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FSMA’s impact on plants—old and new
FDA released for public comment its proposed rule on preventive controls for human food to prevent foodborne illness. (For more details, see “FSMA Update: The devil’s in the details,” FE, March 2013.) Public comment has been extended until September 16, 2013. Under the new rules, processors would be required to have written plans that identify hazards, specify the steps that will be put in place to minimize or prevent those hazards, identify monitoring procedures, and record monitoring results and specify what actions will be taken to correct problems that arise. Since a food plant’s physical space is usually so tightly integrated with the process, there are concerns as to whether existing buildings will need a lot of work to meet FSMA requirements.
As HACCP teams review their programs and good manufacturing practices (GMPs), they are often faced with the reality that outdated facilities impose significant product contamination risks due to the existence of faulty facility design, inadequate construction materials and outdated mechanical systems, according to ESI Group’s Michler. Food safety improvements should include controlling unauthorized access of plant personnel to production/process areas; designing proper site, floor slab and roof drainage systems to eliminate water pooling and the harborage of pathogens; and isolating plant areas to separate raw, production, packaging and warehouse spaces.
“The concern is not necessarily the facility’s age, but more the use it was designed for,” says Bill Sokolowsky, Burns & McDonnell business development manager. Greater risk is likely in facilities designed for non-food processing applications that have been converted to food manufacturing centers. Overhead installations (primarily piping with joints), access for overhead cleaning, proximity to sanitary facilities (e.g., lavatories with access directly adjacent to production lines) and waste segregation are the most obvious shortfalls Sokolowski sees during visits to plants. The integration of wet and dry processing areas also makes the list, as do specific uses of construction methods and materials (e.g., open cavity walls, porous surfaces, etc. that harbor and promote infestation and bacteria growth).
More also needs to be done to fully isolate the exterior environment from the manufacturing area. HVAC upgrades, interior separations and dynamic pressure balancing will likely be issues in facilities not designed to meet today’s more stringent requirements. But workflow and dust control will be among the most difficult issues to overcome in other than optimal plant layouts that have workers, machines and materials negatively affecting the desired and required sanitary conditions of the plant.
Accessibility and visibility are some additional common issues in older facilities, according to Gray’s Cundiff, and planning existing building space to improve them often hinders production and could come at a high cost. However, design techniques such as drop-down, walkable ceilings used in new plant designs are also often considered for plant improvement projects.
In RTE production facilities, a high level of segregation of systems including water and air is necessary, but reconfiguring ventilation and sanitary systems in an existing facility poses many challenges. “During project planning walkthroughs and observing sanitary design issues, we have learned the processor may be in need of updated cGMPs or HACCPs as a broader, but necessary, solution,” adds Cundiff.
As if there weren’t already enough issues on the list, Epstein’s McCormies adds existing HVAC systems that are often inaccessible and difficult to clean, the uncontrolled movement of materials and personnel that allows for cross-contamination and older buildings with too many cracks, crevices or hidden areas that make sanitation difficult or impossible.
While the basics of sanitary construction haven’t changed all that much in the last 10 years, today’s new construction places more emphasis on airflow and ventilation design, says VCP&A Principal William Vaughn. Austin’s Graham adds that allergen separation is another issue being addressed by new construction. HACCP implementation is designed in at the outset. The handling of wastewater and creation of smooth interior surfaces are also addressed by new designs.
According to Hixson’s Steur, allergen control is not only an issue in the plant but the warehouse as well, since older facilities were not properly designed to segregate allergens. Airflow issues are caused by changes over time in product mix, equipment utility requirements, production volumes and unanticipated alterations. “Meat plants that have not been updated since AMI created the Sanitary Design Principles for Facilities in 2004 often must upgrade their HVAC systems to improve the control of moisture and temperature,” says Steur.
As noted earlier, processors are looking for paybacks when it comes to any alternative energy schemes or recouping wasted energy or recycling water. But, taking on alternate energy initiatives (wind, solar, waste-to-energy) is usually beyond the scope of most projects. “We have participated in conceptual efforts—and even design development phase—for a tri-generation energy plant with energy recovery systems for a new food plant; however, we have seen that for the specific application, the capital cost to operational payback ratio may not make sense,” says Gray’s Cundiff. But processors are exploring the possibilities. “Overall we have been asked by several manufacturers to evaluate similar waste-to-energy systems at least from a conceptual standpoint to gauge the various payback scenarios. In the larger industrial manufacturing sector (including food manufacturing), we have observed a consistent and growing trend in requests for similar systems.”
While SSOE has designed and installed waste-to-energy projects, they have not gone into the food industry, according to Gruenhagen, because the food industry generally is looking for simpler, more immediate and cost-effective energy-saving devices. “SSOE has installed a number of systems to recover waste heat from processes—flue gases and waste streams,” says Gruenhagen. Most of these systems are used for heating water or preheating ingredient streams. One application involved pulling excess heat from the production environment and using it for area heating in the rest of the building. While the firm has installed numerous systems to recover water, it is generally used for non-food contact applications, although Gruenhagen reports that in some applications, the recovered water is pure enough for use as an ingredient. But the public perception that the water wouldn’t be suitable caused the processors not to use it as an ingredient.
“The Austin Company’s focus has not been on the construction of [alternative energy] systems, but on working with clients to develop the most sustainable design possible, given the project’s scope,” says Graham. “With that said, we have recently completed or are working on food plant projects that focus on energy savings, reduced air emissions, water savings and more sustainable waste management system features and/or LEED certification.” Some of the more notable systems and features include site work for rain gardens and riparian buffers, highly efficient HVAC, Solatubes that maximize natural lighting and hot water return recirculation. “It should be noted that some LEED elements are a challenge to implement in food production facilities due to conflict with food hygiene requirements,” adds Graham.
Most processors have instituted green and/or sustainability initiatives with a focus on zero-waste systems. “Standalone projects are difficult to gain approval due primarily to internal ROI requirements, but when capital projects such as greenfield facilities are constructed, it is a vital component of the design to incorporate zero waste and/or uses systems,” says Stellar’s Kappele. Some projects Stellar has designed include those that were part of an overall LEED strategy or implemented at a later date:
1. A refrigeration system that uses the waste heat from screw compressors to pre-heat hot water.
2. Waste heat from the refrigeration compressors that is used to heat glycol and pumped under freezer floors to prevent frost and heave.
3. A reverse-osmosis (RO) wastewater treatment facility that returns treated water from the process steam waste system for use in the refrigeration system cooling towers.
4. A wastewater treatment facility, equipped with an anaerobic digester, that is capable of capturing methane gas generated by the process and returning the gas back to the plant’s boiler room, where dual-fuel boilers accept the methane and use it as a fuel source.
While Stellar has been involved with solar, wind, waste-to-energy and zero-net systems, which are typically larger and more aggressive investments, it has found most food processors tend not to pursue these technologies, especially because they require knowledgeable maintenance over the life of the equipment.
Click here for a link to the survey results.
The following companies assisted Food Engineering in compiling this survey:
A M King
The Austin Company
Big-D Construction Corp.
E.A. Bonelli + Associates, Inc.
Burns & McDonnell
Case, Lowe & Hart, Inc.
Kevin J. Lewis
The Dennis Group
ESI Group USA
Food Tech, LLC
Hixson Architecture & Engineering
Michael J. Steur
KBR Building Company
Jane Gray Boland
Charles K. Dietz
Shambaugh & Son, L.P.
Woodard & Curran