Guest Blog: Listeria monocytogenes and Food Processing Equipment, 3/3

A continuation of Listeria monocytogenes and Food Processing Equipment, 1/3 and 2/3

Equipment suppliers have made some progress, but they still have a way to go. Thus a large manufacturer of packaging equipment can make the following claim:

“Perfect hygiene. Outside and in!

The whole of the B 310 can be soaped and washed down.  And every part of the machine is easily accessible for cleaning:

The inside of the tilting lid in a comfortable standing position and in a good light.
The control cubicle and the inside of the machine – with removable side panels.
The conveyor belt – which is loosened at the touch of a button and can be removed completely.
The smooth, sloping stainless steel surfaces with no recesses or sharp edges.”

All of these elements point to true progress. But why indicate that a machine is designed for easy soaping and washing down?

Also, there is no mention of a set of instructions, as I alluded to in part 1/3 of this series of articles. In fact, it’s difficult to believe that “washing down” would be a recommended cleaning method. AFSSA, the French Food Safety Agency, in its discussion of biofilm control, suggests, “… it is essential to minimize the amount of water used. Water not only encourages microbial growth, but can also be a contaminating channel as when running over a biofilm it carries and spreads a part of the micro-organisms that compose it, which may be pathogenic” (such as Listeria monocytogenes).

Sanitary design, therefore, must facilitate cleaning; nevertheless, not just any compound can be used for cleaning. Strict rules apply.

Since I began with Maple Leaf Foods, it is appropriate to reflect here the Company’s Food Safety Action Plan, as given on their website:

Improved sanitization.
Doubled the amount of environmental testing.
Increased the amount of food testing.
Strengthened our product recall procedures.

Personally, I would have much preferred that the Company would have begun by improving their cleaning protocols. To illustrate, the following is a video distributed by the Company to demonstrate the cleaning and disinfection procedures in use in Maple Leaf Foods’ Bartor Road processing plant – the source of last year’s Listeria monocytogenes contamination.

Be observant, and don’t hesitate to improve equipment design, cleaning procedures, cleaning practices, and cleaning materials. And above all, pay close attention to the management of the cleaning crew. A contamination problem is always a management problem.

About Albert Amgar: Albert Amgar lives in Changé near Laval in Mayenne, France. He worked as young scientist at the Parasitology and Tropical Medicine Service of the Pitié Salpétrière Hospital and later spent 12 years in the pharmaceutical industry. In 1989, he became director of a new association of agro-food industrialists named ASEPT in Laval (France). He was the general manager of ASEPT until his recent retirement.

Guest Blog: Listeria monocytogenes and Food Processing Equipment, 2/3

A continuation of Listeria monocytogenes and Food Processing Equipment, 1/3

According to one of the 57 recommendations contained in the report of the Independent Investigator into Canada’s 2008 listeriosis outbreak, “Manufacturers of food processing equipment should ensure that their specifications and instructions to users specifically emphasize the necessity to control the risk of pathogens, including Listeria monocytogenes.” Implementing this recommendation will not be an easy task.

The recommendation goes even farther and, for equipment manufacturers, may be too broad. But is it not an appropriate goal to gain an understanding of sanitation needs in order to design a piece of equipment that is more easily cleaned?

“In addition, manufacturers of food processing equipment should accept responsibility for the foreseeable impact of the design and operation of their equipment on food safety. The design and operation of, and recommended sanitation methods for all food processing equipment should:

enable thorough cleaning and disinfection;
allow for efficient and complete disassembly and reassembly when required;
eliminate to the fullest extent possible all areas likely to harbour pathogens, including Listeria monocytogenes;
wherever possible, use material that is scientifically validated to limit pathogen growth or survival; and
be peer-reviewed (applicable only for the recommended sanitation methods).”

