12 replies to this topic

[brookerehberg]

Hello all, 

 

I have just completed our swab study to validate the effectiveness of our footwear sanitation program, but I cannot find any regulatory resources that define limits for APC or Coliform on the bottom of employee shoes. 

 

Quick backstory: We bake combined meals (meats, breads, fillings) to lethality, then cool them, then package them. The food and the packaging room are considered high-risk according to SQF and to our customers due to these steps, so footwear sanitation or separate footwear are a must. We do not have room to change and store shoes separately, and this would be a nightmare for us due to the way product must move through the facility.

 

It is highly undesirable for us to have wet sanitation methods for footwear for multiple reasons, so we've chosen Sterilex Ultra-Step in a traditional footbath mat (no water) as the method to sanitize. 

 

I have the results that show a drastic reduction in both coliform and APC after performing sanitation, but everything I've read so far basically states that you have to figure out for yourself what the acceptable limits are. Is this the experience everyone else has had?

 

Are there references that I am missing? How does everyone else define acceptable vs. not? Thinking I need to get my degree in microbiology next!

[Aartisharma98]

Hello all, 

 

I have just completed our swab study to validate the effectiveness of our footwear sanitation program, but I cannot find any regulatory resources that define limits for APC or Coliform on the bottom of employee shoes. 

 

Quick backstory: We bake combined meals (meats, breads, fillings) to lethality, then cool them, then package them. The food and the packaging room are considered high-risk according to SQF and to our customers due to these steps, so footwear sanitation or separate footwear are a must. We do not have room to change and store shoes separately, and this would be a nightmare for us due to the way product must move through the facility.

 

It is highly undesirable for us to have wet sanitation methods for footwear for multiple reasons, so we've chosen Sterilex Ultra-Step in a traditional footbath mat (no water) as the method to sanitize. 

 

I have the results that show a drastic reduction in both coliform and APC after performing sanitation, but everything I've read so far basically states that you have to figure out for yourself what the acceptable limits are. Is this the experience everyone else has had?

 

Are there references that I am missing? How does everyone else define acceptable vs. not? Thinking I need to get my degree in microbiology next!

Y'all dont have room to change and store shoes separately. - that is not good.

 

Honestly, ask the employees to sanitize their feet properly, swab and record observations in excel. Create a trend chart based on that create a limit or ask your supplier if they can answer that question.

 

Thinking about getting a degree in microbiology? why not? Go for it! 

Edited by Aartisharma98, 09 May 2024 - 05:43 PM.

[GMO]

Testing is not a form of control.  Testing only acts as verification of your control.

 

You have a high risk facility.  For that you should do everything you can to control ingress of Listeria monocytogenes into that facility.  For that you need barrier control including captive footwear.  APC / Coliforms are not the micro-organisms of concern.

I don't really understand the flow / storage area issue if I'm honest.  But if this is ready to eat or ready to reheat (relying on a consumer reheat) I'd really recommend going back and rethinking.

[Tony-C]

Hi brookerehberg,

 

It would appear that you are trying to justify an element that is a clear non-conformance.

 

The SQF Food Safety Code requirements are outlined in 11.7 Separation of Functions - 11.7.1 (High-Risk Processes).

 

11.7.1.4 Staff engaged in high-risk areas shall change into clean clothing and footwear or temporary protective outerwear when entering high-risk areas. Staff access points shall be located, designed, and equipped to enable staff to change into the distinctive protective clothing and practice a high standard of personal hygiene to prevent product contamination.

 

The SQF Food Safety Code defines High-Risk Food as:

Food or food product with known attributes for microbiological growth, physical or chemical contamination, or which may allow for the survival of pathogenic microbial flora or other contaminants which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak.

 

Kind regards,

 

Tony

[brookerehberg]

Good morning, 

 

Thank you for your response. I understand that the testing is validation, the control would be the sanitization. We have a fairly robust EMP and I have never in two years had a positive result for Listeria or Salmonella. I asked our lab and a consultant how I can prove that the shoe sanitizer is effective, and they both suggested testing for the biologicals we are certain to find, doing a shoe swab before and after to compare. 

 

Testing is not a form of control.  Testing only acts as verification of your control.

 

You have a high risk facility.  For that you should do everything you can to control ingress of Listeria monocytogenes into that facility.  For that you need barrier control including captive footwear.  APC / Coliforms are not the micro-organisms of concern.

I don't really understand the flow / storage area issue if I'm honest.  But if this is ready to eat or ready to reheat (relying on a consumer reheat) I'd really recommend going back and rethinking.

[brookerehberg]

Hi Tony-C, 

 

The consultant I spoke with advised that it's possible that you can "change" your shoes into clean footwear through sanitization, and that if proven effective, it could still meet the requirements of the code, as long as the practice is validated. The staff do wear clean outer protective garments as well. 

