The recent Romaine lettuce recall—two in the last year—has turned the leafy green industry upside down. Flashbacks of the 2006 spinach recall in California’s Salinas Valley haunt the area’s farmers, the same farmers who after the 2006 outbreak implemented stringent practices through the California Leafy Green Marketing Agreement aimed at stopping the next outbreak.

But it happened again. Why?

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Training for on-farm fruit and vegetable operations in the Produce Safety Rule is proceeding. The FDA and state departments of agriculture are offering on-farm educational inspections prior to regulatory inspections in their “educate before we regulate” approach. With the emphasis placed on worker hygiene, soil amendments, wildlife & domestic animal intrusion and irrigation water testing; I wonder if we may be missing an important aspect in post-harvest handling. Sanitation of harvest and packing shed equipment is critical to ensure pathogens don’t become established in the equipment and serve as a source of contamination.

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The beginning of the year brings a time to evaluate the previous year and set resolutions for the next twelve months. As you examine the internal processes at your facility, consider the environmental monitoring data that you put so much time and money into generating. How can you extract greater value from that data to improve your food safety program? Let’s resolve to go beyond reviewing “new” CoAs, updating a spreadsheet of “hot spots” and filing that information away where it’s unlikely to be reviewed again. Continue Reading

Are you experiencing shelf-life issues or increased numbers of Listeria findings in a Ready-to-Eat foods environment? If so, you may want to take a deep dive into your equipment.

Largely, as a consequence of Listeria control efforts, most of us have at least a basic knowledge of hygienic equipment design. In truth, though, we often find inadequacies in the design of the equipment in our facilities, which are magnified with age and/or inadequate maintenance. Couple this with the widespread use of high-pressure water hoses and their ability to drive product residue, microorganisms and water deep inside equipment, and you have all the components needed to create a microbial growth niche. Continue Reading

Hygienic zoning is a key critical preventive control that often does not get the attention that it deserves. The basic concept of hygienic zoning is to divide a food or feed manufacturing facility into defined areas based on food safety risks. This is commonly used to control microbiological risks but also for other segregation needs, such as allergen control, physical hazards or GMO versus non-GMO. Continue Reading

As the Food and Drug Administration (FDA) moves forward with Food Safety Modernization Act (FSMA) implementation, food companies are beginning to realize the need for effective environmental monitoring procedures to minimize microbial cross-contamination and allergen cross-contact. In developing the Preventive Controls Rule for Human Food, the FDA revised the antiquated Good Manufacturing Practices (GMPs) once contained in 21 CFR Part 110 and now published in 21 CFR Part 117. In doing so, the FDA has been very specific in addressing environmental contamination in the revised GMPs and in the new Preventive Control regulations.  Continue Reading

For over 20 years, the food industry has been steadfast in our view of the role of sanitation in classical Hazard Analysis Critical Control Point (HACCP) programs. Our experience with meat and poultry HACCP by way of the International HACCP Alliance and what came later with Global Food Safety Initiative (GFSI) HACCP requirements solidified the supportive role of sanitation as a food safety prerequisite program. We have managed sanitation as a separate prerequisite program, and then used these programs to eliminate the need for sanitation critical control points. However, compliance with the Preventive Controls Rule for Human Food (PCHF) as part of the Food Safety Modernization Act requires a different approach in how we manage sanitation procedures that directly addresses a food safety hazard identified in the hazard analysis. Continue Reading