Commercial real estate strategies often play a critical role in the quality of food and the safety of food production. The key to making food production safer is by ensuring that strategies incorporate sanitary facility design principles. Whether building manufacturing facilities, expanding or upgrading existing plants, or maintaining operations, the implementation of sanitary design principles is essential to producing higher quality food products in a safe environment.
The preventive control rules for human and animal food are the central pillars of the Food Safety Modernization Act (FSMA). The key requirement of these rules is that covered facilities must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls to ensure food safety. Although the preventive control provisions have a strong focus on preventing the presence of pathogens in food, the new regulations also include important food allergen controls. Part of implementing a FSMA-compliant food safety program is recognizing contaminants that can be controlled by an effective prevention-based sanitation process. This means implementing sound commercial real estate strategies to help identify and minimize the risk of microbiological, physical, and chemical contaminants.
Keep It Dry
Microbiological contaminants can depend on the type of product and the processing steps. Pathogenic organisms, like Salmonella, E. coli, and Listeria, can result in sickness, hospitalization, and even death. For this reason, they are of great concern to consumers, the food industry, and regulatory agencies. Because microbiological organisms require water and food to live, one approach to minimize their hazard is to deny them these essentials. This leads to the facility design principle that if a plant is normally dry, keep it dry because removing water once it is present is difficult.
For plants that process liquids and are normally wet, design characteristics should ensure that water does not accumulate and that surface areas can be easily cleaned. In practice, this means designing and constructing floors, walls, ceiling, and supporting infrastructure that prevents the development and accumulation of water. Ensuring that HVAC and refrigeration systems maintain specific room temperatures to control air dew and prevent condensation can also help to control microbial growth. Further, control systems that include a purge cycle (heated air makeup and exhaust) to manage fog during sanitation, and to dry the room after sanitation, can reduce the likelihood of foodborne pathogens.
On the Surface
Frequently food equipment is made of stainless steel because it is resistant to corrosion and can be polished so that food and dirt cannot easily cling to it. It is important to ensure that welds are smooth, corners rounded, and the equipment designed so that it can be taken apart and inspected. These requirements follow from the second essential of microbial life—food. In the course of food processing, many foods form films on surfaces with which they are in contact. These films can harbor microbes. If the surface is rough, the film is difficult to remove and it may be hard to detect whether the surface is clean by inspection. For the same reason stainless steel is used in equipment, it may be chosen for building mezzanines and work platforms. At first, this can seem like an expensive proposition but, in the long run, it is often a cost-effective decision. Stainless steel does not require painting, as would carbon steel structures. Further, unprotected mild steel or carbon steel will corrode in a wet atmosphere and the rust could then become a physical food contaminant. Even if thoroughly painted, paint can chip and also become a physical contaminant.
The exact design and building components for a particular food facility will vary according to the circumstances, but making sure that all building components and construction materials are appropriate and conducive to food safety should be a priority. Food safety can be affected by floor surfaces, wall finishes and coatings, and design items such as walk-on ceilings, so consider finishes such as impervious, resinous floors that are easy to clean and allow for improved sanitation in processing and packaging areas. For wall finishes, specify concrete masonry walls with a block sealer and an easily cleaned high-performance coating or insulated metal panel installed in a vertical orientation. Design and install utility systems using appropriate construction materials that are cleanable to a microbiological level and prevent niches or crevices where dirt can accumulate.
Up In the Air
In a dry plant, where dust is a concern, flat surfaces should be minimized. Dust can harbor insects, attract rodents, and even become a potential explosion hazard. Many food dusts from flour, sugar, and starch are explosive in certain concentrations, which can occur in confined spaces, such as ductwork and equipment. A slight spark or static electricity in such an environment can cause significant damage. A good way to combat this is by ensuring that the facility design contains a dust collection system, which is a vacuum pneumatic system with connections to hoods over bag dump stations, mixers, and other locations where dust can be generated. It is important to note that the dust collection system can exceed the explosive concentration limit in its ducts and receivers. As a result, all electrical equipment must be spark-proof and the entire system correctly grounded, so static electricity does not build up and create a spark. As a practical matter, the dust collection system must be inspected and cleaned periodically because dust can build up in ducts to the point that the system is no longer effective.
Controlling the quality and flow of air through a food processing plant is vital to food safety, especially air that flows to the “heartbeat zone” of the plant where the product initially becomes ready to eat. Air quality in this zone must be of the highest quality. Food at its most vulnerable point in the process is where operations need to be the cleanest. Also, air from raw-product zones in the facility must travel in the opposite direction and exit directly from the plant. These important requirements can be accomplished by designing and installing HVAC and refrigeration systems that adequately filter air to control contaminants, provide outdoor makeup air to maintain specified airflow, minimize condensation on exposed surfaces, and capture high concentrations of heat, moisture, and particulates at their source.
Chemical contaminants of most concern are allergen proteins. Some of the most common and significant allergen contamination concerns for food manufacturers include eggs, soy, wheat, milk, fish, peanuts, and tree nuts. Proteins are often left behind as residue on production surfaces, which can result in cross-contamination and cause severe allergic reactions. One facility design strategy to minimize this hazard is to establish distinct hygienic zones and maintain physical separation that reduces the likelihood of contamination from one area of the plant, or from one process, to another area of the plant or process. There are also other benefits to this strategy, such as the ability to keep one line operational while another line is down for maintenance or the ability to separate allergens on adjacent lines to diminish cross-contamination concerns. While previously the FDA urged manufacturers to avoid the unintended presence of allergens in food, the industry is now required by FSMA to avoid the unintended presence of allergens in foods through a series of specific preventive controls. If these preventive controls fail, are not followed, or are followed but undocumented, the food may be considered adulterated and misbranded by the FDA and subject to mandated recalls.
Finally, one of the most important principles of good sanitary plant design is to incorporate interior spatial design that enables ample space for inspection, cleaning, and maintenance. It is often difficult to justify additional space in the design phase because equipment dimensions are rarely well known; therefore, initial layouts may seem sufficient but frequently as details are filled in, space becomes tight. At the same time, costs almost always rise and the easy way to cut costs seems to be to reduce size. This is quite often a mistake. Incorporating FSMA’s rules is likely to require additional costs and could affect project management scheduling. In the long run, however, the up-front cost to ensure FSMA compliance will be less expensive than non-compliance.
FSMA is the first major overhaul of our nation’s food safety practices since 1938, and includes sweeping new regulations for facilities that process food. This new preventative approach will affect many aspects of food production—including the design of commercial facilities—all of which will mean substantial change for food manufacturers. By understanding the requirements of FSMA and incorporating them into the design and operation of food processing facilities, manufacturers can ensure their commercial real estate strategies are aligned to help them meet the requirements of this new law.
Tolliver is head of industrial research, Americas, at Cushman & Wakefield. Reach him at firstname.lastname@example.org.