11 replies to this topic

[PatGear]

Hi,

 

Currently I'm having a dscussion with my productin manager. I think the standard of cleaning the production areas is not good enough at this moment. We can find accummulated product and spiderwebs in corners etc.

We have a low risk product and the microbiological results are excellent, and this is his reason for not putting more effort in the cleaning.

I tried common sense, did not work, now I would like to have a clear standard so I can throw that at him ;-)

 

But the 852/2004 and the TS 22002-1 are both quite general in how clean the non contact materials/areas should be, is there a standard / ordinance that is more specific about the "hygienic condition"?

 

I found this text:

 

"Nonfood-contact surfaces of equipment shall be kept free of an accumulation of dust, dirt, food residue, and other debris." and this suits me very well, but it was in some American standard, is there a European standard which has this criteria?

 

Or maybe someone can point me out where to find the definition of "hygienic condition "?

 

Thanks! 

 

[Gerard H.]

Dear Pat Gear,

 

You are making a good point and I agree with you, that the situation you described is undesirable.

 

Indeed REGULATION (EC) No 852/2004:

 

http://eur-lex.europ...ELEX:32004R0852

 

CHAPTER I -- GENERAL REQUIREMENTS FOR FOOD PREMISES (OTHER THAN THOSE SPECIFIED IN CHAPTER III)

 

What is mentioned first:

 

 

1.

Food premises are to be kept clean and maintained in good repair and condition.

 

Reading your post, there is a need for more hygiene training and awareness of your personnel.

 

Kind regards,

 

Gerard Heerkens

[Charles.C]

Hi,

 

Currently I'm having a dscussion with my productin manager. I think the standard of cleaning the production areas is not good enough at this moment. We can find accummulated product and spiderwebs in corners etc.

We have a low risk product and the microbiological results are excellent, and this is his reason for not putting more effort in the cleaning.

I tried common sense, did not work, now I would like to have a clear standard so I can throw that at him ;-)

 

But the 852/2004 and the TS 22002-1 are both quite general in how clean the non contact materials/areas should be, is there a standard / ordinance that is more specific about the "hygienic condition"?

 

I found this text:

 

"Nonfood-contact surfaces of equipment shall be kept free of an accumulation of dust, dirt, food residue, and other debris." and this suits me very well, but it was in some American standard, is there a European standard which has this criteria?

 

Or maybe someone can point me out where to find the definition of "hygienic condition "?

 

Thanks! 

 

Hi Pat,

 

Some attempts to answer yr query from a micro. POV are summarised here -

 

http://www.ifsqn.com...ces/#entry60958

 

Alternative approaches to "micro" also exist, eg via ATP measurements (as discussed in many threads here).

 

Unsurprisingly, food-contact surfaces tend to be prioritised from a quantitative POV. Apart from the typical "Hygienic condition",  i can only recall non-food contact surfaces being singled out in some EMP zoning layouts, notably for specific pathogens.

[PatGear]

We do take swabs also of non food contact surfaces, but the results are ok, we have a very dry product with a very low microbiological growth. No help from that side...

 

A part of the problem is that the managing director is really pushing on efficiency and saving costs, so the cleaning is not directly on the priority list. (Managing director is not responding as I would like too, so I am looking for some ammunition ;-))

 

I am currently working on a training and I would like to give the cleaning-chapter some more weight by having some legislation explain why they need to put more time in the cleaning programme. But I think I just need to get my wolfe teeth and growl a bit harder at them.

 

Thanks for the input!!

[CMHeywood]

If you have spiders, you will have flies and other small insects.  The spiders need to eat something to survive.

 

If you have product that is building up in the machines, will the accumulation build up to the point where it is falling back into the product you are processing at the time?

 

What micro are you testing for?  Could there be micro present that you are not testing for the presence.  Once a dry food product becomes damp or wet, it will likely have high micro activity.

 

Spiders and product left in your machines is not hygienic.  Are you certified to any food safety standard?  There should be something in the standard about cleaning.

 

Document what your production manager has said, possibly by email since that will provide a record of communicating to him in writing.  Let your product manager know, that if you ever have a recall, then it's his head that will roll.  Does your plant manager agree with the production manager?  Copy him on the email.

[Ryan M.]

Have you done any salmonella swabbing of those area?  It would be interesting to see those results....

[PatGear]

We are testing for several pathogens in our finished product and occasionally perform listeria/staphylococcus/salmonella swabbing. All results on pathogens are always negative, so their reasoning is "no pathogens, no risk".

 

We are FSSC 22000 certified, this standard isn't very specific about the cleaning.

 

I have been very clear to the managing director (on email) that the current state of hygiëne is not acceptable and we will have a serious problem when there is an inspection from the authorities. But I think the inspection I did together with the managing director this week did ring some bells as he has put this subject on the agenda of the next managementmeeting and we got budget for extra cleaning hours and investment on improving a part of the process. He agreed with me it wasn't acceptable, so I now have a little hope again we are going to make progress.

[Ryan M.]

Hmm....interesting, but pathogens can be tricky to find environmentally. What does "some" mean? How often and how many samples when you swab? Do you always swab for multiple pathogens? An effective environmental pathogen program should have a target pathogen based on risk and targeted areas with a specific frequency and number of swabs.

Be aware..FDA is doing over a 100 swabs for facility when they do their inspections.

[PatGear]

Our sampling plan is quite simple and random at this moment, since we are producing a low risk product, but nevertheless the hygiëne should be good and I surely will take all your advice to upgrade the monitoring, better safe than sorry.

 

Thank you for the input, nice to have some backup here ;-)

[Charles.C]

Hi,

 

Currently I'm having a dscussion with my productin manager. I think the standard of cleaning the production areas is not good enough at this moment. We can find accummulated product and spiderwebs in corners etc.

We have a low risk product and the microbiological results are excellent, and this is his reason for not putting more effort in the cleaning.

I tried common sense, did not work, now I would like to have a clear standard so I can throw that at him ;-)

 

But the 852/2004 and the TS 22002-1 are both quite general in how clean the non contact materials/areas should be, is there a standard / ordinance that is more specific about the "hygienic condition"?

 

I found this text:

 

"Nonfood-contact surfaces of equipment shall be kept free of an accumulation of dust, dirt, food residue, and other debris." and this suits me very well, but it was in some American standard, is there a European standard which has this criteria?

 

Or maybe someone can point me out where to find the definition of "hygienic condition "?

 

Thanks! 

 

Hi Pat,

 

The answer to queries regarding generally implemented official numbers relating to hygiene indicators for fcs or non-fcs is that they simply don't exist.

 

However some individual countries do have their own quantitative requirements. As per the link in Post 3.

[usmanashraf]

But spider can cause contaminaion

[Charles.C]

But spider can cause contaminaion

 

Because it has a web ??