A pathogen equation that helps identify cross-contamination risks
In 1999 as director of field quality for Kraft Foods, I faced a pathogen-related recall in Oscar Mayer foods, and there was debate about the cause and future prevention. Some thought the contamination was good manufacturing practice (G.M.P.)-related; some conjectured it was related to poor raw/R.-T.-E. separation; others pointed a finger at sanitation. We needed to align our priorities and focus our efforts to design a fix.
As the leader of the team tackling that challenge, I had to address it within a cross-functional team and then develop priorities and expectations to minimize the potential of this ever happening again. We needed a road map for making science-based improvements that would minimize the risk of pathogens getting into finished products. I developed a pathogen equation that I hoped would be the road map.
Pathogen control = hygienic zoning + GMPs + clean, dry, uncracked floors + effective sanitation controls + hygienic design of equipment and building
That pathogen equation was hygienic zoning + GMPs + clean, dry, uncracked floors + effective sanitation controls + hygienic design of equipment and building = pathogen control. It aligned priorities across multiple plants and a big organization like Oscar Mayer. This equation — and its variations — has become a food safety mainstay and is used across the food industry as well as trade groups.
The baking industry is now adopting this approach with added complexity in building design, aging equipment and cross-contamination risk.
The industry’s main raw ingredient — flour — can carry pathogens. In the ingredient handling area of a bakery, there is usually some residual flour dust that could carry any number of pathogens. Preventive controls ensure raw flour will not carry over via dust drifting, ventilation, employees, fork trucks, equipment, wheeled carts and equipment layout. Overlaying these situations with the pathogen equation often provides some insight into the risk and its management.
Here are a few of the prioritized steps that could be a guideline for what comes first in a bakery.
Hygienic zoning provides guidance to separating raw product from baked product and general areas. As an example, this would apply to equipment used to transport baked product to a recycling area and raw product to the same area. This equipment needs to be cleaned prior to returning to the R.-T.-E. area.
GMPs also need to be a control point. Employees entering a RTE area would need to be free of raw flour residue, a hair net or a frock change and, of course, washed hands to reduce cross-contamination.
As new measures are implemented, educate employees on the reasons for the new practices. They are much more likely to adopt the new practices if they understand how they will impact the consumers and the company.
As new measures are implemented, it is important to educate employees on the reasons for the new practices. They may have followed the same GMPs or traffic pattern for years and simply telling them to change will not be sufficient. They are much more likely to adopt the new practices if they understand how they will impact the consumers and the company.
Completing a comprehensive risk assessment using the pathogen equation as a guide can provide for identification and adoption of many programs to help control cross-contamination in RTE areas of a bakery from raw flour and other contaminants.
As new measures are implemented, it is important to educate employees on the reasons for the new practices.