Build a fortress to prevent pathogen invasions in your facilities
NEWTOWN SQUARE, Pa., Dec. 4, 2013 /PRNewswire/ -- According to the US Centers of Disease Control and Prevention, more than 48 million Americans are stricken with food borne illness every year.1 Many people remember the 1982 Tylenol incident2 which caused changes in consumer packaging, and the 2009/2010 Tylenol recalls3 4 due to the chemicals traced back to treated wood pallets.
The next big event in food protection occurred in 2011, with the Food and Drug Administration's (FDA's) Food Safety Modernization Act (FSMA) legislation. Still, in 2011 there were four large E. coli outbreaks; 2012 saw recalls in six states due to a Listeria outbreak; and, in 2013 the FDA has issued an average of 11 recall notifications per week.
In the rush to reduce the risk of pathogen contamination in U.S. consumable food and pet food manufacturing facilities to meet the FDA's FSMA legislation, companies have convinced themselves that they are prepared to respond and prevent the risk of contamination. However as positively as those improvement efforts are regarded, they often don't account for obvious gaps: just as a glass of water that is half full is, at the same time, half empty.
Every processing room and area must be viewed as a castle, or fortress, with reinforced walls or barriers. Inside your castle, keep all material handling items—pallets, forklifts, bins and more—secure inside the fortress walls. All incoming material handling items—ingredients transported on supplier-provided skids or pallets—should be kept out of the castle.
As an example, an international manufacturer of gravies and sauces has implemented a process to test all incoming ingredient shipments, their secondary packaging and their mode of transport. The testing determines if the incoming product has been exposed to restricted pathogens. Operations personnel recently discovered that incoming shipments of product, traveling on a 9-block pooled pallet, were shipped on a truck trailer floor damp with liquid from a previous delivery. After testing the liquid on both the trailer floor and the incoming pallets that came into contact with it, restricted pathogens were discovered. Had the inbound pallets—now contaminated with pathogens—been permitted into to the plant, the potential for cross contamination to the food products made there would have been extremely high.5
So how can you turn your human food and pet food plant into a castle to reduce the risk of cross contamination?
Think of your facility as a fortress with a series of defenses. Your first goal is to separate your processing areas from the rest of the facility. Don't let inbound items pass through your external walls. Instead, treat your receiving dock like a moat that separates supplied items from the interior spaces until they've been transferred onto a facility-secured captive pallet, bin or tote. Here are a few suggestions:
- Restrict all material handling equipment (such as forklifts, pallets, bins, totes and more) from entering a processing room or leaving a processing area. Ingredients or work-in-process entering the processing area must only travel on facility captive pallets, bins or totes.
- Restrict all external pallets, bins and totes from entering the facility by using of pallet inverters or pallet transfer stations to remove their loads and transfer them onto captive plastic pallets. If a single external pallet is allowed into the facility, it could end up in sensitive areas.
- Color-code your plastic pallets, bins and totes for easy visual identification at a distance, and also to clearly segregate them for use in specific areas. For example, use blue for your processing areas, green for work-in-process storage areas, and black for finished goods storage within your facility.
Note also that the FDA is working to clarify the requirements, currently holding FSMA hearings related to whether a pallet should be "cleaned" or "sanitized." The current act defines clean as "no debris, soil, blood or oil." Sanitized is defined as a treatment method that "uses heat or chemicals to effectively reduce 99.9% of pathogens."
As Margaret A. Hamburg, MD, a FDA commissioner, stated: "We cannot afford to wait until people become ill to realize there is a problem."6
For more information about how you can better align your handling practices with FSMA legislation, please call Polymer Solutions International at (877) 444-7225 or visit the website at www.prostackpallets.com.
1 http://www.cdc.gov/features/dsfoodborneestimates/ (Accessed, May 6, 2013)
2 http://en.wikipedia.org/wiki/Chicago_Tylenol_murders (Accessed, May 6, 2013)
3 http://online.wsj.com/news/articles/SB10001424052970204792404577229072114500132. J&J recalls infant Tylenol. Jonathan Rockoff WSJ February 2012
4 http://www.palletenterprise.com/articledatabase/view.asp?articleID=4045 DeAnna Stephens Baker, Pallet Enterprise Magazine, "Proposed Food Safety Rules concerning Pallet Industry", November 1 2013
5 Site visit May 21, 2013, a Polymer Solutions Customer, Chicago, Illinois
6 Commissioner's Statement on the Food Safety Modernization Act Margaret A. Hamburg, M.D., Commissioner of Food and Drugs December 21, 2010
SOURCE Polymer Solutions International Inc.