21 replies to this topic

[Seathalos]

Good morning all,

 

Seathalos again. I'm definitely being forged in fire currently, lol. We are currently dealing with sanitation problems, as you might have noticed with my last set of post. I sent out a retest for our presumptive positive, after a week of sanitizing and intensive cleaning, on our wax brushes but it came back as another presumptive positive. It came to my attention during the first PP that they haven't used wax strip in a while because it "causes a big mess", nor were they rotating the brushes during cleaning because "we don't have enough time". (and the issue of them setting up test for false negatives before I started, but I am taking care of the test making the issue null now) 

 

My current plan is to have each and every brush removed, soaked in cleaner/stripper, power washed with a heavy duty washer off site, and then soaked in a high PPM Quat sanitizer. Is there anything else I should do? I am already planning pushing for a rinsate sample post COP cleaning by suggestion from our lab. 

 

I also already plan to push for more frequent cleaning as suggested from a similar post the scampi replied to on wax rollers for an apple packing plant. 

 

Thank yall for all of the knowledge you help me gather already,

 

Seathalos 

[johnct]

Hello Seathalos, 

 

I would also confirm the sanitizer product you are using is still good. Do pH strip test, conductivity, vs.....Verify that the sanitizer is within the acceptable usage range. Not over and not under....

[Shrimper]

Good morning all,

 

Seathalos again. I'm definitely being forged in fire currently, lol. We are currently dealing with sanitation problems, as you might have noticed with my last set of post. I sent out a retest for our presumptive positive, after a week of sanitizing and intensive cleaning, on our wax brushes but it came back as another presumptive positive. It came to my attention during the first PP that they haven't used wax strip in a while because it "causes a big mess", nor were they rotating the brushes during cleaning because "we don't have enough time". (and the issue of them setting up test for false negatives before I started, but I am taking care of the test making the issue null now) 

 

My current plan is to have each and every brush removed, soaked in cleaner/stripper, power washed with a heavy duty washer off site, and then soaked in a high PPM Quat sanitizer. Is there anything else I should do? I am already planning pushing for a rinsate sample post COP cleaning by suggestion from our lab. 

 

I also already plan to push for more frequent cleaning as suggested from a similar post the scampi replied to on wax rollers for an apple packing plant. 

 

Thank yall for all of the knowledge you help me gather already,

 

Seathalos 

 

Seathalos,

 

I have been pushed into the sanitation manager/supervisor role as the QA manager at my plant. An issue that occurred way before my time was developing higher swab counts. No matter how much cleaning was done, or by who it was done, the swabs came back more and more. It took a while to realize but bacterial resistance was the cause. My advice is to have a second sanitizer that is used on one day of the week. We use an acid based sanitizer on Fridays and Quat during the week (my plant typically does not run on the weekends). Hope this help!

[Seathalos]

Thanks all for the suggestions, the sanitizer looks as though it is running as intended. I do have plans to add a rotating sanitizer that is used to limit resistance, just need to find a good acid based one to supplement our use of Simple Green D Pro 5. I also probably have to get portable lights being that the area of concern just does not have enough lighting to allow for proper sanitation, you can't clean what you can't see. I am thinking maybe headlamps but we will have to see what is approved. 

[Shrimper]

Seathalos,

 

I have just read your previous responses to see some of the background info for your situation. I think the direction that you are moving in is great and is the right one. I am not clear on the size of plant you are working with, but a dedicated sanitation team of 3-5 people would surely be enough. As I am sure you are aware, a proper HACCP plan has roots in a strong Sanitation program, so I think this is something that should be expressed to higher ups to emphasize its importance. 

 

As for a acid based sanitizer, there are many on the market i.e. Peracetic acid or lactic acid. Those are the two that I recommend, and make sure to read up/ask about the concentration where you do not have to rinse it off. As for a chemical provider, I know that Zep/AFCO will supply chemicals as well as service any pumps you have. That is something else that may be worth looking into: dosage meters. This takes the threat out of having untrained people dilute chemicals. 

 

For the lights, that is something that needs to be there prior... even for production. Any sort of audit can get you for missing lights as it is a safety concern for your workers. I suggest installing permanent lighting in order to support both production and sanitation. However, for some harder to reach areas, a head lamp might be a good idea. 

 

Hope this helps, and if you need more feel free to ask!

 

Shrimper

[Seathalos]

With us using PAA for our kill step before waxing our apples I feel like I won't be able to use it for sanitation, but there should be more than enough other options I can choose. I'll start taking a look at the options we have to make sure I get the best one for our use case.

