Managing and Documentation of Sanitation Programs

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Managing and Documentation of Sanitation
Programs

• Ron Hall
• Don Bredeman
• Ecolab Food Beverage-
• Northwest District

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Customer Perspectives
Don McMullen Production Superintendent
Margarito Vidrio Sanitation Manger
Rob Wiskerchen Plant Manager
Chris Mone, Quality Control Manger
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GMPs - Good Manufacturing Practices

• 21 CFR 110 - Federal Law
• Minimum Standards
• Food - Manufacturing, Packing, Distribution
• Adulteration
• Unfit of Human Consumption
• Unsanitary Conditions that MAY Contaminate or
  be Injurious to Health

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Risk, Rules, Reactions will continue to change

• Sanitation program must continue to evolve with
  the changes in business
• In the past Continuous Improvement was the
  focus
• Today Food Manufacturers are expected know how
  to produce SAFE Food and predict future risks

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People at Risk

• Under 1 year Old
• Over 60 years Old
• Aids Patients
• Immuno Compromised
• Chemo therapy
• Pregnancy

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Department of Economic and Social
AffairsPopulation Division
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Food marketers must prepare for 'YouTube'
Generation
International food industry executives attending
the Healthy Foods Summit in London were urged by
Lori Colman, chief executive officer of Chicago
marketing firm Colman Brohan Davis, when looking
toward the year 2020 to step up their efforts
around accountability, sustainability and
transparency.
"Kids who are ages eight to 18 today the adults
of 2020 will expect information instantaneously
from shared digital networks, word-of-mouth and
viral sources, social sites, smart phones or
other devices."
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Sanitation Program Divide

• Legal Responsibilities

• Business Requirements
• Meet Business Plan Requirements
• Define Market and customer requirements
• Define your plan to meet 1 2
• Measure and track the plan

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Compare your Policy Programs to Government web
sites and industry news

• Published law is the minimum standard
• Laws Regulatory Guidelines Industry norms
  The Industry Standard
• Plant Standard 1 2 Customer Standards
  (AIB, Cook Thurber, SQF, BRC, IFS)

21 CFR 110 - Federal Law (1969)
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FDA Home Page CFSAN Home Search/Subject Index
Q A Help
TITLE 21--FOOD AND DRUGSCHAPTER I--FOOD AND DRUG
ADMINISTRATIONDEPARTMENT OF HEALTH AND HUMAN
SERVICES SUBCHAPTER A--GENERAL
  10.90 - Food and Drug Administration
regulations, recommendations, and agreements
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FDA Home Page CFSAN Home Search/Subject Index
Q A Help
February 2008
Guidance for Industry Control of Listeria
monocytogenes in Refrigerated or
FrozenReady-To-Eat Foods Draft GuidanceContains
Nonbinding Recommendations
III. Who Should Follow the Recommendations in
this Guidance? We recommend that any processor of
a RF-RTE food, including processors of fresh-cut
fruits and vegetables, and processors of frozen
fruits and vegetables, follow the recommendations
in this guidance. Our recommendations apply
regardless of whether or not the food that is
processed supports the growth of L.
monocytogenes. The fact that a food does not
support the growth of L. monocytogenes does not
affect a manufacturer's responsibility under
section 402(a)(4) of the Federal Food, Drug, and
Cosmetic Act (the Act) to ensure that food is not
prepared, packed, or held under insanitary
conditions whereby it may become contaminated
with filth, or whereby it may be rendered
injurious to health.
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WA State WISHA Hazcom Laws
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Challenges In our back yard

• 3 Plants Burned down
• 4 Plant worker Deaths
• E-Coli
• Juice, Lettuce, Spinach
• Salmonella
• Alfalfa Sprouts
• Tomatoes, Cantaloupe
• Mad Cow Disease
• Slaughter House
• Listeria
• RTE Meat Lettuce

• Jack-n-Box
• Cost per lb 2nd issue
• 11 Food Plants closed
• 3 new Food Plants
• 19 Plants have changed ownership

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OLYMPIA - State health officials believe alfalfa
sprouts are connected to an outbreak of
Salmonella thats sickened nine people in our
state and four in Oregon.

