Food Protection Trends - July/August 2022 - 327

Effective environmental monitoring plans (EMPs) and
the use of root cause analysis methodology to investigate
problems are also essential to maintaining sanitary control
in food manufacturing facilities. As defined by speaker Scott
Stillwell (President and CEO, Stillwell Consultive Services
LLC), an EMP involves proactively seeking and destroying
targeted microorganisms, preventing the establishment of
bacterial harborage sites, and preventing the reintroduction of
microorganisms. Ideally, an EMP functions as " a canary in a coal
mine " to provide early notice that problems might be present.
EMPs rely on robust sampling and testing methodologies.
New technologies, including next-generation sequencing and
sophisticated data analysis tools, can help food manufacturers
better understand the unique challenges of their processing
facilities and increase the predictive power of EMPs.
HYGIENIC ZONING
Hygienic zoning is a prerequisite for environmental
pathogen monitoring, according to Duane Grassmann
(Corporate Hygienist, Nestlé USA). Pathogens do not " just
miraculously appear " in a facility; they are brought to where
they are found. Pathogen movement often occurs as a result
of a failure in hygienic zoning. Pathogen monitoring verifies
the effectiveness of the prerequisite programs that influence
pathogens in our factories, such as cleaning and disinfection,
hygienic design of the building, design and maintenance of
equipment, and the overall hygienic zoning program. When
a pathogen is found in a facility, effective root cause analysis
will include all prerequisite programs and will keep the
factory from playing " whack-a-mole " with pathogens.
Grassmann drew upon his own experiences to highlight
sometimes overlooked areas of concern in food facilities (6)
such as air handling systems, which can serve as sources or
reservoirs of pathogens (5). Other important considerations
include the presence of water, tool management, cleaning
activities, and traffic patterns for people, materials, and waste
throughout a facility.
Facilities should establish risk-based routines and barriers
to make the movement of microbiological hazards between
different hygienic zones more difficult. Barriers include
doors and vestibules. Routines are human behaviors such as
washing hands, sanitizing footwear, and putting on smocks.
Adherence to such barriers and routines by all people in a
food processing facility, including visitors and contractors, is
critical to hygienic zoning success.
LMFS
Low-moisture foods (LMFs) have become a hot topic in food
safety circles according to Richard Brouillette (Food Safety
Director, Commercial Food Sanitation), in part because
of notable outbreaks associated with LMFs such as peanut
butter and flour. Hygienic design and standards are especially
important when initially designing and selecting equipment for
an LMF facility and when rebuilding or refurbishing equipment
and facilities. For designing cleaning and sanitation programs for
such facilities, Brouillette recommended careful consideration of
whether water should be used for cleaning because trace residual
moisture in equipment can foster microbial growth. However,
dry cleaning methods may involve vacuums, brushes, etc., which
can spread contamination that may be brought in from such
items as ingredients.
Clean breaks (breaks in production during which documented
cleaning occurs and distinct production lots are
identified) are easier to define in wet operating environments
than in dry operating environments, in which run times are
often much longer. Methods used to achieve a clean break
differ in LMF facilities from those in other types of food
facilities. Wet cleaning may be possible for equipment, but
other methods often are needed, and sampling and testing
may be necessary to ensure successful contaminant removal.
HARBORAGE SITES, GROWTH NICHES, AND
BIOFILMS
Growth niches are locations supporting microbial growth,
even after cleaning and sanitation. Harborage sites are growth
niches in which a pathogen or its indicator are found (3). Sue
Schwartz (Vice President, Quality and Food Safety, Miniat
Holdings) discussed practical tips for identifying these
growth niches and mitigating risks associated with them.
Using a " wet dog " analogy, she illustrated how operating
(and shaking) equipment can permit residues (including
microorganisms) deep inside the equipment to find its
way out into the manufacturing environment. Schwartz
recommended looking for hidden " wet dogs " in facilities
when trying to find harborage sites. From there, consider
potential pathways from harborage sites to food contact
surfaces. She recommended an iterative, corrective action
cycle to find the " wet dogs, " including tearing down
equipment to the base structural framework when possible,
and emphasized the importance of visual observations:
" If your eyes tell you that it's dirty, it's dirty. " The everyday
experience that operators and maintenance and sanitation
personnel have with the manufacturing line should be
leveraged; third-party resources (such as outside laboratories,
chemical suppliers, and consultants) may also be useful.
Schwartz recommended that environmental monitoring
take a proactive " seek and destroy " approach, defined as
" a systematic approach to finding sites of persistent strains
(niches) in food processing plants, with the goal of either
eradicating or mitigating effects of these strains " (14). Niches
may initially contain only harmless spoilage organisms but
could eventually harbor Listeria species or other pathogens.
When growth niches in equipment are found, mitigation
strategies are needed, which could include redesign of
equipment, periodic equipment teardowns, and thermal or
chemical interventions (Figure 1). Pre- and postclean aerobic
plate counts (APCs) can be used to validate the effectiveness
and frequency of these procedures.
July/August Food Protection Trends 327
Food Protection Trends - July/August 2022

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