1. Enhanced Focus on Cross-Contamination Prevention: Module element 11.6.1.2 states that: “… Unprocessed raw materials shall be received and stored separately from processed raw materials to avoid cross-contamination risk.” Using color-coding as a preventive control strategy (6) can significantly improve food safety and decrease cross-contamination incidents. Commonly, zones separate raw and ready-to-eat production areas, help avoid allergen cross-contact, and/or designate tools that should be used on food contact surfaces or non-food contact surfaces. 2. Air-Testing Requirements for High-Risk Processes: Low risk Vacuuming Wiping Scraping Scrubbing Sweeping Compressed air Hosing High risk Module element 11.7.1.2 states: “Ambient-air [in such areas] shall be tested at least annually to confirm that it does not pose a risk to food safety.” This element points to the need for maintaining safe air quality in high-risk zones like RTE prep rooms or exposed product handling areas. The primary method of air quality control is installing and maintaining air filtration/HVAC systems, and while this removes most contaminants, microbes and/or allergens can also become air quality hazards. Certain cleaning methods, like spraying down surfaces with a high-pressure hose, can aerosolize these particles and spread them around a facility. Choosing a lower-risk cleaning method like vacuuming or scrubbing can minimize this effect while still effectively cleaning surfaces. 3. Foreign-Matter Contamination Control: Module element 11.7.3.1 further requires that inspections must be performed to ensure “… plant and equipment remain in good condition, and [that] equipment has not become detached or deteriorated, and is free from potential contaminants.” Buildings and equipment, from hand tools to large machinery, should be cleaned based on risk assessments. Only durable tools that can withstand the operating conditions (varied temperatures, chemical use, and mechanical stressors) should be used. We’ve frequently been asked about the effectiveness of metal detectable bristles in brushes, and if they can help reduce foreign matter contamination. Vikan did a study (8) on metal detectable tools that showed that these bristles are too small to be detected, and furthermore, they break more easily due to their brittle nature. A better solution would be to use color-coded tools that are hygienically designed and have high- quality bristles secured tightly onto the block. 3
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