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Unintended Food Contact Surfaces
38 Plays3 years ago
Food contact surfaces are extremely important to keep clean in order to reduce the spread of pathogens. When we think of areas that produce comes into contact with, we typically think of a table or a harvest container, but what are some other surfaces that aren't usually considered? In this episode, Produce Safety Technicians Micah Hutchison and Landen Tetil talk about certain food contact surfaces that may be unintentional and how you can keep these areas clean.
Funding for this podcast was made possible in part by the Food and Drug Administration through grant PAR-16-137. The views expressed in the posted materials do not necessarily reflect the official policies of the Department of Health and Human Services, nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
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Transcript
Introduction to Produce Safety Podcast
00:00:00
Speaker
Hello and welcome to the Agri-Food Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule. I am Micah Hutchison. I am the Produce Safety Technician at the Genesee Conservation District located in the Greater Flint, Michigan area. And I work with growers on the on-farm implementation of the FSMA Produce Safety Rule.
00:00:30
Speaker
And I'm Landon Tiedel. I'm the produce safety technician in the Upper Peninsula of Michigan. I'm based out of the Marquette County Conservation District, and I service the whole UP doing the same thing Micah does, working with growers on farm to look at what kinds of food safety things they already have going on and ways we can maybe improve.
Understanding Food Contact Surfaces
00:00:51
Speaker
All right. So Landon, to you, what is a food contact service?
00:00:56
Speaker
I mean, I think when we think about the term food contact service, it's pretty straightforward. It's anything that touches food, right?
00:01:06
Speaker
I think that sometimes it can trick people on farm when we're talking about food contact surfaces, because almost always they forget to mention their hands as a food contact surface. And so that's kind of like a, a gotcha. But other than that, I think it's pretty straightforward. Anything you're going to use to touch produce is a food contact surface.
On-Farm Risks and Prevention
00:01:31
Speaker
I agree, Landon. Anything that touches food is a food contact surface.
00:01:36
Speaker
And definitely hands are a gotcha. They are maybe the thing that most consistently touches fresh produce. But when I first started this role, I never thought of hands as being a food contact surface. I thought it was something more traditional like a table or a harvest container. Yeah, hands are one of the most common and also maybe one of the dirtiest.
00:02:00
Speaker
Yeah, they're definitely dirty. I'm thinking about how many times our hands touch our phone. Or our faces or our hair or like our dogs. So many things. So many.
00:02:15
Speaker
And then you add a farm into the mix and you're like, your hands are in the dirt. You know, maybe you're using soil amendments that are from animal origin. So you're working with compost or manure, which makes it a whole new level of dirty and just like regular farm dirt. Yeah. I definitely think of like working with chickens or chicken litter and how that can
00:02:40
Speaker
if not proper hand washing, that can definitely affect your hands as that food contact surface.
The Four Food Contact Zones
00:02:47
Speaker
Yeah, or mixed use farms that they have livestock and produce on the same farm and you're going back and forth and doing chores for both. Not only is that a risk making your hands dirty, but there's a risk of carrying contaminants with your boots going across the forth too.
00:03:08
Speaker
We're digressing, I think, from the food contact surfaces there. It's so easy to get off track when talking about on-farm food safety because everything so affects everything else. Do you want to talk about how we rank the different zones of food contact surfaces? So there are four zones. They're kind of ranked in how
00:03:32
Speaker
closely they directly impact produce safety with zone one being the one that has the most contact or direct contact with produce.
Unexpected Food Contact Surfaces
00:03:42
Speaker
Zone two is outside of zone one. It would be, for example, like a switch, an on and off switch on a washer, which may not contact food contact surfaces itself.
00:03:54
Speaker
but can contribute to the contamination of zone one, say if there is contamination on and off switch and your zone one hands touch that contamination and then can spread it to produce. Zone three is the area kind of around a packing area. That's how I think of it. So the walls, the floors, the ceilings. And then zone four is outside of the packing area that can have some impact on produce safety.
00:04:24
Speaker
Landon, how do you see the four zones? Yeah, I completely agree with how you described it. So zone one are the things that directly touch food, of course. And then zone two is it's like one step out, but it's still the zone that's most likely to affect zone one or infect if in the case of germs.
