Cleaning is more important than ever
Thankfully, this attitude was not ubiquitous back then. At the time, most processors understood cleaning needed to be done to protect the quality and safety of their products. And, if the plant was processing meat and poultry, it had to be clean or it simply wouldn’t be able to operate the next day. Having a USDA FSIS inspector deem a piece of equipment unclean and tagging it NR (noncompliance record) meant staff had to wait until the unit was cleaned to the inspector’s satisfaction.
Food processors hired sanitation professionals to manage their programs and worked closely with cleaning chemical suppliers. Some suppliers not only provided companies with the appropriate chemicals, they ensured the workers were properly educated in their use and safe product handling and assisted in developing procedures.
Today, processors have an even better understanding of the relationship between proper hygiene and food safety and quality, and cleaning and sanitation are front and center.
But the key words are validation and verification—two words that can create confusion.
In FSMA’s Preventive Controls proposal, validation is defined as that element of verification focused on collecting and evaluating scientific and technical information to determine whether the food safety plan, when properly implemented, will effectively control the identified hazards. This definition is very similar to the one used in the juice HACCP regulations, the Codex Food Hygiene document and ISO 22000.
On the other hand, the proposal defines verification as those activities, other than monitoring, that establish the validity of the food safety plan and that the system is operating according to the plan. This means that, after a process for cleaning is developed, drafted and implemented, it must be validated using good science to ensure it effectively cleans and sanitizes each piece of equipment, utensil or system.
Validation is a part of the different activities that make up verification. And, according to the proposal, validation must be done “before implementation of the food safety plan or within the first six weeks.”
In food processing operations, the goal is to determine whether a plan is sufficient to ensure the cleanliness of equipment and the environment using visibly clean criteria and quantifiable methods.
For example, when a processor is establishing cleaning procedures for allergens, the tests may include but need not be limited to finished product testing, push-through testing, swabbing or rinse water in CIP systems. The swabs, which may be ELISA tests for allergens, ATP tests, protein tests or microbiological swabs, are the quantifiable elements. The cleaning procedures should include the validation of the protocol at least twice to ensure its efficacy.
With cleaning and sanitizing, verification means ensuring the validated procedure is being followed. Processors can use checklists to do this. They also have the options of employing second-party audits to verify the work was conducted and was effective or using ATP or allergen swabs. Some operations use all three of these elements.
But whichever method is used, the bottom line is having records that demonstrate the cleaning operations were not only carried out, but they were done properly. It is also good idea to revalidate or reassess the cleaning and sanitation programs at least once a year by repeating what was done during the initial validation.
Cleaning and sanitation should be integral parts of every food processor’s food safety management system because each plant will be subjected to third-party audits to meet one of the Global Food Safety Initiative’s audit schemes, the ISO 22000 food safety standard or FSMA. So, expect to be challenged, and make sure you are adequately prepared.