Cleanliness may be next to Godliness, but it is basic housekeeping for food manufacturers with the less lofty aspiration of not appearing in a Food Standards Agency (FSA) contamination alert. Between January and April, many notices announced that salmonella was found in manufacturers' seeds and seed products. Listeria was discovered in cheese. Glass, metal and rubber had sneaked into other foods. These episodes are embarrassing, but can lead to much more than a red face for manufacturers.
Unhygienic factories cause bacteria, such as salmonella, listeria, E.Coli and campylobacter, to breed. "They can be present on raw food materials brought into factories and may remain on the product and cross-contaminate others. These bacteria can also be introduced to the site by staff and from environmental sources," says Adam Chappell, certification manager at compliance expert, SAI Global.
The hazard analysis critical control points (HACCP) process aims to prevent contamination by seeking to identify and reduce risks throughout all stages of production, from producer to plate. EU law 852/2004 on the hygiene of foodstuffs, introduced in January 2006, requires that food business operators put into place, implement and maintain documented procedures based on HACCP. The Health and Safety at Work Act and Control of Substances Hazardous to Health Regulations and Food Safety Act also aim to ensure food production is safe.
In the UK, local authorities are responsible for enforcing food hygiene law, including inspections. They must produce a Food Law Enforcement Plan, which sets out the measures they will take to safeguard food safety in their area during the financial year. The format is prescribed by the FSA.
The frequency of local authority inspections in the UK depends on the degree of risk from the food business found in primary, or main, audits. Such inspections can range from every six months to every three years, depending on the type of processing undertaken, hygiene standards, the structure of the premises and how well risks are managed.
Individual premises are scored after each primary inspection for a risk rating. This sets the frequency of inspection. During primary inspections, information is gathered from the observation of procedures and processes, including those based on HACCP principles.
Businesses can also sign-up to independent certification schemes. The British Retail Consortium (BRC) Global Standard for Food Safety is designed to help food businesses comply with food safety law and help protect consumers. It was introduced in the UK in 1998 to evaluate manufacturers of retailers' own-label food products, but is now used across food sectors internationally.
Kevin Swoffer, an independent food safety consultant with KPS Resources says inspections look for an absence of pathogens that cause health risks. "Coliform bacteria are the commonly-used bacterial indicator of sanitary quality of foods and water. Coliforms don't cause sickness, but they may indicate that other pathogenic organisms are present.
Moisture and condensation are the enemy of good food process hygiene, explains Dr Roland Cocker, a biotechnology expert and food industry consultant. For example, wetted zones in open processing, such as water lubricated high speed slicers used for slicing cheese and meat, can produce lots of moisture. Such areas tend to encourage listeria.
"However, many processes that are commonly carried out under very wet conditions, such as fish, poultry and meat processing, can be carried out under 'dry floor' conditions, where the liquids and water needed for the processing are confined and collected," says Cocker.
Three of the biggest contributors are plant design, cleaning methods and the factory. "The law tends to be output-based and is embodied in the requirement for food to be safe," says Geoff Spriegel, director of Global Standards at the BRC. "The onus is then on food producers to maintain hygienic plant. Safe food production simply isn't possible without this."
The management of cleaning is audited under schemes such as the International Food Standard and FPA Safe (the audit system of the Food Processors Association) as well as the BRC Standards. The chief requirements of the BRC Standard are the adoption and implementation of HACCP.
Neither EU law nor the BRC Standard is prescriptive about plant cleaning or cleaning schedules within factories. The sheer diversity of food sectors, plant, cleaning regimes makes this impossible. However, the BRC Standard, for example, does state that cleaning and sanitation procedures must be effective, verified and recorded.
Plant design can make a big difference. Spriegel explains that plant manufacturers are factoring hygiene into the design of machinery to enable cleaning-in-place (CIP) regimes that avoid the need for it to be dismantled. "Cleaning can then be automated, which takes out an element of human error - assuming the CIP system is set up correctly," he says.
"The same principles must always apply. One major pitfall is if equipment is modified, but the cleaning regime stays the same. Cleaning regimes should always be checked after any plant modification."
Kelly Griffiths, senior environmental health officer at Bodycote Health Sciences, believes it is often overlooked that cleaning activities and equipment can be sources of contamination. Bodycote provides inspection, microbiological testing and advisory services.
Cleaning methods affect food safety, too. Spriegel says: "There is a double impact in that inadequately cleaned equipment will allow harmful microorganisms to survive and potentially grow in remaining soil or in the next batch of food." Cleaning chemicals must be removed from plant, because they can contaminate food and cause illness. So cleaning regimes must ensure that residues of chemicals are removed by adequate rinsing.
Cocker points out that biofilms, like slimes, may protect unwanted microbes from cleaning and attempts at disinfection. For example, pipes colonised by biofilms may not be easily disinfected by standard CIP and sterilise-in-place procedures. "Instead, they may require mechanical effort to be removed," he says.
Finally, the factory and its fittings must be fit-for-purpose. "All surfaces in contact with foods should be clean, smooth and non-porous so that particles are not caught in microscopic crevices and become difficult to dislodge," says Griffiths. "If equipment is cleaned with CIP it should be proven that the cleaning techniques used are sufficient to remove debris and potential bacteria."
Swoffer points out that premises built after 1970 "may have untreated surfaces and moisture can leach into the building, leading to the growth of mould and bacteria"
With regard to the bottom line, Cocker says the quality of the hygienic design of equipment and factories affects the cost of cleaning in terms of money, labour and downtime. "For example, it is common in open processing to devote one-third of every 24-hour cycle on manual cleaning of lines and the remaining two-thirds on productive work," he notes. In contrast, closed processing with automated CIP may take two down to zero hours.
Ultimately, though, the most important factors affecting factory hygiene are quite simple: the cleaners and how much resource is available to do their job properly. According to Griffiths: "Senior managers need to ensure cleaners don't get buried by paperwork, but must also remember 'the job is not finished until the paperwork is done'." FM
Key Contacts
- Be-Plas Marketing 0800 413 758
- Bodycote Health Sciences 0121 206 4100
- BRC 020 7854 8934
- Cocker Consulting 00 353 212 348 21
- SAI Global 01908 24 9944
- Sika 01707 394444
- KPS Resources 01732 849230