Examining cantaloupe safety, eVGN June 2013
The impact of increased FDA efforts to ensure safe operations in cantaloupe packing facilities was examined at a recent workshop in Georgia.
The session, at the University of Georgia Tifton campus, outlined how to “Prepare for FDA Microbial Sampling in Cantaloupe Packing Facilities.” The Georgia Fruit & Vegetable Growers Association (GFVGA), the University of Georgia and the Georgia Department of Agriculture (GDA) sponsored the event.
Jud Birdsong, a food processing specialist for GDA, made a presentation with Brad Bush, another food processing specialist with GDA. Birdsong said everything in a harvest and production cycle – from pre-harvest to packing – is now under the microscope of “new surveillance.”
Water quality, pre-harvest inspection, facility design, sanitation, clean break and traceability were among the categories Birdsong highlighted.
“In the past, water quality may have only meant ensuring there was enough water for irrigation and rinsing,” Birdsong related. “Under new surveillance, water quality will be an important part of eliminating contamination during the packing process. Verifying water quality with documentation is going to be critical to the cantaloupe industry.”
Previously, a pre-harvest inspection may have been “no more than a walk to the field to check the growth of the melon to isolate a harvest date, with wildlife being just the nature of the beast. Under new surveillance, pre-harvest inspections of harvest areas for droppings will become a common occurrence, including documentation of observations.”
There was a time when harvest equipment might have been “whatever was readily available to get the job done. Today, closer attention will be paid to harvest equipment and transport trailers to decrease the chance of contamination. All harvest bins should be designed with surfaces that can be cleaned and sanitized.”
A shelter that kept the rain out may have been all that was required for a packing facility in the past, and flow was just an afterthought.
“We must now be conscious of avenues of contamination and how they can occur through production flow – and remove those potential hazards,” Birdsong observed.
It’s no longer a case of sanitation during production taking a back seat to other “raw farm” priorities.
“Under new surveillance, sanitation and documentation of your cleaning practices will be critical. Documentation not only protects your operation and your product, it protects the industry and your customers.”
Birdsong said enhanced food safety concerns have made it essential that a re-design of harvest equipment that takes into account sanitation requirements be considered and implemented.
The idea of a “clean break” was not as critical before as it is today.
“Environmental samples ensure your SSOP (Sanitation Standard Operating Procedure) is working after the facility is cleaned and sanitized. Your documentation of this shows a clean break in production. Product that is packaged before and after these clean breaks are considered different ‘lots’ under the new surveillance.
“For a raw agricultural commodity, ‘traceability’ was not always a major area of concern in the past. Now, traceability and documentation of lots and sanitation practices are essential. If it isn’t documented, it didn’t happen,” Birdsong concluded.
Zones
Bill Hurst, with the Department of Food Science and Technology at the University of Georgia, encouraged packinghouse operators to identify and concentrate sanitation efforts on distinct zones within their operation.
The zones likely to be subject to swab testing by FDA are:
1) Direct product contact surfaces – equipment padding materials, conveyor belts, brush washers, sizers, packout tables and employee gloves.
2) Non-product contact surfaces adjacent to product contact surfaces – such as equipment exteriors, “dead spots” in the line, water nozzles, floor fans, trench drains, employee aprons and shoes.
3) Potential non-product contact surfaces in the process areas that could provide microbial growth niches, notably floors, walls, overhead piping, pests and difficult-to-clean equipment.
4) Areas remote from the packing line that provide microbial growth niches, such as raw material storage coolers, locker areas, restrooms, loading dock and break rooms.
Hurst said Zone 1 direct product contact areas posing possible problems are typically found in padded devices, production line decelerator flaps or wash flaps, employees’ gloves, conveyor guides or frayed conveyor belts.
Zone 2 challenges include water nozzles, cross bars, equipment framing, dirty fans, dirty tools being used on a sanitized conveyor belt and “dead spots” on equipment
Microbial growth niches in Zone 3 could feature blocked drains, cracked floors, exposed cooler drains, refrigeration fans, break room tables and unsanitary restrooms. Open drains and missing caulk on walls and surfaces would be likely sources of concern.
In establishing its own system of environmental sampling, Hurst indicated a company should have a written plan to include what, when and how to sample and who is responsible. The frequency of sampling can vary based on product type, facility, regulatory needs and customer requirements.
“Consistent sampling is critical,” Hurst stressed. “Keep detailed log dates, sampling places, results and corrective actions taken.”
Hurst’s presentation on water sanitation in a packinghouse emphasized that water must be kept clean by sanitizers, particularly when harvest lots are to be mixed together in a dump tank.
Noting that there are no established microbial standards for safe irrigation water, Hurst pointed to a statement by David Gombas, senior vice president at United Fresh Produce Association, that indicated “in the absence of definitive microbial standards for irrigation water, the authors of the California Leafy Greens Market Agreement Best Practices document have chosen to use EPA’s recreational water standards.”
Hurst also addressed well water contamination, stating that condition can occur due to inadequate well construction, well casing failure or a lack of back-flow prevention. He noted that whatever the source for water quality problems may be, when test results exceed acceptable criteria, it’s vital to discontinue its use until the system is back in compliance.
He stated that the benefits of proper wash water disinfectant use would prevent cross contamination and reduce microbial load in water, but it would not sterilize the product.
Be prepared
Beth Bland Oleson, director of education and food safety for GFVGA, said it’s important for packinghouse operators to anticipate what FDA inspectors will be up to when they come knocking at the door. She said the agency will generally provide a 48-hour notice before entering an operation and she advises operators to “use it wisely.”
She said samples will be pulled from incoming product from the field; packed product at the end of the packing line; ready-to-ship items from the cooler, as well as environmental samples.
Retail customers have been known to inform their suppliers to “test and hold” all product from lots FDA has taken samples from “until a clear report is provided by FDA.”
She noted that produce lots are separated by a clean break – when cleaning/sanitation takes place.
“Have written SOPs for all cleaning and sanitizing procedures and a cleaning schedule,” she suggested. “Have MSDAs for all chemicals used in your packing facility. Have as little product in the coolers as possible. Conduct a clean break the morning they are to arrive. Conduct clean breaks throughout the day and/or when they leave. Avoid using high-pressure washers daily, as it can aerosol microbes and potentially spread them.”
Oleson advised operators to keep notes of what and where FDA conducted samples and make notes of any questions inspectors might have posed.
“Get ready now – after pre-season cleaning and sanitation,” she suggested. “Conduct microbial sampling throughout your facility. It’s much better to know you have a problem and fix it before produce is introduced.”