OLYMPIA - Nine cases of E. coli infection that
have been lab-confirmed among western Washington
residents may be linked to contaminated lettuce
OLYMPIA - Cantaloupe from Honduras has been
implicated in dozens of illnesses across 16
states, including nine cases of salmonellosis in
Washington.
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Listeria outbreak linked to Maple Leaf Foods
OTTAWA Lab results from Health Canada
established a link between meat products recalled
by Maple Leaf Foods from a plant in Toronto and
an outbreak of listeriosis in four Canadian
provinces. The same strain has been detected in
four people who have died and 21 cases of
listeriosis have been confirmed to date. Thirty
cases remain under investigation.
Canadian federal health officials say there are
14 confirmed deaths from this countrywide
Listeriosis outbreak linked to processed meats
produced at the Maple Leaf plant in Toronto
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Plant Manger is Responsible

• Plant Manger uses inputs from resources to define
  programs and establish plant policy
• Corporate Directives
• Senior Management
• QA/QC
• Production
• Engineering/Maintenance
• Sanitation
• Finance
• Area Specific Supervisors

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Operational Plan

• Policies
• Written procedures
• Work instructions
• Food Quality Plans
• Internal external audits
• Security Plan
• Crisis Plan
• Corrective actions
• Documentation Management

• Legal training requirements
• Raw Product control program
• Sanitation Program
• Food Safety Security Plan
• HACCP Plan
• Allergen Program
• Pest Control Program
• Warehouse/recall Program

Third Party Verification
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If you do it, write it down!

• If its not written down, it hasnt been done.
• Be able to trace the plan
• Be able to correct the plan
• Be able to present the plan

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What is Sanitation?Perspective stock
holder/consumer

• ____________________________________
• ____________________________________
• ____________________________________

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What is Sanitation?

• Rob Maintaining the Plant in a Clean Condition
  to minimize Risk.
• Don Required to make a saleable, revenue
  producing product
• Chris An ongoing program that ensures the
  entire plant and grounds are maintained to ensure
  product integrity.
• Margarito The most important part of the
  Production Day

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What is Sanitation?Perspective stock
holder/consumerSurvey answers

• Protects product integrity
• A requirement by Federal Law
• A cleaning of the plant processing areas
• Insurance for Product Safety/guard against a
  recall
• Critical part of our production cycle
• Requirement to ensure safe food
• Assurance of quality for our customers
• Reduction of Risk
• Sanitation is the integrity of my plant
• Most unrecognized function in the plant

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The Weeds (details)

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The Weeds (details)

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What is the plan?

• Plan Name of ________
• Purpose Function and agreement
• Buy in statement / Explanation
• Whats in it for me? You? them? (WHY?)
• Because the auditor says so is not a reason.
  Your have an obligation to break the information
  down into usable form and obtain Buy in or
  conformity among the crew
• Follow up - Measurement

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Definition of Sanitation

• Sanitation is the first step in the production
  cycle. Sanitation does not add value to a
  product which has just been manufactured it only
  protects the value of the product that will be
  produced.
  

• Our Sanitation Program is our second largest
  sales platform, right after the quality of our
  product Jim Anderson

Sanitation is the REDUCTION OF RISK as determined
by plant management and implemented PLANT WIDE.
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Whats the plan?

• Define the parameters
• Validate the plan
• Verify the plan

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Validate Verify (The Plan)

• Training Plan
• Master Sanitation Schedule
• Chemical usage plan

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Validate Verify

• Training Plan Legal
• Training Plan Business
• The Topic, Need, Benefit, Justification
• The measurement Before, after, later
• Follow-up
• Department Training plan
• Personnel training plan
• Refresher Training
• Does Training Expectations?

