washing vegetables, antimicrobial effectiveness and food safety modernization act (fsma) ·...
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Washing Vegetables, Antimicrobial Effectiveness and Food Safety Modernization Act (FSMA)
Brian Zomorodi Apio Inc. USA
October 27, 2016
VEGETABLE INNOVATION LAB 2016
Washing Vegetables, Antimicrobial Effectiveness Food Safety Modernization Act (FSMA)
• New Food Safety Regulation in US; FSMA • Produce Microbiological Contamination • Risk Based Food Safety & Preventive Controls • Produce Washing; A Friend or Foe • Wash Water Dynamics & Chlorination • Validating Effectiveness of Wash Water • Validation Options • Conclusion • Q&A
Food Safety Modernization Act (FSMA) A New US Food Safety Regulations
• Food Industry is held more accountable and liable to produce safe foods
• Raw Agricultural Commodities (RACs), are treated more like Ready-To-Eat
• Focus on Supply Chain Food Safety; Fresh produce food safety cannot be achieved without food safety of the entire Produce Supply Chain
• Risk Based Preventive Controls to eliminate or substantially minimize hazards
• Validations/Verification • Foreign Supplier Verification
1. Produce Rule Standards for the Growing, Harvesting, Packing, and Holding of Produce Affects Farm and Re-packing Operations
2. Preventive Control For Human Foods Food Safety Programs for production
Affects Processing Facilities and Re-packing Operations
3. Preventive Controls for Animals 4. Foreign Supplier Verification Programs
Imported food with same standards as US Affects Foreign Suppliers
5. Third Party Accreditation; Rules that governs auditing bodies
Affects Auditing Companies
6. Mitigation of Intentional Adulteration (Food Security)
7. Sanitary Transportation Preventing food contamination (Adulteration) during transportation Affects Distribution and Transportation Companies
FSMA at a Glance
Washing Produce All Fruits and Vegetables Come in Contact with Water
• Water & Produce
Packing House Washing Mango
Washing Salads
Sweet Corn Cantaloupe
Washing Spinach
Produce Microbiological Contamination
• Produce Contamination is very Rare • Mostly Unpredictable; It’s Sporadic & Random • Normally Affects Small Quantity of Product • Water Can Spread Contamination • Proper Wash System and Effective Antimicrobial Use
Can Prevent Cross Contamination • Antimicrobial Effectiveness Depends on Key Factors
such as Organic Load, pH, Type of Vegetable • Continuous Antimicrobial Dosing & Automated
Monitoring System are Necessary to Manage Production Variables
• Wash Water System as a Preventive Control
Risk Based Food Safety & Preventive Controls
Identify Hazards
Understand Causes &
Risks
Develop Preventive
Controls
Validate & Implement
Preventive Controls
Monitor & Verify
Effectiveness
Review and Adjust
Hazard:
Pathogen
Cause: Raw Contamination
Risk: High
Preventive Control: Preventing Cross Contamination in
Wash System Using Antimicrobial Implement:
Reliable Sanitizer injection and
Control System
Continuous Sanitizer Level
Monitoring
Review Verify and
Adjust
Wash Water Effectiveness; A Preventive Control
CCP: Free Active Chlorine Level
Validation
Washing Produce; “A Friend or Foe”
Why Do We Wash Produce? • Cosmetic Improvement • To Reduce Initial Microbial Load • To Remove Latex and Soil, Etc. • To Make it Safer…..?
Washing fresh produce; An opportunity to clean, or contaminate?
