As we begin another year, I want to focus on something that will hopefully establish a new perspective about sanitation: “Attitude” really is “altitude.”
If we have a poor or lackadaisical attitude about sanitation and plug along, just getting by, soon our customers will pick up on our attitude and begin to get uneasy. Next, they become concerned that the safety or quality of the food may be in jeopardy and ultimately decide that the risk of contamination is too great and leave for safer pastures. But, if we have a positive attitude about sanitation, what I call, “Above the Best,” and strive to go beyond the regulatory requirements, we will always be in demand by customers. Our reputation will precede us, and that reputation will be of the highest caliber.
You should view your sanitation program as a return on investment; it is a profit center and an insurance policy protecting your investment of time, work, money and energy spent in producing a high-quality product in a competitive world market.
I see regulations, such as GMPs, as a bench mark. They are the “best” in terms of what should be done to protect food safety. But, I challenge you to look beyond the benchmark.
The general attitude about a sanitation program is that it takes time away from production, consists of a sanitation crew, some chemicals and equipment; that it costs too much and brings in no return.
My view of a sanitation program is a bit different. I believe it must start with the president of the company and work its way right down to the shipping and receiving staff—from the quality control manager to the people on the sanitation crew, from the janitor to the receiving person who brings in the raw materials. Unless you view your plant sanitation as a total concept, you will never have a sanitation program that is “Above the Best.”
In this world market, that attitude will jeopardize your ability to compete. Why? because we are no longer a sovereign nation but a state in a world nation. We have NAFTA, the European trading block, the Asian trading block, etc. If you think that world competition is based simply on price, you are wrong. No buyer in Europe or elsewhere will buy a product from a plant that has a poor attitude about quality or does not have a total sanitation program.
21CFR .110 is the bench mark. These are the GMPs set forth by the FDA. They came into being because some food processors just did not care or desire to consider food safety in their processing activities. The GMPs are free and available through the FDA or from a federal book store. They are concise, clear, understandable and simple. Let’s look at one GMP and see how we can go “Above The Best.”
21 CFR 110.35 (D): “Sanitation of food-contact surfaces. All food-contact surfaces, including utensils and food contact surfaces of equipment, shall be cleaned as frequently as necessary to protect against contamination of food.”
Simple request, but what do you do to go beyond the best?
Document your cleaning of these food contact surfaces. Have a cleaning schedule that specifies who cleaned what, when, how and with what.
Check the food contact surfaces for contamination by doing Bac T’s, ATP with an ATP test unit (e-mail me if you need information on this) and visual inspection for bio-film. Your food contact surface should be cleaner than the food product you put on it!
Get a copy of the GMPs and review each item, look for ways you can go “Above the Best” to exceed regulatory requirements and meet or exceed your customers’ demands.
The Driving Force
The driving force behind a great sanitation program is not the regulations. It is your customer.
Going beyond the best, the benchmark that is the GMPs, involves instituting sanitation training designed to meet the needs of each department of your plant.
First, management needs training in sanitation to develop better leadership and a positive attitude for all employees to follow. A positive attitude by management toward plant sanitation can work to eliminate fiscal losses from recalls, product contamination or customer dissatisfaction. Next, the QC staff has additional training needs and valuable services that they can provide to assist the sanitation crew. The sanitation crew has training needs in sanitation technology and the need for inter-departmental understanding of sanitation’s value.
OJT (on-the-job-training) does not cut it. Just hiring someone for the lowest pay and telling them to “clean the equipment” without providing the necessary training is a set up for failure. One processor told me, “What happens if I hire you to train my people and then they leave?” My response was, “What happens if I don’t train them and they stay?”
Turnover is a poor excuse for not training. To reduce turnover, invest in your sanitation program. When you do that you put value on the person, the position and on the total program.
If you will do all that we have talked about here, you will certainly have a sanitation program that is truly “Above the Best.”