00:04:49
Speaker
And then zone three would be one step further. So it's not quite as likely a zone two to contaminate a zone one, but it's still possible. And then zone four is just the next step out. Micah, will you go down a rabbit hole with me for a second? Every day.
00:05:08
Speaker
So I wanna, while we're on the topic of zones, you mentioned in zone three, you consider things like floors and ceilings. And I want us to talk about the scenario in which ceilings become a zone one. Ceilings become a zone one.
00:05:25
Speaker
Yes. I've heard of dancing on the ceiling. I've never heard of produce on the ceiling. Well, no, we're not putting produce on the ceiling, but we're talking about condensation, turning the ceiling.
00:05:40
Speaker
into a zone one food contact surface because any dirt that's on that ceiling, when the water collects and forms, it's acting as a vector for any dirt or bacteria that's on the ceiling and dripping onto
Cleaning and Sanitizing Protocols
00:05:54
Speaker
produce. If it's allowed to drip onto produce, your ceiling's now a zone one.
00:05:59
Speaker
That's a great thing to go down a rabbit hole for it, Landon. So what do you propose is the best way to encourage growers to think of that as your ceiling, being a zone one? Well, I think that usually growers don't think of it as that being a possibility until I say that out loud and then the light bulb turns on and it's like, oh yeah, you're right.
00:06:26
Speaker
this is a thing. And so the way I see it, and maybe you've got more insight or other options, the way I see it is that farmers have two options.
00:06:37
Speaker
If they know they have a condensation problem, they can either clean their ceiling so it's adequately cleaned and sanitized as if it were a food contact surface, which is something that no one wants to do, or they can do everything in their power to either stop the condensate altogether by controlling the humidity in that space or making sure that it's never dripping directly onto produce.
00:07:06
Speaker
I'll be completely honest, I'm pretty lazy so I would take the never dripping onto produce. Same. I mean, who wants to clean their ceiling? No one. No one. That brings up. What does the produce safety rule say about food contact surfaces? Oh boy.
00:07:24
Speaker
Well, the Produce Safety Rule was not written to be super prescriptive because they still wanted farmers to have some freedom in the way that they do things and so there is no like
00:07:37
Speaker
hard line in the sand when it comes to cleaning and sanitizing food contact surfaces. I think it only states something like it must be clean for the adequate use. Section 112.123d1
00:07:55
Speaker
It says you must inspect, maintain, and clean, and when necessary and appropriate, sanitize all food contact surfaces of equipment and tools used in covered activities as frequently as reasonably necessary to protect against contamination of covered produce. That's really clear. In other words, who knows? Who knows? So what do you tell growers?
00:08:26
Speaker
So first I always ask if they have a cleaning and sanitizing routine or frequency or schedule already in place. And if they say, oh yeah, it's once a season, my answer is going to be dramatically different from someone who says, oh, I clean and sanitize after every single harvest day. If they're cleaning and sanitizing after every harvest day, I usually say that's perfect. That sounds like you're doing an adequate job.
00:08:56
Speaker
And that's generally what I recommend. If you can do it after every harvest day, that's ideal in my mind. What do you say to growers? I think what I first say is to start looking for crime.
00:09:10
Speaker
start noticing if, say, your harvest bins or your harvest tools are getting, you know, that sheen, it's like a gray, brown, dullish color. Like that biofilm. Yeah, like that biofilm color. There's a color difference on a lot of the equipment I see that as it's dirty, it starts to maybe not change colors, but
00:09:34
Speaker
it's dulls the surfaces. So I first want them to look for the dirt to see that it's there. So it's not just another thing that we're asking growers to do. And then I agree with you getting on a cleaning schedule
00:09:51
Speaker
is definitely something that I encourage. So you know everything's being cleaned at the beginning or the end of each harvest shift or packing shift, or even for really small farms. Maybe it's just once a week, but having that routine cleaning schedule that they're doing and sticking to, and then noticing when things are dirty and training their eyes to see that.
00:10:15
Speaker
Yeah, I think that that's a good way to look at things and I will slightly amend my previous statement that I urge growers to clean every harvest day. I don't say that you have to sanitize each time because that's not what the rule says. The rule just says,
00:10:35
Speaker
when necessary and appropriate. And so in my mind, what is necessary and appropriate for sanitizing is if a known contamination has happened. So if you know that poop has entered your wash pack, then you should do a full sanitize or blood or bodily fluid.
