Photo credit: Image provided courtesy of the USDA
Often, areas of egg-processing facilities appear clean—without visible debris and residue from previous processing shifts—but in fact have high levels of bacteria present. In the early 2000s, U.S. Department of Agriculture Agricultural Research Service (USDA-ARS) scientists and university collaborators swabbed shell egg processing facilities before and after sanitation procedures. In all instances and across all populations monitored, no significant changes in microbial levels occurred. The facilities all looked visibly cleaner when the postsanitation swabs were collected, yet laboratory analysis proved this not to be case. There was more work to be done.
To produce safe, high-quality eggs or egg products, you must start with clean equipment and a clean facility. When spoilage and pathogenic microorganisms remain on product contact and noncontact surfaces at the beginning of the processing shift, there is a greater likelihood of product contamination.
During a traceback investigation and inspection associated with a presumed egg-related foodborne illness outbreak, the regulators’ warning letter issued to the firm noted the outbreak organism was detected in the egg-processing area multiple times. The outbreak organism was isolated from samples of standing water on equipment and floors.
Cleaning and disinfection go beyond the process of cleaning between production shifts. There are cleaning tasks that should occur during processing, too. Reducing the occurrence of standing water and pooling egg contents and shells can help limit microbial growth during processing. These are also safety hazards for personnel.
The egg industry has two main divisions that are governed by two different food safety agencies. Shell eggs are governed by the U.S. Food and Drug Administration (FDA), while egg products are governed by the USDA Food Safety and Inspection Service (USDA-FSIS). Each of these agencies has different regulations to meet food safety compliance. Even with these differences, the common denominator for both agencies is a set of practices to improve food safety and reduce public health risk. FDA utilizes regulations around preventive control methods, whereas USDA-FSIS’s regulations revolve around Hazard Analysis and Critical Control Points (HACCP)-based principles. Both these systems are designed to reduce public health risk surrounding pathogens such as Salmonella. There are over 2,400 serovars of Salmonella, and all of them are pathogenic, meaning they can produce human illness. Many of the FDA regulations discuss Salmonella Enteritidis specifically, but in reality, food safety practices that processors implement are designed to reduce risk of all pathogens.
In 1970, Congress passed the Egg Products Inspection Regulations, which aligned egg product regulations with meat and poultry products inspection regulation. On September 9, 2020, USDA-FSIS announced it is modernizing the egg products inspection methods and released regulations regarding egg products HACCP implementation. This modernization will require egg product plants to develop food safety systems like those in meat and poultry plants and to develop an HACCP-based system for food safety, which includes development of written Sanitation Standard Operating Procedures (SSOPs) and Good Manufacturing Practices (GMPs). Since egg products are considered a ready-to-eat food under the new HACCP regulation, meaning they are edible without additional preparation, both Salmonella and Listeria controls will be addressed in the modernized food safety plans.
Furthermore, shell egg facilities may participate in the voluntary USDA Agricultural Marketing Service (USDA-AMS) egg-quality inspection program. A pillar of this program requires official USDA-AMS egg processing facilities to undergo preoperational sanitation inspections each processing day, conducted by the USDA-AMS grader at the facility. Beginning January 2020, USDA-AMS updated the expectations for the preoperational sanitation inspections. To assist USDA-AMS graders, as well as the egg industry, video training modules have been developed by USDA-AMS, USDA-ARS, and Purdue University and are free to access.
VIDEO An Introduction to Egg Sanitation
The Code of Federal Regulations, Title 9, Parts 416.1–416.17, describe inspection of egg and egg products, including sanitation practices. SSOPs are written detailed documents describing the sequence of events that an employee must conduct to prevent direct product contamination and adulteration. These written SSOPs must include what is being cleaned, by whom, when (frequency and timing), and how (the actual procedure). SSOPs can also be divided into preoperational sanitation and operational sanitation procedures to ensure responsibilities and procedures for each are met daily. Preoperational sanitation procedures are conducted before daily operations, while operational sanitation procedures are conducted during breaks and throughout daily operations.
There are really seven steps to cleaning and sanitation. These are as follows
There are some considerations when implementing SSOPs. Each plant is responsible for its own sanitation practices. Corporate SSOPs are easier to implement as there is a standard form and standard practices for employees to follow. However, corporate SSOPs do not reflect specific issues or practices or equipment/process at each plant. Not all plants are the same, and so each SSOP may have to be modified to reflect these differences. Know your water, as pH and hardness levels can affect your cleaning and sanitation compounds. Working with a sanitation company can help modify practices or chemicals to adjust to specific needs based on water quality. In addition to consultation with the sanitation company, it is always best to consult with equipment companies to determine best practices for cleaning and sanitizing hard-to-reach areas. A common misconception it that once SSOPs are written, they are considered done and can be placed on the shelf in the quality assurance office. As with everything in life, things change with the addition or removal of new equipment or process or employees. SSOPs should be reviewed often and at least yearly and updated to reflect any changes in process, equipment, chemical use, sanitation company, or anything else.
