Suitable controls that would allow picking up finished products off the floor

Hello awesome forum members.

I was challenged by our production supervisor and I would like your opinion on this.

Background:

We are packing a ready to eat product that is not supporting growth of any microorganisms( due to its high sugar content, low water activity  and low pH) The policy in place is if a finished product container (that is already sealed and there is no risk of product contamination/) touches the floor it is automatically garbage. The rationale behind it is that the consumers may get sick if touching a dirty bottle ( people usually don't wash they hands after handling food container of ready to eat products). The floors are washed regularly with floor cleaner, there are foot baths with micro quat solution at every entrance to the packing room, there is an environmental program in place, no salmonella or listeria were found ( the program is in place just for a year)

Production Supervisor suggestion:

1. Wiping the bottles that were on the floor with disinfecting wipes and pack as usual

2. Placing a cardboard/plastic sheet under the line, were the product may fall and pack as usual.

I will appreciate if you could share your thought regarding both suggestions.

Thank you!

I was fortunate as a food safety auditor prior to getting into consulting to witness numerous packaged and exposed food falling off the line and onto the floor.

In a cheese plant I watched too many blocks of 4-ounce cheddar bars vying for too little space on the single fed conveyor and thus numerous blocks fell off onto the floor - some actually going into the buckets that were placed on the floor and then watching a worker scoop them up in her apron, look at me and say - "5 second rule" and place them back on the line.

Now, in the same plant I was watched 4-ounce cheddar bars get packaged and drop on the floor too, all of which were scooped up and placed in a hold container to be inspected and then if passed, placed back on the line - some made it back and some did not - was this acceptable, yes.

They checked them for being clean and checked for packaging integrity, the ones rejected were almost always due to having been impacted.

Some places I know skip the checks for the packaged ones and simply toss them out - because many times in a high speed, low profit operation it is cheaper to toss than get into packaging checks, cleaning, etc.

Case in point, I did an SQF audit some years ago in Charlotte, NC at a big soda company that was running upwards of 5,000,000 cans and bottles a day - almost one for one on cans that was fall got dented, so they installed cushion mats and while these do catch a certain percent others bounce off and hit the floor - all in all they ran a study and determined that is was cheaper to toss all of them out instead of having to inspect them. So they went to bursting and recycle.  Bottles faired somewhat better with about 25% recovery.

I would say depending on the composition of the bottle material that I would be more app to put soft cushioning material in rubber bins and place those under the line - but only if it makes $$ sense, otherwise they can go to the employee lunch room or get bursted.

Thank you for your quick reply and for sharing your experience ,Glenn.

In my case the bottles do not get dented and the concern is the contamination of the package from the floor, or am I too paranoiac?

We deal with mostly frozen seafood (fish and crab) with limited fresh.

For the longest time, when product hit the floor, we would pick up the product and dip it into a solution of chlorine dioxide (very effective antimicrobial) at > 50 PPM.

This was common practice for more than 20 years.  Most of the product would be on the floor between 5 seconds up to 25 minutes.

The process was widely accepted by the industry, GOA, and our customers.

About 3-4 years ago, the FDA was audited by the EU Food Safety and during the audit, they announced the EU would no longer accept this practice and would not be legal for product imported in to the EU. 

The reason they did not like this practice was that the product dip gave a false sense of protection.  Although the dip was an FDA 21 CFR 173.325 product that was effective in eliminating pathogens and extended shelf life, they felt it had no protection against foreign material that may have attached to the glaze of the product from the floor. A Glaze is when the frozen seafood is dipped or sprayed with potable water to protect and extend the shelf life of the product.

The industry was given a few years to implement this program. During the interim, most of the plants had to come up with a new program, do a risk assessment and come up with a plan.

A lot of the plants decided to forgo the use of the product dip rather than work a program into it.

Many plants came up with the simple solution of throwing away the product once it the floor.

We do not have this luxury as we do not own the product and the customer would not be very happy with us throwing away product especially when some of these items cost $30-40 a lb.

Our plan was to not use the product dip anymore since we had no knowledge of if and when the customer would send the product to the EU and did not want any rejections ant our cost. We also had over 20 years of data showing the effectiveness of our program.

This is the plan we submitted and did not have any issue.

There will always be areas on the production line where the product has a chance to drop on to the floor.

We would place color coded basket along the section of the belt where product had tendency to fall on the floor.  When the product fell, it went into a basket (suspended from floor) and the QC’s would collect the product and take it back to the lab to rinse and inspect for any foreign material and redistribute to the line.

Thank you for sharing the practices. It is very interesting to learn about different industries.

Our product is in sealed container when it hits the floor, so I guess if we wipe it /dip it in an effective disinfectant we should be ok.

Do you think that we will need to have a validation study to prove that the product is effective, or the suppliers documents should be enough?

We deal with mostly frozen seafood (fish and crab) with limited fresh.