Quotes from Dr. Devon Zagory
Washing & Produce Cross Contamination
• Water is an excellent medium for dispersing and spreading Microorganisms
• Small amount of contaminated produce can contaminate large quantities of produce (many lots)
• Washing does not decontaminate produce • Once Contaminated, its Difficult to De-contaminate Contamination During Washing
– Via Products (surfaces/inside) • Via Particles (small pieces of produce)
– Via Water (Cross Contamination)
Opportunity for cross-contamination Is the highest in wash systems
Washing & Product Contamination
• Pathogens can adhere strongly to the surfaces • Some surfaces can attract and support bacteria • Internalized Contamination is possible
Damaged surface makes it difficult to dislodge pathogens
Washing Does Not Remove All Contaminants
• Produce surface is complex and hard to clean
Unwashed E. coli On lettuce
Washed E. coli 100 ppm Hypochlorite
Post Washed E. coli
Washing Does Not Remove All Contaminants
Contamination Via Water
Improper management of the wash system and antimicrobial level can lead to produce cross contamination
E. Coli in water and on Produce
Properly implemented Wash System can prevent cross contamination via water
Wash Water Dynamics & Chlorination
• Chlorine is the most widely used Sanitizer
• Wash System: a Complex Dynamic Environment
• Preventing Cross Contamination Depends on the Effective Level of Free Chlorine (FC) in the Water
• Effectiveness Depends on Multiple Variables: – Temperature, pH, Organic Load (Turbidity,
Conductivity/COD), Sanitizer Concentration, Product Water Ratio, Contact Time, Source Water Quality
– The main factor is the level of Free Active Chlorine in the system to destroy pathogens, if they are present
Free Chlorine Availability Depends on Depletion Rate of the Sanitizer in the System
Wash Water chlorination Key Points
• Properly managed wash system can prevent microbial cross contamination
• Free Chlorine level changes based on system variables
• The key is how a system maintains the FC ppm at a constant level by properly responding to variables
• At this time the best validated level that can prevent cross contamination is 10 ppm of FC
Validating Effectiveness of Wash Water; A White Paper
Wash Water Validation Group;
“VALIDATING EFFECTIVENESS OF WASH WATER TO PREVENT MICROBIAL CROSS-CONTAMINATION FOR FRESH-CUT LEAFY VEGETABLES”
A collaborative document by Produce Industry Experts and Regulatory Agencies’ Scientists
(FDA and USDA)
This is a work in progress
Wash Water Validation
• Definition; Obtaining scientific and technical evidence that a control measure, when properly applied, is capable of effectively controlling an identified hazard to produce safe and unadulterated products
Validation Options
Option 1: Cross-contamination is prevented under worst case operational condition, using product inoculated by pathogen or suitable Surrogate
– Validation by pathogen can only be performed in specialized and dedicated facilities (IFISH), not in commercial environment
– Can be used to develop critical limits for Antimicrobial levels
– Can establish Base Line Validation Model
Surrogates Microorganism and DNA Based Tracers are being developed
Validation Options
• Option 2: Validating minimum antimicrobial level is achieved under “Worst Case” operational conditions, as shown by sensors
• “Worse Case Scenario” is when the wash system during production is pushed to its limits, operating at the upper limits of all or some of its critical variables, (Simulated Model)
Produce Industry can use this option to validate their own system based on the Effective Sanitizer Level identified in the Base Line Validation Model
Validation Options
• Option 3: Minimum antimicrobial levels are maintained in each processing run, without considering worst case conditions
• Validation is based on: – Placement of sensor(s) in the lowest
concentration point in the wash system
– Demonstrating that system can maintain the minimum level at all times
This option while requires mapping of the wash system, it is more practical for processors to validate fresh produce wash lines
Conclusion Safe Fresh-cut Vegetables for Consumers
• Produce Food Safety Depends on Supply Chain Food Safety • Preventive Controls are necessary to assure produce food
safety • Washing Produce can be a Preventive Control • Washing Is not a Kill Step, the goal is to prevent Cross-
Contamination • Produce washing can be a complex system; needs to be
understood and managed • Improper Wash Systems, can cause cross contamination
and expand outbreaks • Wash Systems must be Validated for effectiveness • Validation options require further development to become
widely accepted and practical
Questions
THANK YOU