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The Virtual Food Systems Training Consortium (VFSTC) is a coalition of four universities that is creating online training for food inspectors from federal, state, local, territorial, and tribal agencies. Inspectors of FDA-regulated foods will be able to get up-to-date training without taking time away from work and costing already-strapped states a lot of money. As the “subject matter expert” for two online courses about sanitation, I am detailing the best practices that inspectors of FDA-regulated foods will be looking for when they inspect a food procesing facility.
The Food Safety Modernization Act (FSMA) gives the FDA increased regulatory authority, and there is a good possibility that new regulations might require written hazard-control plans for food production facilities that have not required such plans in the past. FSMA includes an exemption based on income and sales, but recent discussions with state regulators suggest many states will implement regulations requiring small, exempt processors to meet the federal requirements.
Some of the regulations that will define the law are still a big question mark, but it might be a good idea to look at your current procedures, and companies that do not have a hazard analysis plan in place should get ready to implement a written plan. FSMA’s main emphases are prevention, inspection and compliance, response, and imports. Under “prevention,” you will have to evaluate hazards and then identify preventative steps and controls to reduce those hazards, which means you need to know the basics of disinfection.
Cleaning is the physical removal of visible soil from surfaces, kind of a “touch-up.” But remember—just because a surface appears clean, it might still be teeming with microorganisms. Sanitizing, then, is the treatment of a surface to significantly reduce the number of microorganisms. What we call “sanitation” is a combination of the two.
Figure 1 illustrates the objectives in each step of the sanitation process. We are looking at the remaining soil and bacteria attached to a food contact surface, with the understanding that the initial “dry” clean and rinsing steps have already been completed. On the far left, notice the bacteria in the white area being protected beneath the overlying layer of soil. Once a cleaning agent is applied, along with some mechanical action and/or time and temperature requirements, followed by another rinse, we now see the removal of the soil along with a significant portion of the microbe population.
This first step, cleaning, is extremely important and removes approximately 90 percent of all microbes on a surface. After cleaning the processing equipment, floors, and walls, all visible traces of soils and contamination have been removed—but invisible microorganisms tightly adhering to equipment areas and surrounding surfaces still pose a contamination risk. These surfaces must be disinfected to kill all microbial populations.
The Role of Disinfectants
Sanitizers are the last line of defense against pathogens in a food manufacturing facility; when a sanitizer is applied to the surface after cleaning, the microbe population is reduced even more to a very low, safe, acceptable level, providing a surface nearly free of microbial contamination. Basically, disinfection is the process of destroying pathogens, their toxins, and associated vectors via heat, chemical treatments, or ionizing radiation. The disinfectant is the agent that delivers the disinfection.
The FDA defines sanitization as “the application of cumulative heat or chemicals on cleaned food-contact surfaces that, when evaluated for efficacy, is sufficient to yield a reduction of 5 logs, which is equal to a 99.999 percent reduction of representative disease microorganisms of public health significance.” FDA regulates chemical sanitizers as an indirect food additive and includes conditions of use specifications.