Food Protection Trends - July/August 2022 - 331

Joe Meyer (Kerry) provided advice to food company
personnel on how to respond when receiving a 483 notice
or noncompliance record after an FDA or USDA-Food
Safety and Inspection Service (FSIS) inspection. He
emphasized the importance of understanding any findings
that arise, ideally by talking directly to the inspector and
asking questions during the inspection. Make sure the exact
locations swabbed are understood and agreed upon in terms
of the hygienic zones cited.
For responses to the findings, strive to avoid " firefighting. "
Rather than trying to meet an arbitrary completion date,
generate a detailed and realistic timeline and list of activities.
Do not be afraid to ask experienced outside individuals for
advice. Make sure that anything promised to regulators is
realistic and can be maintained.
Meyer discussed the differences between corrections,
corrective actions, and preventive actions. A correction is
some kind of containment or procedure designed to be a
short-term fix for a problem, for example, a temporary repair
to a damaged floor. A corrective action is a long-term solution
such as a permanent repair to the floor. A preventive action
goes a step further and tries to ensure a problem cannot
happen, for example, having a routine inspection plan for
the floor to ensure that cracks are identified when they first
appear and repaired before they become a problem.
The panelists discussed the 2017 FDA draft guidance on
control of L. monocytogenes in RTE foods (19). The FDA
suggested that when a zone 1 (food contact surface) sample
tests positive for Listeria spp., the product does not have to
be put on hold unless repeated positive results are obtained.
However, many of the panelists said that they take a more
conservative approach than the draft guidance suggests,
testing first for L. monocytogenes before releasing product or
only following the guidance when the food product does not
support the growth of L. monocytogenes.
BREAKOUT GROUP EXERCISES
A unique component of this virtual meeting was the
use of small (two to six people) breakout groups, each
tasked with considering a hygienic zoning strategy and
EMP for a real-life food facility during the manufacture
of a specific food product. Expert facilitators (listed in
the " Acknowledgments " ) were assigned to each group to
guide discussion. Multiple breakout groups were assigned
to the same food products, with opportunity for groups to
share their conclusions with others. The four food products
discussed in the breakout groups represented broad food
product categories.
(i) Low-moisture foods (corn tortilla chips). Discussion
facilitated by Jeff Kornacki (Kornacki Microbiology
Solutions), Kristin Schill (Food Research Institute,
University of Wisconsin-Madison), and Elizabeth
Grasso-Kelley (Division of Food Processing Science
and Technology, FDA).
(ii) Frozen foods (frozen peas). Discussion facilitated
by Lory Reveil (American Frozen Food Institute),
Malavika Sinha (Lamb Weston, Inc.), and Stephen
Grove (Nestlé USA)
(iii) Assembled product (frozen RTE sausage, egg, and
cheese on a muffin sandwich). Discussion facilitated by
Kara Mikkelson (Hydrite Chemical Company), Kristy
Herlitzka (Kwik Trip, Inc.), and Annette Stich (Tyson).
(iv) Plant-based protein (plant-based " cheez " dip).
Discussion facilitated by Cindy Austin (University of
Wisconsin-Madison), Erin Headley (Schreiber Foods),
and Adam Borger (Food Research Institute, University
of Wisconsin-Madison).
More information (food product details, facility map,
production process, etc.) regarding three scenarios can be
found in the supplemental material available at http://digital.
library.wisc.edu/1793/83210.
Breakout groups working on the same food product
often came up with similar ideas, as summarized in Table
1. However, differences in approaches were also noted,
underscoring there are no universal " right " answers when
designing environmental monitoring, sanitation, and
hygienic zoning strategies. The individual facility and its
history and each company's resources and experience will
drive these decisions.
CONCLUSIONS
The meeting helped participants think about and discuss
hygienic zoning, microbial harborage sites (and their
prevention and elimination), and environmental testing
strategies in food manufacturing environments. Many of the
speakers discussed causes or sites of microbial contamination
in food processing environments that might easily be
overlooked when sampling, including the following.
* Wheeled equipment
* Shoes
* Air handling systems
* Equipment: when acquiring new equipment, choose
equipment that is easy to disassemble (preferably
without tools), easy to clean, and compatible with
cleaning agents and sanitizers or thermal interventions
* Tools and maintenance equipment, construction in the facility
* Potential damage (pitting, rust, etc.) to equipment from
the product (especially acidic or high-salt products) or
environment (moisture, humidity) that might increase
the risks of microbial contamination
* Repairs (welds, etc.) to equipment that might create
new bacterial harborage sites
* Tables, carts, etc. that may not be designed for the food
processing environment
* Electrical panels and junction boxes (including those
attached to equipment)
* Infrastructure: e.g., floor material and repairs to the floor
July/August Food Protection Trends 331
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Food Protection Trends - July/August 2022

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