Food processing companies all over the world continue to improve their overall sanitary performance and produce safe foods, labeled properly and in compliance with all regulatory standards; however, all one has to do is read the daily food industry news updates and it is evident that there is still lots of room for improvement. Recall after recall, there are indications that employee hygiene and good manufacturing practices are not being followed and companies are not leveraging their most powerful tools, their employees, to control the process and prevent these events.
Food-processing companies invest hundreds of thousands — if not millions — of dollars to build food-processing plants and install the very best processing equipment they can buy. These investments are only the beginning. The next step is to staff the facility with qualified employees, followed by the development of a process control system that outlines the procedures required to produce safe food products. No matter what the food product, companies should have well-written, defined procedures for everything the plant can do to consistently and safely manufacture products that are sold at retail and commercial food businesses. Once those procedures are in place, the employees must be trained on the role they play to operate and monitor the entire process and produce safe foods free of bacterial contamination.
One of the most important operating programs is employee hygiene. The manufacturing of food must be accomplished in a sanitary environment with employees who understand the importance of cleanliness in the workplace and comply with the company requirements. These programs are more than just hand washing and clean garments and should cover a variety of employee hygiene requirements that help prevent the contamination of food products.
A lot of information that outlines the regulatory standards for processing plants and the oversight of employee hygiene is available. The U.S. Food and Drug Administration (FDA) outlines its requirements in the Code of Federal Regulations (CFR); Title 21 and the U.S. Department of Agriculture (USDA) outlines its requirements in the Sanitation Standard Operating Procedures (SSOPs) in the Code of Federal Regulations Title 9; part 416.
Some of the basic elements for employee hygiene outlined in these programs are:
- Current good manufacturing practices
- Sanitary operations
- Sanitary facilities and controls
These regulatory guidelines contain a significant amount of information that can be used to assist companies in developing operating programs and training of staff on hygiene. The company should use these resources and write operating programs and outline all of the requirements that will be followed to adhere to the regulatory standards and address employee hygiene programs.
Many companies only consider basic elements of employee hygiene for training. These may include hand washing, proper clothing, and hair and beard nets, typically outlined in plant-specific Good Manufacturing Practices (GMPs). But there are many other factors that must be considered when a company develops and operating program and trains employees. Employee hygiene programs should extend to the following types of programs as well:
- Foreign object controls
- Allergen controls
- Glass and brittle plastic controls
- Sanitation controls, cross-contamination, foreign material and soils
Hand washing and personal hygiene
One of the most important requirements in any type of food establishment is hand washing. We know bacterial contamination plays a significant role in the transmission of disease and yet very little focus is put on monitoring and verification to ensure employees are washing their hands properly.
There are a number of ways to monitor hand washing, but before we begin to monitor we need to be certain employees have access to hand-washing stations that are properly equipped with an anti-microbial soap, clean paper towels and trash receptacles. Appropriate signs must be placed at hand-washing areas to remind employees of the requirements. Hand-washing stations can be strategically located to facilitate employee compliance. Their locations must be considered during the initial phases of plant design and construction.
Once all of the proper tools are in place, we need to verify compliance. This can be accomplished by assigning trained individuals to monitor hand-washing stations. Direct observations of hand-washing activities can then be documented and used to verify compliance with company requirements. Many companies use automated hand and boot wash stations that can capture the data to verify compliance with the company requirements. This data can be downloaded and provide appropriate records for regulators and auditors.
Employees should be trained to wash hands before starting work, between tasks and before working with food products, equipment, utensils and work clothing. Correct hand washing includes cleaning the backs of hands, palms, lower forearms, between fingers and under the fingernails using warm water and soap, and preferably a fingernail brush.
The CDC recommends the following to ensure proper hand washing :
- Wet your hands with clean, running water (warm or cold), turn off the tap and apply soap.
- Lather your hands by rubbing them together with the soap. Be sure to lather the backs of your hands, between your fingers and under your nails.
- Scrub your hands for at least 20 seconds. Need a timer? Hum the “Happy Birthday” song from beginning to end twice.
- Rinse your hands well under clean, running water.
- Dry your hands using a clean towel or air dry them.
