Dusts produced when manufacturing and processing food products create significant challenges. Dust particles often become airborne, which can threaten employee health and cause combustible dust incidents. Food dust particles vary in size, and some are so fine they are not visible to the naked eye. Common food dust hazards include cereal ingredients, spices, feed and raw grain agricultural products, egg shell dust, flour, corn starch, sugar, and flavoring additives.
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Manufacturers must comply with Occupational Safety and Health Administration (OSHA) regulations to protect their employees from exposure to airborne dusts, as well as National Fire Protection Association (NFPA) standards to provide a safe working environment. In addition, food processors must follow regulations from the USDA and FDA, which has begun implementing the Food Safety Modernization Act (FSMA).
Manufacturers need to control the dusts generated in food and beverage facilities that can:
- Cause serious harm to human health and negatively impact the environment;
- Cross-contaminate and proliferate the spread of pathogens and allergens; and
- Become combustible and cause devastating explosions that harm workers, damage machinery, and destroy buildings and corporate reputations.
OSHA regulations govern employers whose processes generate dust, and will issue citations and fines for lack of compliance. Food industry employers are required to protect workers from exposure, and each food or beverage manufacturing application will have its own unique set of process conditions. Under OSHA, companies must control dust emissions into the indoor workplace atmosphere to comply with legal limits set for a particular material. If no legal limits are applicable, then the company is required to define in writing, implement, and measure its own environmental safety plan.
Traveling dust in a food processing plant can result in allergen exposure or a pathogen outbreak from the spread of microorganisms. Preventing cross-contamination requires effectively cleaning equipment and processing suites—collecting and removing all contaminants before they become widely dispersed. Collecting, controlling, and filtering pathogens and allergens minimize the spread of harmful contaminants and keep them from returning to the processing environment.
Regulations Governing Occupational Exposure and Cross-Contamination
OSHA. OSHA 1910 is a broad, general standard that covers most industries. It is a comprehensive and complex standard with 20 subsections. The only food industry sector that has its own separate standard is agriculture, which is covered by OSHA 1928.
A list of key parts of OSHA 1910 that are important to the food processing industry and require dust control include:
- 1910.22: Walking-Working Surfaces;
- 1910.134: Personal Protective Equipment;
- 1910.263: Bakery Equipment;
- 1910.272: Grain Handling Facilities; and
- 1910:307: Hazardous (Classified) Locations.
In addition to the above standards relevant to the food processing industry, OSHA has issued a Safety and Health Information Bulletin titled Occupational Exposure to Flavoring Substances: Health Effects and Hazard Control.
The FDA’s FSMA requires food processing facilities to implement measures to ensure contamination hazards will be minimized or prevented. These include controls for processes, food allergens, sanitation, and supply chain, as well as having a recall plan. Food processors must also include and document actions to:
- Identify and correct a problem implementing a preventive control;
- Reduce the likelihood the problem will recur;
- Evaluate affected foods for safety; and
- Prevent those food products from entering commerce if they cannot ensure that the affected food is not adulterated.
FSMA gives the FDA the authority to suspend a food facility’s registration if there is a “reasonable probability” the food product in question will cause serious adverse health consequences or death to humans or animals. A suspended license means the food produced in that facility can no longer be sold.
The mission of the USDA Food Safety and Inspection Service (FSIS) is to protect public health by ensuring the safety of meat, poultry, and processed egg products. As a public health regulatory agency, FSIS investigates reports of foodborne illness associated with FSIS-regulated products. If a foodborne illness investigation determines that a food product contains a pathogen or is otherwise harmful to human health, FSIS could recommend a recall of that item. Other possible agency actions—like initiating criminal, civil, or administrative action—depend on the evidence collected and how strongly human illness is linked to the FSIS-regulated product.
Controlling Exposure to Dust
The best way to reduce hazardous dust exposure and cross-contamination is to install dust collection systems with high-efficiency primary and secondary cartridge-style filters. Primary filter media should be selected for each application based on the dust particle size, flow characteristics, quantity, and distribution. If the primary filtration system does not use a HEPA filter, it is recommended that a secondary HEPA filter be used downstream. Secondary filters prevent hazardous dusts from discharging to the atmosphere and can be configured to prevent return air ducting contamination and the associated costs of cleaning hazardous dust leakage.