How do the Cold Storage Facilities comply with the new FDA - FSMA regulations?

Article written for the Global Cold Storage Alliance magazine: Cold Hard Facts

On September 10, 2011, agents from the Food and Drug Administration descended on Jensen Farms, a produce packaging facility in Holly, Colorado, searching for the source of a nationwide listeria outbreak. Four days later, Jensen Farms recalled 1.5 million potentially contaminated cantaloupes. Despite the massive recall, the tainted fruit sickened 147 Americans and caused the deaths of 33 more. Measured in deaths, it was the worst foodborne illness outbreak since the 1970’s when the FDA began tracking such incidents.

In a letter detailing their findings, the FDA cited condensation puddles in Jensen Farm’s packaging facility as the source of the outbreak as well as improperly maintained and sterilized equipment. In late January 2014, the Jensen brothers, fourth-generation owners of the farm, blamed for the contamination, were each sentenced to five years of probation and both fined  $150,000 each.

At the time, the Jensen Farms outbreak was only the most recent in a string of deadly foodborne illness outbreaks during the 2000’s that saw hundreds die from a host of preventable incidents. Congress responded by passing the Food Safety Modernization Act (FSMA).

FSMA Impact on Cold-Storage

Apart from general cleanliness, which is a food safety concern across all links in the food supply chain, preventing frost and condensation are the biggest concerns for the cold-storage industry in terms of FSMA compliance. Condensation is a major risk factor for food contamination and was pegged as the key cause of the Jensen Farms incident in 2011. In addition, the FSMA specifically address condensation dripping onto stored food as a hazard cold-storage facilities must prevent.

A Solution for the Frost Problem

This battle is nothing new for those in cold storage. Facilities have fought against frost and condensation for the entire history of the industry and often, construction deficiencies are to blame. What is new, however, is that to be in compliance with the FSMA, coldstorage facilities must find a verifiable, documentable solution to frost and condensation build-up or risk losing their FDA registration altogether. Building defects are no longer an excuse and must be remedied under the new law.

How do building defects lead to frost and condensation? It’s simply a matter of temperature control and air flow. Most coldstorage facilities do not have perfect building envelopes. Joints between walls and ceiling, entry points for HVAC and plumbing, doors between freezer spaces and loading docks are all passageways where warm air can invade a cold space. And when warm air enters and meets the cold, the result is frost, ice, and condensation..

In the past, facility managers were forced to run refrigeration units at max capacity to fight against this warm air, causing energy costs to skyrocket. When that doesn’t work, some facilities remove ice by hand, resulting in increased labor costs. Often times, temperatures in poorly sealed facilities fluctuate wildly, causing formed ice and frost to condense and drip, bringing all the surface filth down on the food stored below. When you think in these terms, it’s a wonder food borne outbreaks aren’t more common.

So, for cold storage facilities that encounter building defects as a hazard to food safety, what’s the solution? Without a complete facility overhaul or brand new construction, how can these deficiencies be remedied while still allowing for a business to grow and thrive?

Vapor Armour? has created a revolutionary vapor barrier system that we believe is a solution to condensation in cold storage facilities. Vapor Armour ? creates an impermeable barrier between warm, cold, and freezer spaces. A Vapor Armour? team can analyze the exact nature of the facility’s construction defects and identify the precise sources of vapor drive, the movement of warm air into cold areas. Once the vapor drive is located, the patented application of the Vapor Armour? product will create a sealed building envelope, completely eliminating invasive warm air. Vapor Armour? solves issues of condensation remediation, creating a sealed building envelope that requires less energy to cool and eliminates labor costs for ice removal.

A High-Stakes Battle

The fallout from the Jensen Farms incident didn’t end with the Jensen brother’s guilty pleas. Under the threat of over sixty lawsuits, Jensen Farms filed for bankruptcy protection in 2012 and its credibility has forever been tarnished. Even today, lawsuits against growers, inspectors, and retailers still work their way through the courts, and much is left to be decided, but whatever money is divided up, won’t atone for the tragic consequences of their carelessness.

Is the FSMA the answer to our food safety question? That remains to be seen, but for now, the responsibility for protecting our food supply lies squarely on the backs of the growers, harvesters, processors, and storers. And the cost of mistakes are terribly high.