Good morning,
Thank you for your response. As far as barrier control, no items are brought from one zone to another, save for baking racks, which there is no way around as we have to transform the raw items to RTE while on the rack. Shoes would be the only exception, as separate protective clothing is worn in the high-risk area and all implements used in that room live there permanently.
We definitely could use shoe coverings, but it seems like that comes with its own set of challenges, and could lead to more contamination if proper hand sanitation isn't perfectly followed (removing and putting on the covers multiple times per day).
I agree, this is not about passing audits, actual food safety is our top priority. I am in favor of implementing processes that are hard NOT to follow, if you know what I mean. I've always tried to 'poka yoke' when possible. If someone is forced to do a thing just by it being there ( i.e. walking on a sanitizing mat that is directly in their way with no way around it) then compliance is one less thing for front-line workers to think about because it's built into the workflow.
That said, if folks here have tried that and failed or, like in this case, most everyone is saying "that's not a great idea," I'm inclined to re-assess. Before I hire another consultant, I'm just going to ask you all what you do and save myself the expense, lol.
While you're saying your control is the sanitation, that's not an effective barrier control. It will fail from time to time. And if you're not detecting pathogens in your production area, I'd say your EMP is not effective because without robust barriers, they are there. You're just not finding them.
I find that a lot of Technical people and Operations people think in absolutes "this can't be done" etc. What I'm challenging is if you have space for a shoe disinfection area, do you genuinely not have space for proper barrier control? It's not just shoes, it's all the other items which will go back and forth between your zones.
But if you are determined to use the sanitation method, DO understand that it won't fully work all the time and this isn't about passing audits or getting non conformances, it's about food safety. This is why I'm quite worried about the increasing use of dark kitchen type arrangements in the UK. High care and high risk manufacturing was established for a reason. It has pretty good compliance in the UK and we also have pretty low levels of Listeria related recalls and deaths (and often those are from the smaller establishments who totally should not be doing patient feeding). Just my view on it which you can take or leave.