 

Unfortunately, at least within the next year, it will be a uphill battle to get us to even have a dedicated team. Or at least that is what it sounds like, when I told the Office Clerk about my plans to try to get a team of 5 she laughed and said "good luck". From what I have gathered the last Ops Manager, he was also a former owner, really pushed everything to do with food safety to the wayside. Not having the line fully clean if they "didn't have the time", refused to properly train production workers and those doing sanitation cause he felt like just throwing them into the deep-end was the right plan, refused to verify any of the paperwork needed, and having them collect false negatives on the microbial test by specifically cleaning/sanitizing the testing spot right before taking a test. And unfortunately the current Ops Manager was his disciple that was given the position after the old one was pushed into retirement by the new owners.

 

Lighting issues more so have to do with the roller brushes being black making hard to see underneath and between them leading to missed organic material (and them not testing for ATP or any other cleanliness/sanitation verification. Just really a ton of compounding issues that have lead to this mess. Sadly most people in production don't seem to understand the importance of food safety being that they are more worried about short term profits instead of long term sustainability and safety 

[Seathalos]

Good afternoon all,

 

I have an update with more questions on how I might want to proceed. While trying to make sure that we had a plan set I was blindsided by the Ops manager telling me that we are not going to do a full tear down of the area that tested presumptive positive twice for Listeria spp. Saying that "we aren't going to have someone from outside our facility tell us how to clean" (in reference to the COP suggestion I originally recommended and that a microbiologist from our testing lab supported), "If you actually looked you would have seen there was wax build up" (an issue I was trying to resolve through the introduction of the portable lights with the difficulty inspect under black brushes without additional lighting), saying that the area is now "clean" (only "confirmation" is from visual inspection, no microbial test nor ATP confirmation as I have not reimplemented the practice as we are waiting on supplies) and him affirming  that he will supervise my testing "to make sure it gets done 'right'". Unfortunately, by being done "right" he means having us take cleaner and sanitizer to the testing location, so we can clean and sanitize the testing areas immediately before taking our swabs. Which can lead to possible chemical adulteration.

 

I have already cited the FDA's recommendation for testing from their Guidance on Listeria listed in doc# FDA-2008-D-0096-0029 and provided them with that information in my latest email. I also requested for the Ops manager to send out what he wanted and was having done for this situation for CA documentation purposes. Unfortunately, it seems like I am only having a conversation with myself in that thread as I have gotten no reply from him and only a single response from the Facility Manager. 

 

Do any of our more seasoned Food Safety individuals have an suggestions on how to progress forward? I can attach any non-confidential documentation that would assist if needed.

 

Thank you for taking time out of yalls day to assist,

 

Seathalos

[Scampi]

2 presumptives and no tear down????????????????

 

 

Run far far away

 

 

Listeria is incredibly difficult to eradicate fully, so you can chose to do a couple of things:

 

1) rip the equipment apart yourself 

 

2) call the FDA with a whistleblower tip

 

3) quit on the spot and then call the FDA

[Seathalos]

2 presumptives and no tear down????????????????

 

 

Run far far away

 

 

Listeria is incredibly difficult to eradicate fully, so you can chose to do a couple of things:

 

1) rip the equipment apart yourself 

 

2) call the FDA with a whistleblower tip

 

3) quit on the spot and then call the FDA

Honestly, if there wasn't going to be a major change of leadership happening within 6-12 months from being sold to a larger company I probably would jump ship. They have plans to completely change out the rollers within the next 3 weeks, but unfortunately the current ops manager only can see the things as a "cost" and not something that needed. Sadly something that was prevalent when the last good Food Safety individual was in charge but with there being 4 years of having people that did not understand nor care about food safety the bare bones food safety culture that was in place was completely destroyed. I might have to go to the higher ups in the parent company but wanted to keep that as a last resort. I really didn't want to go nuclear but I may have to

[Scotty_SQF]

Can you contact anyone in this company that just bought you to explain the situation?  You cannot move forward until you have negative results.  You are putting your reputation and career on the line.  Now is the time to push hard, stand your ground and do not back down.

[Seathalos]

Can you contact anyone in this company that just bought you to explain the situation?  You cannot move forward until you have negative results.  You are putting your reputation and career on the line.  Now is the time to push hard, stand your ground and do not back down.

Just sent a email to the Food Safety Manager about what I should do, and to hopefully pull more support. I could also speak with the owning company's labor analytics about how important this is and the very little support I m receiving. Definitely a fun way to start off my time in food safety lol. FDA contact has been in my back pocket for a while I was just hoping to have the current management realize it is an issue (honestly it is just the operations management that is getting in the way unfortunately, and with them structurally my "supervisor" with the old owner lowering his work load as the Facility Manager)

[Scampi]

Fingers crossed you get the support you need

 

If it's going to be replaced in 3 weeks, just condemn the equipment now--but the surrounding area will have to be deep cleaned as well to ensure there is no listeria in the environment (drains, over head cooling units etc.)

