slicers, conveyors, collators, plastic barrels, product totes, hand pallet jacks,
electric pallet jacks, maintenance tools
and product racks. Other roadblocks include a failure to effectively investigate a
positive monitoring result.
A contact surface positive should result in an investigation. The investigation method to determine if a piece of
equipment is a source of the contaminating organism is to perform a “Seek
and Destroy” mission (Figure 1).
That piece of equipment should be
completely and fully disassembled. Samples are taken for both aerobic plate
counts and Listeria species. Observations
for excessive organic matter are conducted. Data is produced to determine
whether the organism was harboring in
that piece of equipment.
Unfortunately for some companies,
the only corrective and preventative action performed is to clean and sanitize
the transfer point that was positive then
to resample the same contact surface
transfer point. This may appear to be a
solution, but the pervasive nature of
the organism will prevail. This is a textbook example of firefighting. As long
as the growth niche is present and the
transfer vector is capable of transport,
this problem will be solved over and
over again.
Control
The Seek and Destroy Process is the
accepted scientific method to:
• Find pathogenic growth niches
• Find potential growth niches that re-
quire monitoring
• Define normal level of disassembly
• Define periodic deep level of disas-
sembly
• Define frequency of periodic deep
level of disassembly
• Qualify a new piece of equipment
(run for 90 days then conduct Seek
and Destroy Mission)
• Validate effectiveness of equipment
cleaning protocol
• Validate effectiveness of intervention
applied to a piece of equipment
The Journey
That light at the end of the tunnel
may not be a train—at least for some.
The journey to a state of environmental
control can be broken into parts and described as stages (Table 1).
Often, companies avoid having to go
down this path by having a “successful
microbiological” monitoring program.
They sample regularly and never find a
positive! Successful environmental monitoring is finding a positive, not a trigger
for regulatory enforcement. Sampling
plans need to be designed to find the organism. Investigative sampling directed
towards high-risk situations should produce enlightening data. Plants with excellent controls do find positives. Those
positives are typically from indicator
sites designed to trigger preventative action. These positives enable the plant to
take preventative action while the risk
level is low, before a contact surface or
product positive is encountered.
Food Safety Management is more
than just sampling and reporting results.
Its responsibility is to move the establishment along this journey from the
“Awareness Stage” to the “Predictive
Stage.” Failure to effectively use or deploy preventative practices keeps the establishment in a “firefighting state.” In
this state, management promotes not
getting to the root cause and rewards
solving the same problem over and over
again.
Food Safety Management must create and cultivate a company culture that
promotes preventative action. Data then
can drive the preventative mindset to a
predictive state where actions are taken
in advance of the potential problem becoming a high-risk situation. Join the
journey. The continuous improvement
pathway is marked with proven best
practices. n
John N. Butts, Ph.D. is vice president of
research at Land O’ Frost, Inc. He received his B.Sc. in Agriculture and M.Sc.
in Food Science from Kansas State University and his Ph.D. in Food Science
from Purdue University. He is a member
of the Institute of Food Technologists, the
American Society for Quality, Poultry Science, the American Meat Science Association, the Institute of Packaging
Professionals and the International Association of Food Protection.
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