How Clean Is Clean?

By Lisa Lupo

The word “clean” can be idiomatically used to emphasize the completeness of an action or experience, e.g., “he was knocked clean off his feet.” Synonyms include words such as totally, thoroughly, and absolutely. When your cleaning and sanitation crew finishes its shift, are those words applicable to the state of your food processing facility? What does it really mean to be thoroughly/totally/absolutely clean? And why is that important?

“A thoroughly/totally/absolutely clean food facility is a hygienic facility that serves as the foundation for manufacturing safe, high quality, and consistent food products,” said The Ohio State University Food Industries Center Program Specialist Steven Simmons. “It is a hazard-free facility at pre-op inspection, that allows for the continuous mitigation of pathogen cross-contamination and allergen cross-contact during operation.”

Unclean surfaces can and will contaminate product with spoilage, pathogenic bacteria, or allergens, so having an absolutely clean environment means that the sanitation process is capable and in control from a microbiological standpoint, preventing contamination from the plant environment, said FoodSafetyByDesign President John Butts. “Unfortunately,” he added, “there are harborage sites and growth niches below the surface in the equipment and facility that may emerge during the production process.” Because of that, words such as thoroughly, totally, and absolutely clean would mean the ability to keep subsurface growth niches and harborage sites from exuding their contents, he said. “Sanitary design is necessary to minimize this risk.”

The creation and maintenance of a hygienic food facility is arguably the most critical component of any effective food safety system, and the overarching goal of all food safety systems is to protect public health, Simmons said. “The U.S. food supply is commonly regarded as the safest in the world, largely due to the emphasis that food manufacturers place on sanitation.” Additionally, because unsanitary conditions resulting from deficient sanitation practices are often the root cause of inspection non-compliances, recalls, and foodborne illness outbreaks, USDA and FDA regulations stress the importance of food facility sanitation, such as through Sanitation Standard Operating Procedures (SSOPs) and Sanitation Preventive Controls, he said.

But, said DOZ Enterprises President Ole Dosland, the level of “clean” is in the eyes of the beholder: a plant maintenance worker would have a different level of clean than that of a microbiologist, yet both levels might be acceptable for their purpose; and cosmetic cleaning might fool a visitor, but deep cleaning is critical to meeting food safety expectations of no insects or harmful bacteria. Because of these varying perceptions, it is important to define an acceptable level of clean, based upon science and prevention of hazards, to provide clarity and consistency for the cleaning activity, Dosland said.

COMMON FAILURES. The three experts agreed that the areas most commonly missed in cleaning and sanitizing are those that are difficult to access. And when they are missed? “Product contamination and reduced shelf life are common results of failure,” Butts said.

These can include low areas, such as the underside of equipment, the wheels of material-handling equipment, the support structure of conveyor belts, and the interior of control boxes, as well as high areas, such as overhead utility piping, refrigeration equipment, and the underside of elevated walkways, explained Simmons.

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Overhead areas are of major concern because they are likely oriented directly above exposed product, product contact surfaces, or product contact packaging at some point in the manufacturing process, Simmons said. “It is possible for these areas to harbor environmental pathogens, with the ability to contaminate product or surfaces through a drop of condensate or as passengers on dust.”

Other common failures are:

• Lack of periodic deep cleaning of equipment through disassembly. In fact, a common failure is even knowing the proper level of disassembly, Butts said. This should be determined by measuring design risk areas visually and microbiologically in a seek and destroy (S&D) investigation. This is important because, he said, “Repeated S&D investigations yield data that is used to define normal and periodic levels of disassembly. This data also measures the effectiveness of the normal and periodic sanitation process.”
• Inattention to “touch points,” such as door handles; doorway curtains; control panels; hoses and nozzles; and the handles of utensils, tools, and material handling equipment. Touch points are key vectors for pathogen cross-contamination and allergen cross-contact and must be adequately cleaned and sanitized to minimize the risk of employees’ hands introducing these hazards to the product, product contact surfaces, or product contact packaging, Simmons said.
• Lack of sanitation of employee hands, gloves, uniforms, and personal protective equipment are also of concern, he said. If these become contaminated, they must be replaced with sanitary versions prior to continuing sanitation operations.
• Rushing to get the job done. “Often sufficient time is not allotted for the desired cleaning activity due to production overruns and early startups,” Dosland said. “A well-developed SSOP should identify the time frame needed to accomplish the task.” A solution is to provide an uncompromising time frame for the SSOP(s) start to finish. Then, periodically update each SSOP to maximize cleaning effectiveness and efficiency.
• “Sanitation crews are often overly aggressive when pre-rinsing and manually cleaning, using excessive water pressure or overly abrasive scrubbing tools, respectively,” Simmons said. This is an issue in pre-rinsing because the goal is to flush large soil particles from surfaces prior to cleaning, but excessive water pressure is likely to displace soil from one area to another as water oversprays, or casts off the sprayed surface. This is most problematic on food contact surfaces for allergens, and on floors and drains for environmental pathogens.
• In manual cleaning, sanitation crews tend to use overly aggressive scrubbing tools, such as scouring pads, inadvertently damaging equipment surfaces, Simmons added. This can be serious because the damage enhances the ability of food soils and microorganisms to adhere to the surface, while reducing the effectiveness of cleaners and sanitizers.