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Validate Verify

• Master Sanitation Schedule

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Validate Verify

• Training Plan
• The Topic, Need, Benefit, Justification
• The measurement Before, after, retention
• Follow-up
• Master Sanitation Schedule
• Product Contact 1st and 2nd level
• Environmental
• Procedural / SSOP Evaluation
• Chemical usage plan

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Whats the Risk?

• Start
• Program use rate
• Overuse
• Underuse Increased Risk

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How much chemical do I use?

• Whats the plan? Target use rates?
• Legal requirement Sanitizers, Process aids
• Whats the limit? Plant target?
• Action if your above or below Legal limit?
• Action if your above or below Plant Target?
• Business requirement Cleaners
• ___ above or below the plan, justify when you
  are outside of plan range.

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Cost Example 1

• Chemical XYZ use rate is 5 oz/gal, 5.00/gallon
• 1000 gallon circuit
• 1 gal 128 oz
• 5 oz/128 oz .039 gallons x 5.00/gal .19
  unit
• 1000/5 200 units x .19 38.00

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Cost Example 2 (10 increase)

• Chemical XYZ use rate is 5 oz/gal, 5.50/gallon
• 1000 gallon circuit
• 1 gal 128 oz
• 5 oz/128 oz .039 gallons x 5.50/gallon .21
• 1000/5 200 units x .21 42.00

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Cost Example 3 (10 increase)
(20 water reduction)

• Chemical XYZ use rate is 5 oz/gal, 5.50/gallon
• 800 gallon circuit
• 1 gal 128 oz
• 5 oz/128 oz .039 gallons x 5.50/gallon .21
• 800/5 160 units x .21 33.60
• Savings 1st level (4.40) (11)
• Savings 2nd level Waste Treatment

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Food Safety RegulationsEarly Beginnings

• 600 AD "He who deliberately gives or sells it
  (unfit food) to another will be banished for a
  year. If the person to whom it has been given or
  sold dies, the offender will be hanged" T'ang
  Dynasty, China
• ?? "If dried or fresh meat causes
  illness, leftovers must be burned immediately.
  The producer will be flogged 90 strokes

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Education and Training

• Competent Management to Produce Safe and Clean
  Food
• Training Programs for Food Handlers and
  Supervisors
• Responsible Persons Identified

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Sanitary Operations

• Maintain Facilities and Equipment in a Clean
  Condition
• Clean and Sanitize as Needed to Prevent
  Contamination
• Keep Cleaners and Sanitizers Free from
  Microorganisms

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Production and Process Controls

• Validation - QC Microbial/Chemical/Extraneous-ma
  terials
• Raw Materials - Inspection/Segregated/Storage/Wash
  ing
• Manufacturing Operations - Processing
  Time/Temp./pH/Flow/Pressure/etc.
• Separation of Raw and Processed
• Control of Foreign Substances

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The SPIRIT of the LAW

• GMPs
• General Guidelines
• All Food Processors
• Processors Responsibility
• Interpret Guidelines
• Develop Specific GMP Plan / Policy
• Implement
• Train
• Monitor

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SSOPsSanitation - Standard Operating Procedures

• Required by USDA - FISI
• Mega-Reg
• Considered a Prerequisite to HACCP
• Require Effective GMPs

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SSOP Format

• 1. Date
• 2. Identification
• 3. Plant Product ID
• 4. Management Structure SSOP Responsibility
• 5. Equipment Type
• 6. Cleaning Frequency
• 7. Procedure Including
• Preparation Disassembly
• Cleaning Sanitizing
• Reassembly
• 8. Monitoring Concentrations, Microbial, ATP
• 9. Corrective Action- Who What Verified?
• 10. Record Keeping

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SSOP - Example
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Good Manufacturing Practices - GMPs

• Deadly Results
• Consumer People DIE
• Business Lost Sales / Costly Recalls
• You Plant Closes
• Everyones Job - 100 Commitment
• Safe / Quality Foods
• Safe Environment for
• Food Production / Worker / The Environment
  -Earth

Make The Right Choice