For the longest time, when product hit the floor, we would pick up the product and dip it into a solution of chlorine dioxide (very effective antimicrobial) at > 50 PPM.

 

This was common practice for more than 20 years.  Most of the product would be on the floor between 5 seconds up to 25 minutes.

The process was widely accepted by the industry, GOA, and our customers.

 

About 3-4 years ago, the FDA was audited by the EU Food Safety and during the audit, they announced the EU would no longer accept this practice and would not be legal for product imported in to the EU. 

The reason they did not like this practice was that the product dip gave a false sense of protection.  Although the dip was an FDA 21 CFR 173.325 product that was effective in eliminating pathogens and extended shelf life, they felt it had no protection against foreign material that may have attached to the glaze of the product from the floor. A Glaze is when the frozen seafood is dipped or sprayed with potable water to protect and extend the shelf life of the product.

 

The industry was given a few years to implement this program. During the interim, most of the plants had to come up with a new program, do a risk assessment and come up with a plan.

 

A lot of the plants decided to forgo the use of the product dip rather than work a program into it.

Many plants came up with the simple solution of throwing away the product once it the floor.

 

We do not have this luxury as we do not own the product and the customer would not be very happy with us throwing away product especially when some of these items cost $30-40 a lb.

 

Our plan was to not use the product dip anymore since we had no knowledge of if and when the customer would send the product to the EU and did not want any rejections ant our cost. We also had over 20 years of data showing the effectiveness of our program.

 

This is the plan we submitted and did not have any issue.

 

There will always be areas on the production line where the product has a chance to drop on to the floor.

 

We would place color coded basket along the section of the belt where product had tendency to fall on the floor.  When the product fell, it went into a basket (suspended from floor) and the QC’s would collect the product and take it back to the lab to rinse and inspect for any foreign material and redistribute to the line.

If you wanted to sanitize the bottles and use them -  to validate your process - swab the bottles in the worst case scenario. Take multiple samples of different bottles. Then verify as needed. You'll need to decide how many and how often depending on your process. Also make sure you're checking your sanitizer concentration too.

Thank you! I will need to check if it worth the effort

If you wanted to sanitize the bottles and use them -  to validate your process - swab the bottles in the worst case scenario. Take multiple samples of different bottles. Then verify as needed. You'll need to decide how many and how often depending on your process. Also make sure you're checking your sanitizer concentration too.

Hi Altermanm,
 

A lot of the plants decided to forgo the use of the product dip rather than work a program into it.

Many plants came up with the simple solution of throwing away the product once it the floor.

 

We do not have this luxury as we do not own the product and the customer would not be very happy with us throwing away product especially when some of these items cost $30-40 a lb.

Should be an interesting Risk Assessment.

Likelihood/Consequences of a Negative event versus existing financial losses. Hmmm.

How Risk Averse is yr Company ?

Details of yr Product/Packing are limited but I hope it is not going to the EU.

IMHO "Prevention takes Priority over Cure".

Since you are in Canada and under CFIA Inspection, what are their thoughts on this topic? I have supported our Canadian Factories over the years and CFIA is always on-site each day of production. If a situation like this occurred in one of our factories, we would ask their opinion/guidance since they would have the final say. Otherwise, you might put a practice in place that they will not support and instead take the opposing view on. 

Thank you.

Thank you for the suggestion, I will ask our inspector what do they think,

As we are a low risk facility they only come few times a year, but I am sure they have something to say about it.

Thanks again

Since you are in Canada and under CFIA Inspection, what are their thoughts on this topic? I have supported our Canadian Factories over the years and CFIA is always on-site each day of production. If a situation like this occurred in one of our factories, we would ask their opinion/guidance since they would have the final say. Otherwise, you might put a practice in place that they will not support and instead take the opposing view on. 

 

Thank you.

This.  The concern is picking up any pathogens and other microorganisms from the floor that get transferred during handling of the package.  The handling could be your company, distribution, and out to the consumer.  As kfromNE said, test worst case scenario and see how it fairs.

In our operation the production management got sick of all the scrap so they focused on line improvements to prevent packaging from falling off the line.  You can't get perfection, but the closer you get to it, the cheaper it is for everyone saving money and time.

If you wanted to sanitize the bottles and use them -  to validate your process - swab the bottles in the worst case scenario. Take multiple samples of different bottles. Then verify as needed. You'll need to decide how many and how often depending on your process. Also make sure you're checking your sanitizer concentration too.

I absolutely agree.

Thanks 

This.  The concern is picking up any pathogens and other microorganisms from the floor that get transferred during handling of the package.  The handling could be your company, distribution, and out to the consumer.  As kfromNE said, test worst case scenario and see how it fairs.

 

In our operation the production management got sick of all the scrap so they focused on line improvements to prevent packaging from falling off the line.  You can't get perfection, but the closer you get to it, the cheaper it is for everyone saving money and time.