KANSAS CITY — One of the most important ways to keep food safe is to avoid cross-contamination. Harmful substances or disease-causing microorganisms can be transferred from one surface to another by hands, food-contact surfaces, sponges, cloth towels, equipment, storage and utensils.

Food manufacturing environments present many food safety hazards.

“Potential contamination can come from pests and pesticides, as well as proliferation of bacteria from temperature abuse and condensation,” said Stephanie Lopez, vice-president of operations for AIB International. “For products that are not fully encased in packaging during transport and storage, the risks increase to include allergen cross-contact and foreign-matter introduction.”

As with mitigating any type of risk in a manufacturing environment, employee education is paramount, according to Ms. Lopez.

The growth of large-scale production of artisan and niche baked goods has also brought about new challenges, including sanitation and cross-contamination concerns.

“Each bakery deals with a unique and diverse range of ingredients from flour, wheat and yeast to sugar, cream, icing, chocolate and often nuts,” said Tim Hendra, director of sales for Neogen Corp. “With each additional ingredient comes new quality assurance challenges.”

And low-moisture foods and ingredients that haven’t traditionally been part of the discussion create opportunities for unintended food allergens and salmonella.

“Today under the U.S. Food & Drug Administration’s Food Safety Modernization Act (FSMA), there are many items to examine for a robust food safety plan,” said Gina Reo, president of Quality Assurance Strategies and adviser to the American Bakers Association. “When you begin to review steps needed to mitigate risks, it is best to approach thinking from an entire supply chain perspective, from farm to fork. Concentrating on one potential cross-contamination or contact is a strategy that can have significant impact on your preventative controls minimization strategy."

A robust supply chain program review should include assessment from the farm or source, as well as supplier verification of activities and transportation before material enters a manufacturing facility, according to Ms. Reo. And don’t forget packaging.

“Appropriate verification activities that are consistent with the food that you are producing, including allergen controls, chemicals, microbiological, radiological or physical contamination are vital considerations,” she said.

Transportation verification should not be overlooked as it can be a vulnerable moment for cross-contact.

Avoiding tainted foods

Food contamination happens when something gets into food that shouldn’t be there. While there are many scenarios that might cause this, most fall under one of three categories: biological, chemical or physical. Biological contamination is when bacteria or toxins contaminate food; this is a common cause of food poisoning and food spoilage. Chemical contamination occurs when food meets chemicals and can lead to chemical food poisoning. Physical contamination happens when objects, like glass or human hair, contaminate foods. Sometimes when a food is physically contaminated, it can also be biologically contaminated because the physical contamination might harbor dangerous bacteria.

"Consumers must trust their food supply, and the industry works tirelessly to maintain that trust." — Matilda Freund, Ph.D., Mondelez International

Producers also need to focus on allergen contaminants.

“It is estimated that 10 to 14 million U.S. consumers have a food allergy,” Mr. Hendra said. “Reactions happen immediately, and the only known cure at this time is strict avoidance of the offending food. Thus, food-allergic consumers have become diligent label readers.”

According to Food Allergen Labeling and Consumer Protection Act of 2004, the term ‘major food allergen’ means any of the following: milk, egg, fish, Crustacean shellfish, tree nuts (e.g., almonds, pecans, or walnuts), wheat, peanuts and soybeans. It is estimated that in the U.S., these eight account for 90% of food allergies.

There are also pathogen and chemical contaminants to worry about. The milling process has little to no effect on the microbiology of wheat flour.

“While low moisture may control the growth of salmonella, it can still survive and pose a risk to consumers,” Mr. Hendra said.

“To successfully risk-manage chemical contaminants and the hazards they present, agri-food businesses must adopt a holistic approach that extends outside of standard prerequisite program and HACCP management techniques to use other strategies,” said A.J. Alldrick, Ph.D., Campden and Chorleywood Food Research Association.

These strategies include Threat Assessment Critical Control Points and the CARVER-Shock method. CARVER refers to Criticality, Accessibility, Recuperability, Vulnerability, Effect and Recognizability, which helps bakers measure impacts of an attack, access to a target, recovery and potential loss.

Separate paths charted

Contamination can happen at any point in the supply chain; it’s an issue that FSMA tries to address.

“In March 2016, a major flour miller was subjected to a class II recall when it was discovered that its wheat was contaminated with peanuts. The source was determined to be the rail cars, which had previously hauled peanuts,” Mr. Hendra said.

This example underscores a major challenge bakery and snack food manufacturers face, specifically commodity-comingling.

Because of this challenge, food safety should exist all along the food chain, starting at the farm.

“Farm handling equipment may be used for multiple foods with less vigorous sanitation controls,” Ms. Reo said. “These should be monitored through your supplier and verified.”

For food transportation, FSMA’s goal is to prevent practices such as failure to properly refrigerate food, inadequate cleaning of vehicles between loads and failure to properly protect food, all of which can create food safety risks. The rule establishes requirements for shippers, loaders, carriers by motor or rail vehicle, and receivers to implement sanitary practices. Specifically, FSMA established requirements for vehicles and transportation equipment, transportation operations, records, training and waivers. FSMA’s rule on sanitary transportation of human and animal food requires that the design and maintenance of vehicles and transportation equipment ensures that they do not cause the food that it transports to become unsafe. For example, vehicles must be suitable for their intended use, adequately cleanable and capable of maintaining temperatures necessary for the safe transport of food.

