Don’t overlook those overheads

Was it just a consequence when the Jul. 25, 1996 MEGA REG was published in the Federal Register, that SSOPs were to be implemented by all FSIS / USDA Establishments in 1997, whereas, HAACP was tiered in, based on the number of one's employees over a three (3) year period?

USDA / FSIS knew well that industry needed to get cleaner not only the interior and exterior areas, but personal hygiene practices of employees as well - that's why.

Yet many people had said that the tiered implementation was because HACCP was draconian.

Come on ... please.

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Last year, I wrote a Meatingplace.com blog on how filthy forklifts, hand/powered jacks, and plastic/wooden pallets were often overlooked and allowed to roam in raw and ready-to-eat (RTE) and not ready to eat (nRTE) processing areas.?

Another area that’s commonly overlooked are those dirty overheads.

Ring a bell?

You know, those hard-to-get-to areas that require forklift cages, scissor lifts, and/or a variety of OSHA fall-protection equipment that’s needed to be donned in order to clean and sanitize. Many plants have those hard-to-get-to areas — especially older plants.

Today’s more modern plant designs have ceilings constructed of smooth impervious surfaces with easy-to-clean light fixtures, while minimizing unnecessary overhead conduits as well as engineered air flow to help obviate condensation.

False ceilings (pop-up panels/non-permanent) can spell trouble because they have a proclivity to rust on the supportive T-bar - become damaged over time, and collect and disperse dirt/rust/flaking paint/mold/moisture/condensation/grime, and can be prime areas for pest harborage, including Listeria growth (via airborne droplets/aerosolization in RTE plants) and other airborne pathogens, while being very difficult (biofilms) and time consuming to clean and sanitize on a regular basis.?

It doesn’t matter if it’s your annual announced or un-announced Global Food Safety Initiative or third-party good manufacturing practice audit - today’s auditors know better than ever where you might not want them to look at - and is informed at the opening meeting exactly who are the assigned Sheriffs and their important Deputies - to ask questions.

If your company employs a contracted sanitation company /vendor that cleans your plant or if the cleaning is performed internally - I would - as an auditor / consultant want to interview the designated lead person and their assigned Sheriff and her/his Deputies and observe her/his body language when the frequency of cleaning is questioned concerning the ceilings and other peripheral overhead structures/items.?

What a clear tell-tale sign(s) that nearly always conveys, and that’s simply because selected plants overlook the overheads or --- allows perilous procrastination to settle in and take hold - not too unlike what biofilm enjoys doing.?

{A biofilm comprises any syntrophic consortium of microorganisms in which cells stick to each other and often also to a surface. These adherent cells become embedded within a slimy extracellular matrix that is composed of extracellular polymeric substances}.

Next, I’ll take a glance at their always tale-telling 'Master Sanitation Log' and with the help of a notepad, scribble down what the official frequency is for those overhead ceilings, cross beams, rails, light fixtures, cat-walks, electrical/water/air/CO2 lines, vents, fire sprinklers, fans, micron filters for air exchangers, refrigeration units, etc., and then take a look out on the floor.

No two auditors or consultants are the same. Yes auditors have templates / time parameters to follow. I prefer out on the floor where all the action is.

Oh, yea!

Any time Homo sapiens are involved in anything there's mistakes (old habits R hard to stop) that may very well be exposed. I have never-ever been a Gotcha-Auditor / Consultant - I always wanted to remain objective and see all plants do well because I know "oh too well" how tough monthly - monthly as National School Lunch audits can be - with six (6) years of being one of several responsible for the monthly audits by ISO 9000 trained and humane handling accreditation by qualified AMS auditors. The time and preparation for any audit is time consuming and 99 % of plants being audited have put forth their very best to be the best.

If I can be convinced at the get-go that the paperwork trail of several SSOPs are in line, it actually allows me to really look, explore and see what is really going on. Because being out on the floor is so, so vital - though so is the paperwork - but I put much more value on observing production, shipping and receiving, maintenance and mid-shift clean-ups.

When I do step into production, this is where the real ground zero is located. This is why I have always stressed the dire importance of a solid and qualified Human Resource Dept., and the on-going training of the plants most valuable employees - the employees in of themselves. After all - employees are the ones doing the hard labor on a daily basis.

Past non-compliance records cited by FSIS / USDA assigned Inspector-In-Charge and naturally any changes to the plants SSOP, HACCP and planned and improvement plan. Auditors are expecting to see several signatures and dates included - and then - interview those people and then - check their documented training records, and then, check the signature register and then go back, back, back... examining with a fine tooth and comb and look for white-outs / scribbles (yes, I still see lazy white outs), and dates, dates, dates ... signatures and initials that should B symmetrical with training records of each applicable employee's assigned job(s). Finally, I shall interview in English or Spanish applicable employees.