 

Hi brookerehberg,

 

It would appear that you are trying to justify an element that is a clear non-conformance.

 

The SQF Food Safety Code requirements are outlined in 11.7 Separation of Functions - 11.7.1 (High-Risk Processes).

 

11.7.1.4 Staff engaged in high-risk areas shall change into clean clothing and footwear or temporary protective outerwear when entering high-risk areas. Staff access points shall be located, designed, and equipped to enable staff to change into the distinctive protective clothing and practice a high standard of personal hygiene to prevent product contamination.

 

The SQF Food Safety Code defines High-Risk Food as:

Food or food product with known attributes for microbiological growth, physical or chemical contamination, or which may allow for the survival of pathogenic microbial flora or other contaminants which, if not controlled, may contribute to illness of the consumer. It may also apply to a food that is deemed high risk by a customer, declared high risk by the relevant food regulation or has caused a major foodborne illness outbreak.

 

Kind regards,

 

Tony

[Aartisharma98]

Good morning, 

 

Thank you for your response. I understand that the testing is validation, the control would be the sanitization. We have a fairly robust EMP and I have never in two years had a positive result for Listeria or Salmonella. I asked our lab and a consultant how I can prove that the shoe sanitizer is effective, and they both suggested testing for the biologicals we are certain to find, doing a shoe swab before and after to compare. 

Most companies we had no detection but 2 of these companies i have worked for one of them had presumptive listeria which turned out to be negative and the other positive for listeria. Once you detect its presence its hard to get rid of it. It's good that you have a robust EMP just make sure you maintain it.

 

bdw how are you testing for apc&coliform, also what is the frequency? is it lab or testing in your facility

 

Hi Tony-C, 

 

The consultant I spoke with advised that it's possible that you can "change" your shoes into clean footwear through sanitization, and that if proven effective, it could still meet the requirements of the code, as long as the practice is validated. The staff do wear clean outer protective garments as well. 

employees are wearing same footwear to enter facility, go on breaks/smoke break, exit & re-enter. Outside footwear shouldn't be allowed inside processing area even with proper controls because of the risk. you should bring up area lockers, and changing room for employees in the meeting with the management. 

[brookerehberg]

We use a 3rd party lab and sponge swabs, and I test at least twice a month for the pathogens of concern, and on a rotating basis for other biologicals. 

 

One section of our facility is a raw process area, then we have a transitional area where the goods are baked (transformed from raw to RTE) and then the post-baking cooling and packaging areas. 

 

We have footwear sanitation throughout the facility, but because our processes are fairly dry (except water used in dough), in the past we haven't required separate footwear from inside to outside. 

 

I am in the process of evaluating whether the current sanitation regime is sufficient, thus the testing. I'm at the beginning of a month-long study. If the results indicate that separate footwear is necessary from outside to inside, we would make that change, but entirely separate footwear just for the cooling and packaging rooms doesn't seem to be the best way to go due to the amount and areas of movement, of the racks of baked goods. 

Most companies we had no detection but 2 of these companies i have worked for one of them had presumptive listeria which turned out to be negative and the other positive for listeria. Once you detect its presence its hard to get rid of it. It's good that you have a robust EMP just make sure you maintain it.

 

bdw how are you testing for apc&coliform, also what is the frequency? is it lab or testing in your facility

 

employees are wearing same footwear to enter facility, go on breaks/smoke break, exit & re-enter. Outside footwear shouldn't be allowed inside processing area even with proper controls because of the risk. you should bring up area lockers, and changing room for employees in the meeting with the management. 

[Aartisharma98]

We use a 3rd party lab and sponge swabs, and I test at least twice a month for the pathogens of concern, and on a rotating basis for other biologicals. 

why dont you do q-tip swabs instead of sponge swabs if you are checking APC or Coliform & save $$, also when you notice the number are lowering you can decrease the frequency from monthly, quarterly and then to yearly (also keep the risk in mind, & nature of your business). 

 

q-tip swabs for acc, ecoli/coliform

sponge swabs - salmonella & listeria

Edited by Aartisharma98, 10 May 2024 - 01:43 PM.

[Tony-C]

Hi Tony-C, 

 

The consultant I spoke with advised that it's possible that you can "change" your shoes into clean footwear through sanitization, and that if proven effective, it could still meet the requirements of the code, as long as the practice is validated. The staff do wear clean outer protective garments as well. 

 

Hi brookerehberg,

 

In the circumstances I can only offer 2 pieces of advice:

 

1. Check with a different consultant

2. Ensure your consultant has put that in writing and has liability insurance.

 

Kind regards,

 

Tony

[brookerehberg]

I truly appreciate it!

 

Hi brookerehberg,

 

In the circumstances I can only offer 2 pieces of advice:

 

1. Check with a different consultant

2. Ensure your consultant has put that in writing and has liability insurance.

 

Kind regards,

 

Tony

[GMO]

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.

[brookerehberg]

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.