[AltonBrownFanClub]

Make sure to bcc yourself on any emails you send to these other managers.

 

You want to protect yourself when the inevitable happens and someone gets sick.

Make sure you are doing everything you can to convince them and keep records of that. Don't be their scapegoat.

[Seathalos]

Fingers crossed you get the support you need

 

If it's going to be replaced in 3 weeks, just condemn the equipment now--but the surrounding area will have to be deep cleaned as well to ensure there is no listeria in the environment (drains, over head cooling units etc.)

Thank you, I hope I can get it too. I really like working in food safety but how hyper focused people are with short term profits or costs drives me up a wall. If we can handle and mitigate the problems early they are going to keep the cost far lower than if we try to take care of them once it becomes an issue. (this current situation is a good example of it). 

 

Make sure to bcc yourself on any emails you send to these other managers.

 

You want to protect yourself when the inevitable happens and someone gets sick.

Make sure you are doing everything you can to convince them and keep records of that. Don't be their scapegoat.

I did forget to BCC myself in the emails but have been keeping an extensive paper trail of what actions I have taken so far, suggestions I have made, and conversations I have had with outside experts like the microbiologist I work with for our testing. But going forward I will make sure to bcc myself for even more protection. And they for some reason have every single email and password made for the company on a excel sheet. 

[AltonBrownFanClub]

Considering how egregious their actions are, I would suggest downloading all your emails.

If your company uses Outlook, it will be super easy.

 

If I was in your position, I'd be buying a hard drive on my lunch break and making backups immediately.

A $50 hard drive could make a ton of difference if there is ever any legal issue.

 

For example, the emails from the Peanut Corporation of America really sealed their fate.

In your case, it will prove that you are doing everything you can. Good luck 

[Seathalos]

Considering how egregious their actions are, I would suggest downloading all your emails.

If your company uses Outlook, it will be super easy.

 

If I was in your position, I'd be buying a hard drive on my lunch break and making backups immediately.

A $50 hard drive could make a ton of difference if there is ever any legal issue.

 

For example, the emails from the Peanut Corporation of America really sealed their fate.

In your case, it will prove that you are doing everything you can. Good luck 

Way ahead of you emails sent to them, ones to the FSM at parent company, and ones sent to microbiologist all downloaded and consolidated to an off site location for my protection. It isn't my first rodeo in a situation that I have to protect myself. Learn quickly with the how monstrous the US Cannabis industry can be.

[Scampi]

Way ahead of you emails sent to them, ones to the FSM at parent company, and ones sent to microbiologist all downloaded and consolidated to an off site location for my protection. It isn't my first rodeo in a situation that I have to protect myself. Learn quickly with the how monstrous the US Cannabis industry can be.

 

Same here in Canada!  I will never go back to that industry again

[Seathalos]

Same here in Canada!  I will never go back to that industry again

I would love to own my own Microbuisness (In my state you can get a license to grow, produce and sell but you can only have 100 plants post clone stage) but I personally will never get back into the major companies as they are only focused on making as much money as possible. I have done both dispensary and cultivation (head of house Lead tech for cultivation) and the amount of times I have had to deal with adulteration of product from a owner shoving their whole ass hand in a bag of RTU product is mind numbing. Then the issues of not making sure that the facility was completely finished before starting production was the icing on the cake.

[Scampi]

The blatant falsification of records is what blew my mind

 

Don't like the THC values from Lab A?  No worries, send them to lab B---ah that's better, let's use that value (even though the methods were completely different) 

[Seathalos]

The blatant falsification of records is what blew my mind

 

Don't like the THC values from Lab A?  No worries, send them to lab B---ah that's better, let's use that value (even though the methods were completely different) 

"But we need to have the highest THC possible", it irks me how limited understanding people have with cannabis. My old cultivation facility didn't even have floors that would allow the water go to the drain or room/time enough to properly sanitize. Just tried to shove as many plants as possible in each room thinking that they would make bank off of that instead of making sure their process was the most effective way to grow. 

[johnct]

Back in pre-Covid times in Oregon (Portland area) there were small labs that would come to us saying " don't worry we will get you the values you need, we can put on the CoA  whatever you need" 

 

I am out of that game...........

[Seathalos]

Back in pre-Covid times in Oregon (Portland area) there were small labs that would come to us saying " don't worry we will get you the values you need, we can put on the CoA  whatever you need" 

 

I am out of that game...........

That is insane, pretty much the wild west. Honestly shows how we NEED robust regulation in both food and cannabis. And regulation designed by experts of the field instead of old congress people who realized they could make a profit off of something they demonized during their entire career