Employee clothing and tools
Employees should be required to adhere to acceptable hygiene standards when coming into the workplace. They should wear clean clothes, their hair should be clean and fingernails must be properly cared for. Food processors must provide employees with the proper clothing for in-plant use that creates a barrier between the employee and the product. These can include coats/smocks, plastic aprons or plastic sleeves, hairnets, beard nets, gloves and required tools, as well as personal protective equipment. Laundering of employee clothing must be controlled by the company in order to ensure these items have been cleaned and sanitized adequately before being worn in food processing areas. Documentation should be available to show the efficacy of cleaning and laundering, especially for garments used in post-lethality packaging areas.
Foreign object controls, including glass and brittle plastic
Many companies vaguely refer to foreign object controls in their plant specific GMPs; however, the risks are very high for foreign objects to be introduced into products or included in raw materials used to manufacture food products. Employees should receive adequate training on the risks and what their roles are in preventing the occurrence of foreign object contamination.
Employees are powerful tools for observing the process, raw materials, the plant environment and the finished product for foreign objects. The workforce sees all of the processes and the plant daily and can identify risks that should be addressed to prevent or eliminate foreign object hazards. Employees are the first line of defense to observe and report foreign object risks.
A loose bolt, a crack or a missing part on equipment can and will be observed and reported if employees know their roles and there is a process in place for reporting and correcting the things they discover. Once employees are actively engaged in this activity as part of their job, the company will find the risks from foreign material contamination will be significantly reduced.
Employee hygiene has an impact on your allergen control programs. When an employee works in an area of the plant where allergens are being used and then, in the normal routine of their jobs, must go into other plant areas that are not using allergens or are using a different allergen, their actions or lack of action can create the opportunity for contamination of a food product. Allergen contamination or product ingredient mislabeling are the leading causes of recalls in the U.S. today. Given this fact, it is extremely important that employees are well trained on allergen controls and how to prevent contamination or cross-contamination and the risk of a product recall.
Sanitation controls, cross-contamination, foreign material and soils
“Keep it clean at all times.” This should be the motto of all food plants. Keep it clean to reduce bacterial growth and contamination during the actual process of producing foods. There are many reservoirs and dead spots in sanitary equipment and in the plant environment that allow for the buildup of foods and food ingredients. Food plants operate long hours and these residues and buildups can harbor bacteria — which given the right amount of time, water activity and a food source — will grow to high levels. These high bacterial counts can contribute to contamination of food products and create a risk for consumers.
Having programs in place for periodic cleaning and sanitation during operations is important. Employees should be trained on what they need to do in their area of the plant to maintain sanitary conditions at all times, identify and report issues that could represent risks and actions to take when they identify a potential product contamination.
Building an empowered employee hygiene program
Employee hygiene is a critical aspect of any food operation and yet companies seem to struggle with developing and implementing an empowered program that utilizes employee oversight at all levels to hold the team and individuals accountable for compliance. Training is the key, along with discipline. Leadership is critical.
Hand washing is not just hand washing if it makes your children, family or friends sick, or perhaps endangers the lives of those who have compromised immune systems, or harms a consumer. The same can be said for allergen or foreign object controls. Training has to be realistic and point out to employees why we do what we do to control things in the manufacturing environment. It is not about compliance with some regulatory statute or even the company programs so much as it about protecting ourselves and those around us who we care deeply about. Empowering employees at all levels to help monitor the plant, the process and the product is the only way to prevent product contamination.
Once trained, employees must receive constant retraining on critical aspects of their roles in preventing foodborne illness and contamination of foods. It is imperative that managers and supervisors not only comply with their company’s employee hygiene requirements but also constantly monitor employee activities to ensure proper controls and actions are in place to prevent food contamination and reinforce the standards established by the company.
The old adage “do as I say, not as I do” does not help to enforce the importance of these programs. Managers and supervisors must set the example for employees in all plant hygiene programs. They should be the first ones at the hand-wash sinks, or picking up a broken piece of wood from the plant floor. Or perhaps they should be the ones helping their employees inspect equipment for loose nuts and bolts or a crack that could harbor bacteria. This on-the-job training and reinforcement goes a long way in creating the right environment for a great employee hygiene program. Trained, empowered employees help the company realize the full potential of its investment. NP