Whether a food is considered by regulation to be ready-to-eat (e.g., cut and packaged fruits and vegetables) or not (e.g., produce considered to be “rarely consumed raw”), it often is best to consider that just about any produce might be eaten raw and follow application standards and regulations. Take, for example, eggplant. Listed in the Produce Safety Rule as rarely consumed raw, a quick Google search will bring up results for raw eggplant recipes, indicating that at least some consumers are consuming it that way.
Additionally, although FDA recommends that consumers wash all produce thoroughly under running water before preparing or eating it, we all know that this is not always done. In fact, we can probably all recount at least one time that we just wiped an unbagged tomato with the edge of our shirt — or simply rubbed it between our hands — before taking a juicy bite.
In any case, FSMA’s Produce Safety Rule makes it mandatory for covered growers to follow “procedures, processes, and practices that minimize the risk of serious adverse health consequences or death, including those reasonably necessary to prevent the introduction of known or reasonably foreseeable biological hazards into or onto produce.” One such requirement is that of § 112.123(d)(1), which guards against pathogens that can be transferred to produce from contaminated tools and equipment that contact food.
Acknowledging that the wide range and diversity of equipment, tools, and practices makes it impractical to sanitize all food-contact surfaces of equipment and tools used in covered activities, the rule only requires that food-contact surfaces be sanitized when necessary and appropriate, but that producers “always inspect, maintain, and clean all food-contact surfaces of equipment and tools used in covered activities, and to do so as frequently as reasonably necessary to protect against contamination of covered produce.”
One way to maintain the safety of the equipment in your production facility to comply with this rule is by implementing sanitary design practices. “Sanitary design” is not specifically cited in the Produce Safety Rule. The science-based minimum standards of Subpart L — which apply to any fully or partially enclosed buildings used for covered activities, including greenhouses, germination chambers, or other such structures — are intended to prevent equipment and tools (as well as buildings and inadequate sanitation) from introducing known or reasonably foreseeable hazards into or onto covered produce or food-contact surfaces and prevent adulteration. Thus, implementing sanitary design practices, as practicable, in any growing and harvesting facility simply makes good business sense.
Applying Sanitary Design. Attention to sanitary design should begin at purchase, be considered during installation, and become a part of ongoing cleaning and maintenance procedures.
"Attention to sanitary design should begin at purchase, be considered during installation, and become a part of ongoing cleaning and maintenance procedures."
- The most critical components of any equipment — from automatic harvesters to sizers, conveyor belts, preparation tables, tools, blades, and even cartons for transportation — are the food-contact surfaces. According to the On-farm Food Safety Cleaning and Sanitizing Guide from the Iowa State University Extension Service, “Any surface that comes in contact with food, either directly or indirectly, is a food contact surface.” FSMA’s Produce Safety Rule also addresses food contact surfaces, stating that food-contact surfaces — including those of equipment and tools used during harvest, packing, and holding — are potential routes of contamination of produce. Thus, FDA guidance notes, “Food contact surfaces such as equipment that are designed and constructed to be cleanable minimize the potential for contamination of produce.” Because rough surfaces, such as wood, can harbor dirt and microorganisms, the food contact surfaces of any equipment being considered for purchase should be smooth, nonporous and nonabsorbent to allow for easy and effective cleaning. Additionally, the surfaces should be free of cracks, nonreactive/nontoxic, corrosion resistant, and durable. It is for this reason that stainless steel tables and counters are commonly used in processing facilities due to durability and ease of cleaning.
- Check the equipment for niches and hollow areas which can harbor pathogens and pests and be difficult to clean. Ensure the equipment can be easily broken down so all areas are as accessible for inspection, maintenance, and cleaning. Check the equipment legs, tubing, etc.; if these are hollow, they should be hermetically sealed. Inspect edging; rolled edges can cause liquid to collect that can attract and harbor pests and pathogens.
- If purchasing used equipment, be sure you know its previous use. In-depth cleaning and sanitation will be required if there would be any potential for remaining contaminants, and, in some cases, it may be best to bypass it altogether, e.g., if the equipment is old and does not meet today’s sanitation standards, it is of a material that could harbor contaminants from previous use, etc.
- When installing equipment, clearance, spacing, and sequence should be of high priority. That is:
- To enable cleaning, the lowest shelf or platform should be at least 6 inches from the floor and 4 inches from walls. If equipment is to be sealed to the wall, the mount should have no niches or gaps allowing pest/pathogen access and harborage.
- Equipment should be spaced far enough apart to allow for easy access and breakdown as needed for cleaning.
- Produce conveying, processing, and packaging equipment should be installed to flow from incoming/raw to finished/packaged to prevent cross contamination.
Cleaning and maintenance
While these recommendations do not include every aspect of sanitary design for equipment, they provide a solid foundation for the purchase, installation and ongoing maintenance of equipment, particularly as produce growers and producers continue efforts to comply with FSMA’s Produce Safety Rule.