University Of California, Davis

Food Processors Sanitation Workshop

February 3 & 4, 1999
Modesto, CA

Sanitation Concerns In The Fresh-cut Fruit and Vegetable Industry

Devon Zagory, Ph.D.
Davis Fresh Technololgies, LLC
Davis, CA

Because fresh-cut fruits and vegetables are living and breathing during and
after processing, they are subject to rapid deterioration and can support the growth of
large populations of microorganisms. Unlike other processed foods, there is no kill
step during processing and there is no treatment, other than good temperature
management, that will significantly retard deterioration. Thus, the retardation of
deterioration and microbial growth is one of the principal challenges facing fresh-cut
processors. Because product deterioration is the result of many ongoing biochemical
and microbiological processes, no single treatment will stop them all. Maintaining the
quality and safety of fresh-cut produce is a challenge that is only met by doing many
small things well. If temperature is not managed well, good sanitation and adherence
to Good Manufacturing Practices (GMPs) will not ensure either quality or safety. A
poor sanitation program will prevent HACCP from functioning fully.

Good sanitation and food safety are best provided through the proper use of
multiple programs, including GMPs, sanitation programs, QA (quality assurance) and
HACCP (Hazard Analysis Critical Control Point) programs. Each rests upon the other
and will not work well unless the supporting program is in place.

HACCP

QA

SANITATION

GMPs

Because fresh-cut produce is prepared from a raw agricultural product

produced in contact with soil, often eaten raw, and with no processing kill step to
ensure microbiological safety, there are particular concerns of food safety not

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encountered with retorted or frozen foods. Human pathogens can and do infest fresh
fruits and vegetables and have been responsible for food borne illness. Processing
these products can take a point source of bacterial contamination and disseminate it
throughout a batch of product. Conditions inside flexible plastic packages (high
humidity, low oxygen and high carbon dioxide) can encourage growth of pathogens
that might not otherwise thrive on produce. If these packages then encounter
temperature abuse, pathogens may grow and cause problems. While each of these
may be low probability events, their possibility requires prudent processors to take
them very seriously.

Good sanitation practices should focus on those places and practices where
contamination of food is most likely. Contamination with pathogens is most likely to
occur from:

Fecal contamination of soils due to grazing animals or human waste.

Contamination from un-composted manure used as fertilizer.
Irrigation water contaminated with runoff from areas grazed by animals.
Handling by workers practicing poor personal hygiene.
Contaminated wash water in the processing facility.
Drip or splash from contaminated floors, drains, overhead pipes or cooling
systems.

Foodborne Illness Outbreaks Associated With Fresh Produce In The

United States, 1986-1996
Commodity Microorganism # of Source of Contamination
Year Out-
break
s
1986 Fruit salad Giardia lamblia 1 Pet rabbit in home
Lettuce Shigella 2 Undetermined
1987 Lettuce Shigella 1 Infected food handler
Shredded Clostridium 1 Field contaminated, temp. abused
cabbage botulinum in MAP
1988 Tofu salad Shigella 1 Infected food handlers
Iceberg Hepatitis A 1 Suspected contamination from
lettuce infected food handler
1989 Cantaloupe, Campylobacter 1 Food handler in restaurant cut fruit
honeydew and raw meat on same surface
and
pineapple Clostridium 1 Field contaminated
Garlic in oil botulinum
Salmonella 1 Field contaminated fruit from Mexico
Cantaloupe chester
1990 Tomatoes Salmonella 1 Undetermined
Cantaloupe Salmonella 1 Field contaminated

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 Raw Giardia lamblia 1 Infected food handler sliced
vegetables vegetables
Salad bar Salmonella 1 Cross contaminated from uncooked
montevideo meat in restaurant kitchen
1991 Cantaloupe Salmonella 1 Field contaminated
poona
Watermelon Salmonella 1 Field contaminated
javiana
Apple cider E. coli O157:H7 1 Field contaminated
1992
1993 Tomatoes Salmonella 1 Undetermined
Melons E. coli O157:H7 1 Cross contaminated from raw meat
by food handler
1994 Scallions Shigella 1 Speculated that nonpotable rinse
water was used
Salad bar E. coli O157:H7 1 Cross contaminated from raw meat
1995 Alfalfa Salmonella 1 Undetermined
sprouts
Iceberg E. coli O157:H7 1 Cross contamination at point of
lettuce preparation with raw meat
(Maine)
Iceberg E. coli O157:H7 1 Cross contamination at point of
lettuce preparation with raw meat
(Idaho)
Leaf lettuce E. coli O157:H7 1 Speculate surface water or
(Montana) unsanitary handling practices at
grocery store.
1996 Sprouts Salmonella sps. 1 Undetermined
Raspberries Cyclospora 1 Water used for pesticide spray mix
carried the parasite
Mesclun E. coli O157:H7 1 Suspected poor sanitation at the
salad processor

Number of outbreaks ascribed to fruits and vegetables where contributing factors

were known:
No. or % of Improper Inadequate Contaminate Food From Poor
Outbreaks Temps. Cooking d Equipment Unsafe Personal
Where Factors Source Hygiene
Were Reported
67 40 55 25 17 29
% 60 82 37 25 43
J. Food Prot. 53(9):804-817. 1990

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 As can be seen from the proceeding tables, most food borne illness
associated with fresh fruits and vegetables in the United States has been due to
contamination of raw product in the field or from food handlers in processing facilities
or restaurants. This does not imply that sanitation measures in produce processing
facilities are not important. Rather that additional effort needs to be placed on
sanitation in production areas and hygiene and training of food service workers.