“Intermediary storage sites may not be qualified for holding foods properly,” Ms. Reo said. “Ensure your supplier has documented audit and verification of all holding facilities. Tanks and vessels used to transport food ingredients are not always exclusively reserved for foodstuffs. Depending on shipper, container controls and cleaning methods, there is potential for residual chemical carryover or ingredients from previous cargoes.”

Safe through arrival

As ingredients come into the plant, good facility design and operating features can protect them from contamination, according to Greg Carr, senior director of project planning for The Austin Co. He suggested beginning with a separate non-allergen receiving dock and painting the exterior and interior of the door with the plant’s non-allergen color code. Delivery trucks may well have allergen and non-allergens, so carefully check inside the truck before unloading for spillage. Provide an airlock at the receiving dock, where delivery pallets can be switched for color-coded plastic plant pallets via a load transfer station. The air lock should be positive to the exterior and negative to the ingredient warehouse. Have a dedicated color-coded forklift for allergens and clean it regularly in case of contamination from a delivery truck. And if there are delivery ports for bulk ingredients, color code and lock them.

This extends throughout the plant as ingredients move through the facility. According to John Koury, architect at A.M. King, allergenic ingredients need to be handled similarly to pathogens. Equipment washdown between product runs is required. Dedicated lines in separate rooms and climates isn’t always possible, but it is recommended. Following the path of carts, trays, bowls or other process equipment throughout the plant, soiled tools and equipment need to be kept separate from clean equipment, as do those handling controlled, labeled allergenic foods. Their storage needs to be obvious. Color-coding can be used to designate the vessels, just as color-coded smocks can be used for employees working in designated areas.

“FSMA is impacting existing facilities that battle possible cross-contamination," said Rowdy Brixey, president of Brixey Engineering, Inc. "The biggest contributors are ventilation systems, compressed air systems, associate traffic and behaviors, and material flow." 

Ventilation systems should be designed so air is not shared between segregated plant areas. Filtration isn’t enough, he explained. Contaminated air exhausting from one plant area can become the intake air for another system. Many plants have this issue, which Mr. Brixey said is correctable; just contact a good industrial facilities engineer. A compressed air system’s intake filter can remove dust but cannot keep allergens from infiltrating the system. Plants should get all intake air from a neutral area or confine the intake systems to isolated locations.

Traffic inevitably moves product through vulnerable places in the plant. Packaging traffic may cross paths with sanitary, ready-to-eat product, or trash carriers from raw areas may be emptied and brought back into food production.

“Controlling pathogens starts with understanding lanes of process and controlling where people and equipment travel,” Mr. Koury said. “In the ideal world of ground-up construction, these scenarios can be planned. However, processes are frequently added to existing buildings in less than ideal configurations.”

Good tracking and, more importantly, strict cleaning protocol with sloped floor drains and full coverage hoses help.

AIB International food safety equipment inspection

Sanitation for recall prevention

Even with isolating ingredients and equipment and the paths allergen-free products take, poor sanitation practices can undo that good work.

“Hygiene, hygienic design and the subsequent monitoring of their effectiveness are of critical importance in establishing and maintaining a safe food supply as well as contributing to the overall success of a food-handling facility,” said Matilda Freund, Ph.D., senior director of global quality for Mondelez International. “All processes must begin with clean equipment.”

To compete effectively in a challenging environment, a facility should be able to incorporate line flexibility and hygienic control. The converse effect can be low production output and the potential for recalls that can impact the company’s livelihood and erode consumer trust.

Different process systems and food products may require different standards of hygiene, according to Gustavo Barbosa-Cánovas, Ph.D., professor of food engineering and director of the Center for Nonthermal Processing of Food at Washington State University. In any case, the design must ensure acceptable cleaning and hygiene conditions. Food equipment must be designed to protect food contents (in processing stage) from external contamination.

“All interior zones of equipment in contact with foods must accommodate easy self-draining of liquid foods and cleaning/sanitizing chemicals,” Dr. Barbosa-Cánovas said. "This is important since accumulation of food or cleaning products in defined internal zones of processing equipment may result in microorganisms and subsequent food contamination, creating hygiene problems in processes.”

To help bakers address these vulnerable points for contamination, AIB offers companies standards, inspections, audits and training.

“We have recently added an audit standard for sanitary transportation, focusing on the sanitation of bulk carriers and the associated truck washes,” Ms. Lopez said. “This addition has been driven by well-known recalls and increased regulation under FSMA for bulk transport.”

Food safety is critical to building consumer trust in the food supply.

“From a food manufacturer’s point of view, the consumer is the No. 1 priority, and the safety and quality of their products is of primary importance. Consumers must trust their food supply, and the industry works tirelessly to maintain that trust,” Dr. Freund said.

But this cannot be achieved without everyone in the industry on board.

“While FMSA regulates cross-contamination, customer safety is everyone’s responsibility," Mr. Brixey said. "By planning ahead and using good hygiene, many plants can become more consumer friendly."

While we take precautions to prevent cross-contamination in the manufacture of bakery and snack products, basic steps to food safety — clean, separate (combat cross-contamination), cook, chill — should be always applied to keep our food safe along the farm to table continuum.

In the future, new developments in analytical testing, such as an increase in detection limits and advances in equipment, might make cross-contamination detection and prevention easier. On the other hand, evolving pathogens and new allergen risks could create new challenges. Continued research and training and updated regulations will be the guide to tackle these challenges and to provide sustainable food safety.