Keep in mind that virtually all of these elements are contained in the European Machinery Directive, which states, in part, “…all surfaces in contact with foodstuffs … other than surfaces of disposable parts, must:

be smooth and have neither ridges nor crevices which could harbour organic materials. The same applies to their joinings,
be designed and constructed in such a way as to reduce the projections, edges and recesses of assemblies to a minimum,
be easily cleaned and disinfected, where necessary after removing easily dismantled parts; the inside surfaces must have curves with a radius sufficient to allow thorough cleaning; and
machinery must be designed and constructed in such a way as to prevent any substances or living creatures, in particular insects, from entering, or any organic matter from accumulating in, areas that cannot be cleaned.”

Watch for Listeria monocytogenes and Food Processing Equipment, 3/3

Guest Blog: Listeria monocytogenes and Food Processing Equipment, 1/3

The following Guest Blog first appeared as a three-part series in French on Le Blog d’Albert Amgar, a regular feature on ProcessAlimentaire.com, and is reproduced here in English (translation by Phyllis Entis) with the kind permission and cooperation of its author, Albert Amgar.

Five Canadian provinces experienced an outbreak of listeriosis in July and August 2008 that caused the deaths of 22 people. The outbreak was traced to refrigerated, ready-to-eat meat products manufactured by Maple Leaf Foods. An independent investigation report (pdf format) into the background and handling of the outbreak was commissioned in January 2009 and released on July 20 2009. The following is a brief summary of the findings.

“Ironically, Listeria is sometimes described as a bug of clean plants because some believe that intense sanitizing kills off the bacteria’s natural predators. This belief, however, has not been demonstrated to be true and contributes to ineffective Listeria control procedures.” Dr. Bruce Tompkin, Member of the Listeriosis Investigation Expert Advisory Group

What was the origin of the outbreak? According to Michael McCain, President and CEO of Maple Leaf Foods Inc., “It was a failure to analyze test data that we weren’t even obligated to collect – a failure on our part to analyze that data and look for root-cause analysis, investigate and follow-up on individual trends, to look for patterns so that we could find the bacteria that we couldn’t see inside these facilities, and end up with a different result. It was more a failure to analyze those findings for a root cause, and a failure of those protocols, than it was a failure of inspection, per se.” This admission is made more striking, because Maple Leaf is one of the few companies since the close of the 1990s to have developed a HACCP plan. Nevertheless, as we know, a HACCP plan does not confer immunity against contamination.

One of the concerns for those interested in process sanitation for refrigerated, ready-to-eat (sometimes also referred to as high-risk) products is to understand how to improve their own systems for managing food safety. According to Bruce Tompkin (2004, Asept, Laval), “A higher prevalence of Listeria on surfaces in contact with the product indicates a higher potential for the presence of Listeria monocytogenes in the product.” This observation goes to the heart of the problem of equipment sanitation!

The independent investigator wrote: “I am calling for swift and significant action in key areas that are critical to food safety – the culture of food processing companies, the design of food processing equipment, the rules and requirements for food safety set out by the federal government as well as governments’ capacity to manage national foodborne emergencies.”

Chap. 5, rec. 14: “Increased coordination and improved communication about food processing equipment is needed among the manufacturer, the food processor and the CFIA regarding design specifications and the validation of sanitation procedures.”

All meat processors should ensure that new and existing equipment is and remains appropriate for the intended use. Sanitation methods should be validated and implemented by meat processors in consultation with the equipment manufacturer, with a particular focus on the intended use and the products being processed on each piece of equipment.

This requirement already is embedded in European regulations; but, to the best of my knowledge, it is seldom, if ever, applied. Thus, Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on machinery, and amending Directive 95/16/EC (recast), mandates the following: “The instructions for foodstuffs machinery and machinery for use with cosmetics or pharmaceutical products must indicate recommended products and methods for cleaning, disinfecting and rinsing, not only for easily accessible areas but also for areas to which access is impossible or inadvisable.”

Watch for Listeria monocytogenes and Food Processing Equipment, 2/3