SOLUTIONS. How does the food facility correct these? “The solution to most sanitation program deficiencies is an effective employee training program,” Simmons said. “Sanitation employees must understand the importance of their responsibilities and buy in to the company’s food safety culture.” It is the responsibility of each employee to choose to perform their tasks properly, but management can support this through job performance rewards, often linked to monitoring and validation data.

It also is critical that sanitation employees are provided with the proper tools and supplies, he said. For example, if abrasive scouring pads are the only manual cleaning tools available, it is highly likely that sensitive equipment surfaces will be damaged.

Some best practices in sanitation the consultants have seen and recommendations they have developed from those include:

• Engaging sanitors who understand that they have the most important job in the facility; if they fail everything else is at risk. “Sanitation management must effectively engage sanitors while removing roadblocks from their success,” Butts said. “The most demoralizing situation is when a facility deploys a contingency of ‘QA Police’ to enforce visual cleanliness.”
• Clearly establishing a robust comprehensive microbiological environmental monitoring program, Dosland said.
• Reducing the monotony of sanitation work and enhancing employee vigilance. “There is a tendency for sanitation crews to get into daily routines, which may appear to be the ideal scenario for a properly implemented sanitation program. Unfortunately, routines tend to reduce employee vigilance when seeking out niches and other problem areas within a facility,” Simmons said. To break the routine, vary employee responsibilities from day-to-day or at least week-to-week, or have employees inspect the work of their coworkers to hold each other accountable for completing the work appropriately. This also helps each employee maintain familiarity with all areas and equipment in the facility.
• Similarly, Butts recommends that facilities measure and recognize the work of sanitors and expect microbiologically clean. “Make it a plant KPI,” he said.
• Sanitizer rotation is a practice that has the potential to improve the effectiveness of every sanitation program, Simmons said. Using a different sanitizer every other night, every other week, or even once weekly may enhance a program’s ability to combat the wide variety of spoilage and pathogenic organisms that may be present in a food facility. The theory is that each sanitizer has a different efficacy for each organism, so a simple rotation will minimize any deficiencies or gaps and reduce the likelihood of an organism becoming a problematic resident in a facility,” he said.
• “One job position I don’t hear much of anymore is a plant sanitarian,” Dosland said. “The best tip I can offer is to have one.” A clean facility is a longer-lasting facility reflecting an industry leader, he said. “That doesn’t happen by accident, it is the result of the intelligent effort that a sanitarian can provide.”

VALIDATION. How do you know if your facility is thoroughly/totally/absolutely clean? The first step is designing and developing a robust sanitation program and assembling a trustworthy, knowledgeable, and skilled team, Simmons said. Then, management must interact routinely with the team, including observations, discussions, ongoing education and training, and review of monitoring and verification records, such as adenosine triphosphate (ATP), microbiological, and allergen test data, he said.

Dosland provided a three-step method for determining an acceptable level of clean. Assuming the Master Cleaning Schedule (MCS) and Sanitary Standard Operating Procedure (SSOP) were developed properly:

1. Verify the MCS and SSOP have been followed. If one is late with the MCS, the SSOP might not be adequate.
2. Examine the cleaned surface organoleptically for instantaneous feedback. If it doesn’t feel, look, or smell right, it probably isn’t right, he said.
3. If 1 and 2 are acceptable, confirm with microbiological testing. Microbiological testing/swabbing includes testing for target pathogen(s) and indicator microorganisms.

If any indications of failure are found, it is critical that they are corrected. Product contamination and reduced shelf life are common results of failure, Butts said, and it also could cause products requiring a COA to not be in compliance with the product specification, leading to rejection.

“The consequences are serious,” Dosland said. “Bacterial contamination of products can lead to foodborne illness, recall, product destruction, and facility closure.”

The author is Editor of QA magazine. She can be reached at llupo@gie.net.