often shocked to find out that chlorine in a cleaning product doesn’t act as a sanitizer. “When you mix chlorine with detergent, it won’t sanitize,” he said, explaining, “It will clean, but it won’t kill the microorganisms. Chlorine kills only when it is mixed with water. Ninety percent of workers and sanitation, quality assurance, and quality control managers don’t know that.”

Sanitation workers also need to take care in mixing chemicals. Although they should have a basic knowledge of the cleaners and chemicals, he said, “they are probably not chemists and don’t understand how they interact”—and that can be a hazardous combination.

8. Decontamination Equipment. Just as the wrong cleaning chemicals can be hazardous rather than helpful, so too can the equipment in place to prevent cross contamination actually cause contamination if it is not maintained. As people walk through footbaths, the footbaths accumulate organisms from their feet—as they are meant to do. After a while, if the solution is not replaced, the organic matter will absorb the sanitizer, robbing it of its efficacy, “and it will become a source of contamination,” Makdesi said.

9. Maintenance Involvement. “Maintenance and sanitation are joined at the hip whether they like it or not,” Bruns said. It is critical that structural elements be maintained, he said, citing the example of a pinhole leak in the roof that could cause dripping down a pipe and onto a food surface. It may look like condensation, but actually be contaminated moisture.

Air flow can also be a critical component, and is one that is often missed. If sanitation is not working together with operations, negative flow could cause contaminated air to flow into the process area.

10. Follow Up. In every situation, whether reviewing the notes from a self audit or a third-party audit, “it is very important to follow up,” Makdesi said, adding, “Usually recommendations are very critical for the safety of the product.” If you are the one making a recommendation and see that it is not being followed, Makdesi recommends that you continue noting it over and over until it is done.

In follow up, as well as every one of the 10 steps, Murray said, it comes down to ensuring that you have a living document and active leadership. “You can have all the pieces in place, but you have to drive them from the top.”

The author is Managing Editor of QA magazine. She can be reached at llupo@giemedia.com.