Top 10 Hazard Prevention Solutions: Preventive Controls
By: Bill Bremer
Principal, Food Safety Compliance, Kestrel Management
QUICK TIP #1: Hand Washing
Human contamination of food is the highest ranked risk for food & beverage manufacturers, and hand washing is the preventive control.
The number and location of hand washing stations is commonly overlooked. Installation of additional hand wash stations with signage, soap, hand drying and waste control can help prevent contamination.
QUICK TIP #2: Hand Sanitation
Hand washing helps prevent human contamination of food – but it can’t be constant. Expanded use of hand sanitizer stations helps provide a preventive control against contamination in between hand washings.
Installation of hand sanitizer stations in areas between hand washing sinks helps provide an expanded level of prevention against human hand contamination of food.
QUICK TIP #3: Drain Sanitation
Drains have been the source of many biological contaminants in serious recalls, including those involving higher risk bacteria such as Listeria M., responsible for many serious food safety outbreaks.
Better maintenance, conditions, and sanitation help support preventive controls. Increase both sanitation (chemical), use of dry steam, and drain replacement and maintenance as preventive controls for drain sanitation.
QUICK TIP #4: Cross-Contamination/Food Contact Utensils
Eliminating cross contamination is a real opportunity in nearly all food operations. The use of color-coded and controlled food grade utensils and tools, including sanitary storage, offers a significant opportunity and preventive control measure.
The practice of controlling food contact utensils and tools needs to be expanded in food and beverage processing. Color-coding helps prevent cross contamination, and ensuring sanitation, while using shadow boards helps to provide safe and hygienic storage. Food plants need to have as many utensil sets as necessary for specific use as color coded (application – food type – allergen type) and have at least one set in sue while the other set is being cleaned, as well as back-ups and adequate supply for multi-shift situations.
QUICK TIP #5: Cross-Contamination/Maintenance Tools and Parts
Eliminating cross contamination is an ongoing challenge for nearly all food and food-related operations. A process for cleaning and sanitizing tools and parts must be in place for food use, and tools and parts need to be protected in storage or when staged for use.
Use of multi-tiered maintenance carts to separate used and replacement tools, and used and replacement food equipment parts represents a significant preventive control opportunity. The control of cleaned parts and tools establishes a preventive control supported by the storage and separation of clean from used parts that might be contaminated.
QUICK TIP #6: Chemical Control
Chemical and non-food material control is a key requirement not consistently met in most food and beverage manufacturing plants. The addition of segregated storage provides a preventive control.
Most food plants do not store chemicals effectively, necessitating the addition of locked storage cabinets—note that H1 chemicals must be stored separately.
QUICK TIP #7: Signage: Access/Directional/Warning/GMP
Most food plans are not well supported by visual workspace elements such as signage. Signage supports a visual workspace with posted information for all employees. A review and update presents an opportunity for a preventive control.
Verify that visual plant solutions are adequate and look for hazards, like pinch points, that need to be identified as well as controlled access and procedural information. Signage with posted information and warnings help support food safety, employee safety, training and multi-lingual communication.
QUICK TIP #8: Doorway Sanitation
Many of the major food biological contaminant outbreaks occurred due to broad plant contamination spread in part by poor doorway sanitation. This presents an opportunity for a vital preventive control.
Doorway sanitation is a method of helping to control possible contamination from footwear in a food facility including any chemical, biological, and physical or allergen contaminants. Doorway sanitation between food plant zones including outside-in doors presents an opportunity for control via sanitary mats, fountains, shoe covers, changing from street shoes to designated work boots, and sanitation stations which can be installed to address this problem.
QUICK TIP #9: Environmental Testing
Many plants perform environmental testing but expansion to higher risk sources and test verification is an accepted control to improve programs.
The use and expansion of environmental testing for biological contaminant levels on food plant surfaces (non-direct surfaces of floors, walls and equipment) constitutes a preventive control under FSMA. Additional areas to be tested include door handles, hoods, light switches, storage units, fork trucks, transports or any other non-food contact surfaces that could be a source of biological contamination. The program and the expansion of existing programs qualifies these activities as preventive controls to monitor hazards and provide improvements in control of biological contaminants.
QUICK TIP #10: Biofilms/Hard-to-Reach Areas
Biofilms present a difficult problem for the food industry, and also present a food safety risk. A biofilm is any group of microorganisms in which cells stick to each other; often these cells adhere to a surface, leading to growth of biological contaminants in a food plant.
The use of dry steam in hard-to-reach areas is a very good preventive control option for removing biofilms (that show as bluish coloration on surfaces). Both dry steam solutions and bio source sanitation products provide preventive controls for higher risk sources including food equipment transfer and floor drains. Biosource sanitation solutions include products that are specified to remove biofilms including acidic cleaners and sanitizers.
Information provided courtesy of Kestrel Management™
Bill Bremer is a Principal with Kestrel Management’s Chicago area practice and heads Kestrel’s food safety consulting group. In his food compliance roles, he has led compliance and assurance activities to help many food industry companies meet FDA/FSMA, GFSI (i.e., BRC, IFS, FSSC22000, SQF), HACCP, EHS, and overall operations management requirements.
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