Food Safety During a Remodel or Redesign

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Bobby Love has seen his share of redesigns and refreshes.

While the director of global food safety, quality assurance and regulations at Phillips Foods in Baltimore, Md., has been part of a couple large production facility renovations, he considers any change to a production line, such as the introduction of a new product, to be a redesign of sorts.

“I’ve been into hundreds of those,” Love said, noting those are times to make sure everything is up to standard when it comes to considering food safety and sanitary design. “Every time you’re bringing up a new product, you’ve got to go back to your HACCP, you’ve got to look at your equipment … you’re having a look at your flooring.”

Furthermore, Love said, facility redesigns, expansions and refreshes are much more common than construction of brand new facilities in his experience.

“Most times it’s a rehab, facility takeover over a renovation,” he said.

Good sanitary design isn’t an investment, it’s a necessity. And whether it’s a redesign or refresh — or like Love said, a new product — it should be treated as an opportunity to rethink, retool and reinforce sanitary design.

“It’s a ‘have to,’ not a ‘want to,’ ” Love said. “Listeria is one of FDA’s and USDA’s top priorities. If you can’t clean thoroughly or ensure you’re free of material contamination, you’re done. Visual clean is not clean.”

Blind spots in sanitary design — such as hard-to-clean areas behind items that are mounted too closely to a wall, or under tables and equipment that don’t provide enough clearance from the floor — are where pathogens and more can hide.

“But it’s more obvious in a tear in a stainless-steel table or a hole where a bolt was,” Love said.

Paul Storsin, director of quality and food safety at Aladdin’s Baking Co. in Cleveland, Ohio, which is designing a new production facility making croutons and pita chips, said companies need to get better at sanitary design because regulations are changing and getting stricter.

“You have to have the good food safety policy in place,” he said.

For his part, Rob Mommsen, senior director of global quality and food safety at Sabra, said that as sanitary design improves in equipment, such as fillers and mixers, what becomes most important is the layout of a plant.

“That’s critical,” he said.

Love, Storsin and Mommsen filled us in on best practices when it comes to food safety during a redesign.

Expect the unexpected.

Any fan of home remodeling shows such as “Property Brothers” or “Fixer Upper” know there’s almost always some unknown hiding behind a wall that’s going to implode the project’s budget. It’s no different in food safety.

“The common theme is always, ‘It is going to cost this much money,’ ” Love said. “And then they start ripping up the floors and they’re like, ‘Oh, my God, it hasn’t been done in 100 years.’ It’s the same exact thing here.”

That’s why, he said, it’s important to make sure you have room in the budget for “have tos” in addition to the “want tos,” which means educating upper management.

“They’ve got 1,000 things on their plate right now,” he said. “We need to sell these things. We need to educate them regularly.”

HACCP readiness.

The Food and Drug Administration’s (FDA) Hazard Analysis Critical Control Point (HACCP) management system, which covers analysis and control of biological, chemical and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product, is an important component to sanitary design. And Love said it’s important to document each step, following the guidelines, in a new process or production line before starting to build it out.

“You need to start looking at the hazards at each step,” he said. “So that’s going to rely on your equipment, that’s going to rely on your flooring, that’s going to rely on your ceiling tiles.”

Kick the tires on new equipment.

Whether it’s a new product line, a redesigned space or an expansion, you probably have some new or reconditioned equipment coming in. Make sure you give everything more than a cursory glance. Inspect fittings, bolts and more. Run the equipment to make sure it’s up to snuff.

“Make sure what you’re getting is good stock,” Love said. “Everybody can sell something, but you start running it and oil spews out. ‘Oh, yes, it does that.’ Nope.”

And before you buy, design or redesign equipment, make sure it’s easy to clean inside as well as out, with lots of openings. Storsin used the example of an intermediate proof box used in baking. Instead of designing it with doors that open outward, he and his team designed one with a 10-foot window that lifts up.