“Since egg products are considered a ready-to-eat food under the new HACCP regulation…both Salmonella and Listeria controls will be addressed in the modernized food safety plans.”
GMPs are also considered a foundation for HACCP-based food safety systems. These practices include procedures for personnel (training, personal hygiene, etc.), buildings and facilities (pest control), maintenance (production areas and storage facilities, etc.), equipment (contact and noncontact areas), production parameters, and process control. While these are all important for a solid food safety foundation, employee training is one of the most difficult to ensure success at. All employees, regardless of position, should be trained in basic food safety and hygienic practices upon hiring and periodically afterward. Training should be conducted by someone knowledgeable and enthusiastic, and it should be fun. All employees have a role in understanding bacteria, their role in illness, and how bacteria are spread. The goal of training is not only to gain a better understanding of the topic of food safety but also to reduce indifference among employees. Food safety should be a top priority every day for all employees no matter the title or job description. Therefore, a strong training program should be a top priority for all companies to ensure an effective food safety plan.
The most common mistake during cleaning and sanitation operations is lack of training when it comes to proper mixing of detergents and sanitizers. Proper training of employees and continued verification steps are critical to ensure proper mixing. An easy way to verify proper mixing is to use a test strip and ensure concentrations are as expected daily. Chemicals with reduced concentrations will not be effective and can lead to bacterial tolerance; chemicals at higher concentrations can lead to adulteration of product and employee safety issues. It is important to work with a sanitation company you trust and that can help provide some of these services, including training, to ensure best results. During a foodborne-illness outbreak traceback investigation, inspectors will often observe sanitation operations to verify written SSOPs are being followed. Letters of warning have included observations such as employees did not comply with exposure times as written; employees did not complete all steps of the SSOPs; employees did not test chemicals to ensure proper concentrations were used; and employees could not show where written SSOPs could be accessed. Again, employee training and engagement can prevent each of these citations.
Furthermore, production, sanitation, and maintenance teams should work in concert to ensure egg and egg products facilities are thoroughly clean. Citations during inspections have included observances such as equipment and food contact surfaces being placed on floors or dirty surfaces; maintenance equipment being placed on cleaned and sanitized food contact surfaces without subsequent sanitation procedures; and dirty utensils and tools being used to clean food contact surfaces. Most of these occur due to employees just trying to do their jobs, but lack of communication and coordination between teams resulted in sanitation infractions.
As mentioned before, sanitation programs are not “fix it and forget it.” While daily microbial sampling and enumeration would be optimal, that’s not always practical. In consultation with quality control/quality assurance personnel, chemical suppliers, equipment manufacturers, sanitation personnel, and facility management, an assessment plan should be developed. Trouble spots and hard-to-clean areas should be sampled more frequently to ensure effective cleaning and disinfection is occurring. While rapid-screening tools are available and can be more cost effective than swabbing for laboratory analysis, rapid-screening methods should be combined with scheduled traditional laboratory analysis to provide a complete view of sanitation program effectiveness.
If problems arise, equipment changes occur, housing systems for eggs entering the facility change, substantial sanitation personnel changes occur, chemical suppliers or compounds change, etc., the overall sanitation program should be reassessed. This will ensure the program in place meets the needs of the facility. Complacency can lead to long-term challenges. Sanitation programs also play a role in overall product quality. High loads of spoilage organisms on equipment can lead to customer complaints, lost accounts, and ineffective pasteurization of egg products.
Each plant is responsible for creating a positive food safety culture and ensuring and instilling basic food safety knowledge and practices daily for all employees. Creating solid SSOPs and GMPs is a critical foundation for an HACCP food safety system. To accomplish all these food safety goals, it is important to utilize resources including sanitation companies, equipment companies, university personnel such as Extension and research faculty, knowledgeable consultants, and any allied company that can provide services. Remember, once a food safety system is established, it should be reviewed and updated often. Food safety systems are about reducing public health risk and establishing a record of practicing food safety culture daily.
Take time to watch sanitation shifts and in-process sanitation procedures. Turn off your electronic devices, put a Do Not Disturb sign on your hairnet, and focus on the flow and actions in your facility. Did maintenance just grab a dirty brush to clean up after a repair? Where did that squeegee come from that was used on the farm belt? Has someone checked the concentration of chemical in that spray bottle? Where is it documented? Most of the time, employees are honestly trying to do their jobs to the best of their abilities. Unless management takes the time to be engaged and lead by example, your employees will not be engaged. A visit to the late-night sanitation shift and cleaning some equipment alongside the team will make a far bigger impact than posting a memo.
Deana Jones, Ph.D., is a research food technologist in the Egg Safety and Quality Research Unit of the U.S. National Poultry Research Center, USDA-ARS, in Athens, GA.
Christine Alvarado, Ph.D., is a technical service manager with Arm & Hammer Animal and Food Production in Schenevus, NY.