Critical areas??

You’re damn right they are — and then some.

Are any overhead objects direct product contact areas?

No, but they can potentially be harbingers of cross contamination (physical, biological) if neglected.

Looking on top / underside of false ceilings in the past has yielded "unknown roof leaks," from above.

The last time I looked, overheads R directly over exposed raw, nRTE or RTE products, packaging materials, wandering people, and equipment. Besides, Sir Isaac Newton’s 17th?century universal law of gravitation still rings true in the 21st?century.?

Grated catwalks/open stairs over critical areas should have a catch pan underneath in order to eschew anything from dropping down below. A detailed Risk Analysis would be ideal here along with historical data. So too with micron filters in RTE rooms that would involve the Sheriff and Deputies involving maintenance and then repeat --- as I would look where they store food grade grease and --- their color coded food grade grease applicator(s).

I’ve always advised (as a consultant) establishments to cover tables and all production equipment with?disposable, unique color coding coverings?when cleaning the overhead areas; especially when refrigeration coils, drip pans and exhaust fans/vents are cleaned.

This is really super-critical at nRTE, RTE plants, particularly in and around post-processing areas because of Listeria. One would expect to see extra cleaning and sanitizing was / is being done and documented as such at nRTE, RTE facilities. And if ... outside vendors are involved ... you tell me what you need. Record review time? Yes.

I'll then check to see how often the disposable unique color coding equipment covers are kept and how they are cleaned, sanitized and stored. A well documented Risk Analysis based on random total plate counts and ATP testing would be ideal to snuff out my rear flank attack on the plants right flank. Finally I would check records, records, records with signatures and dates... .

Don't think that Listeria only plays hide-and-seek in your floor drains: once it becomes established, it can move anywhere within your plant and can even take flight like Superman just like the Covid 19 virus did / does via sneezes and coughs.

It’s easy for Listeria to get established in such wet locales as overhead refrigeration units and the like because of the ubiquity of collective nutrients, moisture, oxygen, pH, competitive micro flora, and room temperature that can exist in such areas; and can be super difficult to eliminate once established. Some USDA plants eventually had to tear down sections of their facility because they were not able to eliminate Listeria.

Another susceptible area is those hanging electrical / water / CO2 lines that are within easy reach of production personnel. It’s so elementary to tell whether these apparatuses are being cleaned daily or not. Production personnel have an uncanny knack of handling these and then going back and touching product contact areas and/or the products themselves. Not prudent, unless one has specific / SSOP’s / Risk Analysis written and implemented.

I always cringe before inspecting hanging electrical cords that aren’t being used that have plastic caps snapped shut at the end to protect the outlets during wash down (and please, don’t have plastic bags/tape temporarily tied around them!).

I’ve lost count how many times I’ve observed meat residual, mold and moisture inside those electrical caps that are just a small step away from exposed products and product contact areas/items. The same can be said for electrical wall outlets with protective caps.?

Eliminate all overhead items that are no longer needed.

When you do, you’re eliminating potential rust, dust, mold and myriad other physical and microbiological hazards with one fell swoop.

So many times plants are caught with their paws in the auditors cookie jar (and the resident USDA Inspector-In-Charge - via a 9 CFR 416 non-compliance record being issued) by not doing what their own creative Master Sanitation Logs claims they’re doing and get penalized; needlessly.

Base your cleaning frequencies on historical data that’s unique to your plants exclusive sanitation needs and then validate that they are indeed being executed as written and intended.?

8/28/2015 Meatingplace.com (revised 03/19/2022)

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Currently, Steve Sayer is a workplace safety *consultant #accredited auditor to *OSHA, *EPA, *#GFSI, *USDA, *FDA, *Human Resources, *#and Humane Handling of feed birds and animals and is a technical writer for multiple industries, as well as a part-time maintenance worker for California State Beaches.

(The views and opinions expressed in this blog are strictly those of the author.)

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Beginning next Wednesday, Mar. 23, 2022,?I'll begin posting a 15-part series of one-a-week blogs?that shall describe a generic HACCP System for Beef Harvesting (Slaughter) - A step-by-step description as per the Beef Harvesting Flow Chart pictured.

I'll still post other blogs each week along with the 15-part Beef Harvesting series - and - I'm keeping each individual blog to no more than 800 words or less - (Good luck General Armstrong on holding down your word-count(s) ).

Have a good weekend everyone.