Plant sanitation - Gracey's Meat Hygiene - page 105

and the new BRC standard gives greater prominence to
them.
It states that:

requirement that the business owner has a duty to carry
out safe processing. It will eventually fall to the already
running EU Biocidal Products Directive (Directive (EC)
No 98/8) to license officially a biocidal product (circa
2008 onwards) for use in defined applications, inclusive
of its manufacturer's 'in-use' claims and technical/toxi-
cological supporting data. It is then envisaged that regis-
tered products with the right credentials can then be
fully integrated into individual risk assessments. This
legislation does not prevent any EU member states from
applying additional requirements as they see fit.
If terminal rinsing is required, it should be done in
time to allow surfaces to dry before production begins,
but not so early that disinfectant is removed prior to the
achievement of the surface hygiene target for residual
micro-organisms.
Terminal rinsing should be much quicker than the
pre-rinsing and post-rinsing stages as no contaminating
particles of soil should be present and the surface area to
be rinsed is smaller since routinely it is only direct food
contact surfaces that are treated with terminal disinfect-
ant. The microbiological quality of the water is very
important. It must be potable or else it can be a source of
re-contamination itself.

…Where control is achieved through existing prerequisite
programmes, this shall be stated and the adequacy of the
programme to control the hazard validated … procedures
of verification shall be established to confirm that the
HACCP plan, including controls managed by prerequisite
programmes, are effective…

Clearly, these standards are pushing for the elevation of
some aspects of GHP/pre-requisite programmes to a
higher level within the food safety management system,
and if they are critical to the control of a known food
hazard, they should be treated almost like CCPs in the
HACCP system. If cleaning and disinfection (both CIP
and COP) are to be classed in this way for some areas or
types of process, then this means validation, verification
and monitoring will be necessary to ensure adequate
control is in place.
In order to monitor C&D procedures, a simple logical
approach is possible in practice. Critical points in the
cleaning and disinfection programme should be identi-
fied and monitoring protocols set up. Some of the points
will be readily measurable, for example, the solution
concentration of a detergent or disinfectant, while others
may involve checking the procedure itself, for example,
was foam coverage complete and for the required resi-
dence time. After each stage in the cleaning procedure,
the operator should check for effectiveness and thor-
oughness. This check should be backed up by the hygiene
supervisor, who, if not satisfied, should ask for a repeat
of the stage. Quality assurance and/or production per-
sonnel should also check the plant regularly, looking in
particular for old soil deposits not removed at the last
clean, a build-up of fungi and corrosion/scale deposits.
The hygiene supervisor and his/her team should also be
periodically audited to ensure that the cleaning and dis-
infection procedures are being followed. If procedures
are being followed but routine inspections provide
evidence of short- and long-term surface hygiene issues,
then cleaning procedures and frequencies must be
reviewed and validated again. Chemical solution
strengths should be regularly checked by titration, test
kit or conductivity metre. This information should be
used to validate the dilution method in use (injector,
proportional pump, etc.), thus ensuring consistent per-
formance every day. Internal monitoring can be usefully
supplemented by audits from external experts, such as
hygiene service suppliers, consultants, etc.
There is another way to approach HACCP and the
possible requirement to elevate and include pre-requisite

Monitoring of hygiene
Monitoring of cleaning and disinfection effectiveness is
partly a matter of trained visual assessment and partly of
surface analysis and microbiology . A plant that is not vis-
ually clean always presents a risk regarding the microbial
contamination of food. The control and avoidance of
food safety risks are, as mentioned earlier, best achieved
using a HACCP approach. Legislation strongly recom-
mends the use of HACCP principles to secure a due dili-
gence defence. It is an ongoing discussion whether
cleaning and disinfection activities could/should be used
as critical control points (CCPs) in a HACCP system.
This is certainly not a new idea and has been proposed
for high-care areas (e.g. post-cooking/pasteurisation)
where, for example, a dirty process surface (hazard) is a
significant food safety risk (likely to be realised) to a
ready-to-eat product processed on it (Harrigan and Park,
1991, pp. 156-158).
The new ISO food safety standard allows hygiene pro-
cedures to be designated operational pre-requisite pro-
grammes (OPRPs) when they are critical to food safety.
These activities are treated like CCPs, and though they
must not have critical limits assigned to them, they must
be monitored (BS EN ISO 22000, 2005). Similarly, the
recent BRC global standard (British Retail Consortium,
2011) refers to the fact that pre-requisite programmes
have needed a much clearer role in HACCP programmes,