00:10:51
Speaker
Just to take some of the load off growers, there's some growers who like to sanitize after every time they clean and more power to them. But that can get expensive. It can get expensive and I'm not sure that it, if that's what the rule means by necessary. I feel like it's super farm specific. Yeah, so I guess the produce safety rule is pretty vague. I think that's our bottom line here.
00:11:16
Speaker
But I think that's good. It allows growers to kind of tailor their operations to fit into what the rule requires and also what works for them.
Addressing Unintentional Contact Surfaces
00:11:27
Speaker
I agree. Yeah, I think that being non-prescriptive in most cases is a good thing. I totally agree. We've talked about food contact surfaces. What do you think about unintended food contact surfaces?
00:11:45
Speaker
Can you define what you mean by unintended? So those food contact surfaces that aren't like a packing table or a harvest bin or harvest tools, something that might unintentionally contact produce during those activities, but isn't not supposed to, but is kind of unintentional.
00:12:08
Speaker
Yes. So what comes to mind straight away from me is, and I'm guilty of this in my home garden, I'll be out, you know.
00:12:20
Speaker
checking on the garden and oh my gosh, there's three ripe cherry tomatoes or there's two ripe zucchinis, I'm gonna pick them real quick, but I don't have anything on me. So naturally, I carry them up to the house in my shirt. I make a little pocket with my shirt and carry them up. So that's an unintended food contact surface. My shirt was never supposed to be a food contact surface, but now it is. Is that the kind of thing you're talking about?
00:12:47
Speaker
That is exactly the kind of thing I'm talking about. And I do that too. It's nice to know that. We're not alone. We're not alone. My clothes are often unintentional food contact services.
00:13:02
Speaker
Yeah and it's you know so it's different when it's your home use because I'm not selling the produce out of my garden obviously I'm just eating it and gonna prepare it in my home kitchen and eat it with my family. On a farm that's it's really different because that produce is going to be sold and so that is a bigger deal. I guess I would just highly encourage farm workers or farm harvesters to not use that method.
00:13:29
Speaker
and use the harvest bins that were intended to harvest crops in that situation. I agree. I also think it kind of shows the importance of good personal hygiene and like how important it is to wear clean clothes to work every day. Definitely. Because sometimes you might unintentionally like harvest something into an apron or a shirt. And if it's not clean,
00:13:59
Speaker
To me, it just, again, shows how important personal hygiene is and how that part of the produce safety rule kind of ties in with other parts.
00:14:11
Speaker
Yeah, and I think that this is like a really important thing to talk about on farm, especially on smaller farms. I think that there's this mentality of like, oh, I'm a farmer, I'm supposed to be dirty. But really, we want to try to keep ourselves as clean as possible because that helps keep the produce clean. Yes. Here's another unintended food contact surface. What do you think about gloves?
00:14:40
Speaker
Oh, okay. Disposable or reusable gloves? Reusable gloves. Oh, so I think that reusable gloves can get so gross and dirty so quickly within just like an hour of wearing them working on a farm. I feel like there's no good way to keep them clean. If a farm
00:15:07
Speaker
is promoting the use of reusable washable gloves. I think that that's fine so long as they have like a very stringent laundering policy and they don't let farm workers just like wear these dirty gloves over and over and over and over again. Yeah, I think for me, another kind of issue I have with reusable gloves is you can't feel if your hands are getting dirty.
00:15:38
Speaker
So it feels really hard to be able to monitor them while working. Yeah, and then also there's the issue of where do you put them when you're taking a break? Like if you're taking your lunch break or if you're taking a bathroom break, are you taking those gloves into the bathroom with you and then not washing them and wearing them out again? I'd hope not. I hope they were stored somewhere that kept them away from contamination
00:16:08
Speaker
I'd hope that there was a designated area where employees could put those gloves. Yeah. And same with aprons too. If a farm, farm workers are wearing aprons too, there should be a storage spot. And so, you know, there's nothing that says a farm can't use these reusable things.
