Download Sanitation & COVID-19's webinar slides.
COVID-19 will change how we work because food manufacturers will be challenged to prove that all plant surfaces are clean. As a starting point, let’s clarify how key terms are defined.
- Cleaning – This step is simply removing the food and debris from the surface to the extent that the human eye can see.
- Sanitation – Per FDA, “Sanitize means to adequately treat food-contact surfaces by a process that is effective in destroying vegetative cells of microorganisms of public health significance, and in substantially reducing numbers of other undesirable microorganisms, but without adversely affecting the product or its safety for the consumer.”
- Disinfection – Disinfection is the next level of clean. While we didn’t speak to disinfection during this webinar specifically, you may find the FDA’s List N: Disinfectants for use Against SARS-CoV-2 useful.
- Verification – Verifying that you complied with your program and your sanitation was effective.
We then profiled some of the changes to Cleaning, Sanitation, Verification and Training & Onboarding we believe will need to take place in our “new normal.”
Changes to Cleaning
Have you conducted risk assessment for cleaning?
It’s important to understand what you’re cleaning for – are you just removing the residue? To minimize pest development? From a microbial standpoint?
How will you change your training program to ensure compliance to CFR 117.35?
Regulations are already in place for cGMP’s specifically on personnel practices. Sanitary operations focus on sanitation and pest control, so we cannot forget about these important areas.
Changes to Sanitation
FDA & Regulators Will Be Expecting Changes
We expect inspectors to be looking for sanitation practices and cleaning procedures. They may also identify some things that weren’t a priority before.
Will mandatory cleaning frequencies similar to 416-4-A USDA facilities sanitization regulations be looked at as a model?
The USDA has this mandatory cleaning regulation, directing that facilities clean and sanitize on a regular frequency. Other regulators may look to this as a model for future regulations.
Validation Procedures Can Complement Your Program
Are you validating your current cleaning program? If you are sanitizing, was it effective? Validation procedures can complement your program.
How will the industry regulate itself?
Programs like GFSI are in place for manufacturers to regulate themselves to make sure they are in compliance with customer expectations.
Changes to Verification
Chemical Concentrations per Label Recommendations
It’s important to check and ensure the appropriate chemical concentrations so these chemicals work properly.
Have you included temperature requirements in your cleaning chemical usage?
The correct water temperature can help make the chemicals as effective as they’re supposed to be. This is especially important for caustics.
Training & Education Comprehension
We often test employees on programs like OSHA, keeping them safe from workplace accidents. Why don’t we also test for proper food safety practices? We have the opportunity to educate and test on GMPs and sanitation – to communicate the “why” they’re doing some things may be most important to adoption and compliance.
Science-based testing
Surface testing, including ATP – while this won’t tell you what the microbial concerns are, it will tell you that there the surface is dirty. This can complement your sanitation program.
Finished product testing – Many facilities do product testing for various pathogens, including Listeria, salmonella and E. coli.
Changes to Training & Onboarding
- Employees need to be educated on the reasons they are required to follow certain procedures - not just trained on cleaning and sanitation.
- The training program for both onboarding and continuous needs to be enhanced and enforced. The GMP’s to train them on are not just best practice – they are law. Regulations are already in place for cGMP’s, specifically on personnel practices.
- We verify comprehension of programs such as Employee safety (OSHA) by testing. Why do we not do the same for GMP’s? Employees need to understand the “whys,” as well as the “do” and “do not.”
Practical In-Facility Scenarios
We then offered insight into how these changes can be implemented in-facility through three scenarios.
Longer Production Runs
To meet demand, we’re doing longer runs. What can we do to effectively sanitize?
- Provide sufficient time for sanitation – You’re not just cleaning, but sanitizing to control pathogens.
- Provide effective training for sanitors – Make sure your team understands why they’re cleaning, why they’re using certain chemicals per the label directions.
- Collaboration with maintenance and production to maximize cleaning – Utilize the cleaning hours that you have to make sure you’re properly cleaning and sanitizing the facility.
Pest Management
Will pest control activities be impacted if plants are not shutting down to properly clean and sanitize?
- Some insect cycles are between 4-6 weeks – If you’re not cleaning often enough, you won’t interrupt them.
- Cleaning interrupts the life cycles of some pests – By cleaning every 2-3 weeks, you’re breaking that pest production cycle, not allowing those insects to develop.
- Cleaning removes the food source pests need to survive – Food residue is a location where some pests can find a food source and reproduce.
Temporary Facility Closures
My facility has been temporarily closed. What sanitation measures do I need in order to re-open?
- Pest development
- Detailed inspection for pest activity and signs – Utilize your IPM to inspect your facility is clear of pests so you’re ready to start up again and there’s nothing that will cause a delay or quality issues.
- Assessment conducted with IPM professionals – We require an annual assessment to ensure that all of the necessary pest management programs are in place.
- Pathogen or microbial development
- Sanitation of food contact surfaces – While COVID-19 is not a pathogen, a good and detailed cleaning and sanitation of food contact surfaces is key.
- Validation testing for contact surfaces and inspection for product zones – These are things we can do in the facility to make sure the re-opening of your facility goes smoothly.
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