“So you can actually get in there, and don’t have to worry about not getting the little nooks and crannies when you clean,” he said.

Room to clean.

Before installing anything — equipment, conveyors or storage racks — make sure there’s enough room behind, below and above it to clean.

For anything on or near a wall, Love recommended making sure there’s 9-18 inches of clearance. Anything on the floor should have at least 6 inches of space below it.

“You have to design it … so you can clean behind, [under] or remove every item,” Love said. “People get all wild, and they start putting up posters, and they start putting up devices to hang coats and the walls become crazy — nothing is to be put up unless it’s a cleanable surface.”

Storsin also added not to make anything too tall, to avoid having to get up on a ladder to clean it.

“Make it sanitation friendly,” he said.

Zone defense.

The concept of zones to break out different areas and items in a food processing facility should be familiar, but it’s one that isn’t always followed.

Zone 1 includes all food contact surfaces and utensils, such as conveyor belts, tabletops, knives and more — anything with direct contact to product. Zone 2 covers anything in close proximity to food contact surfaces such as walkways, carts and equipment control panels. Zone 3 covers storage areas, catwalks, drains and restrooms; while Zone 4 covers hallways, offices, coolers and freezers.

But what’s important is making sure the zones are adequately distanced.

“Zone 4s are the farthest things away from Zone 1s,” Mommsen said. “Zone 1 should be surrounded by Zone 2, Zone 2 should be surrounded by Zone 3. Zone 3 is your last line of defense before going into Zone 4. Those kinds of things are what I look for when I go into a plant, just to make sure that when you design an environmental program, it has some degree of success.”

Have patience.

Delays will happen, and that’s OK.

Whether it’s discovering you don’t have enough circuits to power new equipment, which means bringing in an electrician, or delays in getting certain materials, it may take longer than you think to get up and running, so build in extra time.

“It’s hard to open up on time,” said Love.

Start simple.

Automation is great. But if you’re a small company, Love advised the small-town mentality of starting with what you can afford, and then build up as a product line starts earning more money.

“Everybody wants automated right from the beginning,” he said. “But automated means lots of corners, lots of joints, lots of fasteners, lots of movable parts — and they all have to be clean.”

Separate storage.

If storage facilities are part of your redesign or expansion, make sure those spaces are designed to allow separation of products.

“Remember, allergens are not cross-contamination, they’re cross-contact,” said Love. “So you don’t want any vertical stacking. Everything has to be lined up.”

Section off.

If your facility is going to be handling products that go from raw to ready-to-eat, such as meat or, eventually, bread items (Storsin expects an announcement on this coming from FDA), you need to segregate those areas to avoid contamination. Make sure walls or curtains separate the areas, that different colored smocks or shirts are designated for each and that there are changing and sanitizing stations between each.

“With COVID, you actually want to put several sanitizing stations in,” Storsin said. “Each time you go from [one area to the next], you’re going to want to at least have hot water and soap.”

Flow matters.

Storsin said it’s important to have a good product flow. Make sure railings are at least 3-6 inches above and around belts. If you can afford it, have everything around the belts designed with stainless steel, including catch pans, railings and ceilings.

“You’ve got to think about what may land on product and get out the door,” Storsin said.

Surface tension.

When planning walls, whether you’re using stainless steel or laminate, make sure that there are no gaps or holes where sections meet. Use molding to avoid gaps.

“In a wet plant, moisture gets behind there, you get mold, obviously, but you get bacteria growth,” Storsin said.

For floors, make sure it’s a smooth surface that’s slip-proof.

“One, for your employees; but you don’t want anything that’s going to crack or buckle, so you have gaps again, which will hold moisture, which will create Listeria,” said Storsin.

Cover the floors with food-grade coating, and make sure they’re easy to clean.

“If you’re using a mechanical cleaner — one of those big walk-behinds — make sure that you don’t tear up the floor,” said Storsin. “We’re small, so we use a mop.”