00:16:29
Speaker
But it's extra work, right? It's extra things for the farm manager, the farm owner to think about when implementing the use of these things. And so do you have a laundry service come and pick them up? Or are you washing them at home? And how often are you washing them? And how are you monitoring your workers to not take them home or to use them properly? Not take them in the bathroom. Yeah.
00:16:56
Speaker
Storage, safe, clean storage spaces for people to set them down while they're on break. Yeah. It's a headache. It's a whole headache. It definitely takes a lot of consideration to use reusable gloves and be mindful. Although the disposable gloves have the same issue that you said, Micah, about you can't really tell that your fingers or your hands are getting dirty.
00:17:25
Speaker
I think there's a false sense of security too, especially with reusable gloves that like I am being safe and thinking that the gloves are the barrier when the gloves may not be the barrier to the produce or food contact surfaces. Yeah. And I think there's this misconception around gloves in general of like, Oh, I have gloves on so I don't have to wash my hands. Yes. I feel like I see that a lot with gloves that gloves are the protection
00:17:54
Speaker
so hand washing doesn't have to happen. And it's just not true. No. A dirty hand and a clean glove is a dirty glove. Very true. You mentioned storage, Landon. What it made me think of are another unintended food contact surface, like knives, scissors, clippers, and how important it is to monitor those tools, as well as, like gloves and aprons,
00:18:24
Speaker
store them and keep them clean.
Harvest Tools: Storage and Maintenance
00:18:27
Speaker
Yeah and I guess I view those types of things like those harvesting tools you're talking about. I view those as like a pretty common sense food contact surface more than an unintended but um because you're using it to touch the food to get it into the harvest bin to get it into the pack shed. But absolutely the way that those are handled and stored and
00:18:53
Speaker
Are they cleaned? Do you actually wash your harvest knives in between uses or do you just set them on the table until the next day you harvest? I think that those are great questions and I have seen a lot of variation on how farms treat their harvest tools.
00:19:13
Speaker
I have too. And honestly, how harvest knives are treated to me is one of the better indicators to a cleaning and sanitizing program for food contact services. What have you seen?
00:19:30
Speaker
I feel like when I show up on farms that have a system in place for the cleaning and sanitizing of those harvest implements, they're usually more aware of how important it is to clean other food contact surfaces. It just seems like if that grower is thinking about harvest knives, they're definitely thinking about other unintended food contact surfaces.
00:19:59
Speaker
aprons or gloves or, you know, something that could be zone two like that washer switch or condensate on the ceilings. And your ideal dream farm, what do you see? What are the steps that farmers are taking to take care of their harvest tools in a way that keeps them clean? I like to see storage in containers with tops.
00:20:25
Speaker
Oh, so they're definitely protected from any kind of environmental or, you know, animals coming in after their clean box. So after they're cleaned, after they're cleaned, they're put in a container until the next with a lid until the next workday.
00:20:45
Speaker
I feel like with every kind of scenario, having that cleaning schedule and having that eye for seeing if things are clean or not
00:20:57
Speaker
kind of like is universal in what it pertains to. So it's not necessarily the aprons or the gloves. It's just really getting a cleaning schedule down that is tight, that is effective for your farm and training yourself to look for when things are showing signs of being dirty and then cleaning them as needed based on what you see.
00:21:24
Speaker
Absolutely. I couldn't agree more, Micah. I think it's all about creating that habit within yourself of that light bulb switching on, of a contamination event has happened. I know exactly what needs to be cleaned. It's like making those associations in your brain so it becomes second nature. Yeah, and I think it's what you said. These events happen so I know what to do. It's not like
00:21:53
Speaker
Okay, these are my unintentional food contact surfaces that I must check. It's kind of like evaluating the whole system and being able to like see and respond to scenarios.
00:22:07
Speaker
Yes, and making it easy on yourself in terms of what you need to get that done. So having cleaning supplies at the ready, like maybe in a caddy you can carry around to different parts of the wash pack or like, or maybe you've got multiple sets of cleaning materials located in places that are going to make it easy to use and accessible and you don't even have to think about it. It's just you grab it and you clean it and you're done.
00:22:37
Speaker
Links to anything referenced in this episode are provided in our show notes, which can be accessed on the website at canr.msu.edu slash agri-food underscore safety. Thank you to everyone for listening, and don't forget to tune in next month for another episode of our Produce Bites podcast.