Food Quality News reports today on the penalty imposed on the cantaloupe farm owners who failed to implement properly a cleaning system installed which would have included an antibacterial spray. This may have helped to avoid the Listeria outbreak which killed 33 people. The two brothers may face a year in prison and fines of up to $250,000 for each of the six charges.
The essence of the news story is that, in this case, some washing equipment was installed. Somehow it failed to be implemented or used properly. This is exactly the kind of thing which can go wrong if HACCP is not used as the foundation for the implementation and review of food safety controls. This is demanded by law and by common codes of practice such as the British Retail Consortium (BRC Global Standards) Global Food Safety Standards and similar GFSI (Global Food Safety Initiative) benchmarked standards. The fitting of this new equipment should, at this processing farm, have initiated the following sequence:-
- Ensure that the washing equipment was effective and capable of doing the job – check that it is properly specified – does it meet any specified claims, can it be easily cleaned itself, it is hygienically designed. A good start to learn about “food safe equipment” is here www.haccp-international.com
- Take out the HACCP Plan – determine what microbial hazards may be reduced by this new control system, re-determine the presence and nature of any CCP’s relating to this processing step. Amend the HACCP flow diagram and HACCP Plan if needed
- Visit any pre-requisite controls (cleaning, maintenance and calibration come to mind) and amend if necessary including the implementation of records, perhaps including sanitiser addition / concentration + cleaning times.
- Validate the new system – initiate rinse water, product and as necessary swab tests to prove that the antibacterial wash step is effective. Record the strength of sanitiser using test strips or kits. Record and keep this validation data.
- Revisit the microbiological test schedule and amend as needed to prove the sanitising wash step.
- Sign of this new equipment / process as commissioned and fit for use.
The new equipment and step has now been “proved” to be fit for purpose. The likelihood of an outbreak is reduced!