Since sterilization of product or remediation of contaminated product is not

possible, prevention of contamination is the only option for ensuring food safety.
Some issues and methods will be briefly discussed here. A more complete treatment
of these and other produce safety issues can be found in the Food Safety Guidelines
for the Fresh-cut Produce Industry, available by joining the International Fresh-cut
Produce Association, 800-452-6552. All businesses involved in fresh-cut produce
processing should become members of this association to gain access to a wealth of
technical information on processing and safety issues.

Field Sanitation Issues

It is clear from the above points of possible contamination that produce

sanitation must start in the field and encompass all areas of growing, harvesting,
handling and processing. While many processors have little influence over how and
where raw product is produced, all should take an active role in making their
sanitation and safety concerns known to their suppliers and to find alternate suppliers
when those concerns are not addressed. One approach is to request that growers
provide evidence and documentation of the microbiological safety of their fertilizers,
irrigation water and worker hygienic practices. A sample letter requesting such
information may take the following format:

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 As Fresh-Cut Produce processors, we strive to provide the best quality and
safest product possible. As with all food providers, the safety of our products is of
paramount concern to us. Certain elements of that safety reside with you, our
supplier. We are sending this letter to make you aware of our concerns and to help
you provide us with assurances and documentation that you are taking steps to
ensure the safety of the ingredients that you are supplying to us.

Our concerns are in three areas:, Pesticide use and documentation, fertilizer
use and documentation and irrigation water quality and documentation. We would like
assurances from you that you have the following programs:

Pesticide Control Program

Maintain specification sheets for all agricultural chemicals applied to crops.

Material Data Safety Sheets (MSDS) must be made available for all agricultural
chemicals applied to crops.
All chemicals applied to crops are EPA approved for their respective applications.
Evidence of pesticide applicators license(s) and training documentation for all
workers applying pesticides.
Complete records of all pesticide applications.
Documentation of reviews to assure legal compliance and proper application of all
pesticides.
Documentation of proper storage of pesticides.

Fertilizer Control Program

No manure used as fertilizer.

No sewage sludge used as fertilizer.
Crops not grown on land that has been used for grazing livestock in the previous
two years.
Specification sheets for all approved fertilizers, identifying the composition and the
intended use of the fertilizer.
Material Safety Data Sheets (MSDS) for all fertilizers.
Documentation of proper storage of fertilizers.
Records of all fertilizer applications.
Analysis of all fertilizers to confirm that they do not contain excessive levels of
heavy metals.

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Water Quality

Analysis of irrigation water quality, including levels of E. coli and heavy metals.
Documentation that well water, if used, meets EPA guidelines.
Records of any chemical treatments of irrigation water.

We believe that it would be in both of our interests for you to maintain such
documentation. These assurances of safety are very important to us, as they are
important to all Fresh-Cut Produce processors. In the future these concerns are likely
to become even more important and, indeed, any grower wanting to sell raw product to
processors will almost certainly need to maintain such records.

Please respond to this letter in writing informing us of your safety programs and
documentation. Together we can work to ensure the safety and wholesomeness of all
of our products. Thank you for your cooperation.

Working with suppliers to maintain such documentation can help ensure safe
raw product and is an essential part of a good HACCP program. In addition, growers
should certify that field workers and harvest crews have access to, and use, toilets and
hand washing stations. While these are commonly available (and required) in the
United States, off shore producers should be held to the same standards of hygiene.

Worker Hygiene

Similarly, within the processing plant, workers hands can be contaminated with
pathogens. All personnel that contact product should be required to wear gloves and
to use hand dips (usually iodine or quaternary ammonium solutions) before being
allowed on the processing floor. These requirements should apply equally to
workers, management, maintenance workers and visitors. Neither gloves nor
smocks should ever be worn into bathrooms. Signs stating that workers must wash
hands with soap and water after using the bathrooms should be posted in appropriate
languages. Worker hygiene training programs should reinforce the importance of
hand washing by explaining the reasons for hygiene and the consequences of poor
hygiene. These practices are included in GMPs, sanitation programs and as part of
HACCP.

Processing Facility Sanitation

Wash Water Sanitation. Product wash water, if not properly sanitized, can
become a source of microbiological contamination for every piece of product that

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passes through. It is a widespread misconception that chlorinated wash water cleans
and/or sterilizes produce as it is washed. Chlorinated wash water does little more to
clean produce than clean, non-chlorinated water. Chlorine does sanitize the wash
water and maintains a low microbiological count in the water. In this way the water
does not become a reservoir for bacteria to infest the produce. Sodium (or
sometimes calcium) hypochlorite is most commonly used in produce wash water.
The antimicrobial activity of these compounds depends on the amount of
hypochlorous acid (HOCl) formed. This, in turn, depends on the pH of the water, the
amount of organic material in the water and, to some degree, the temperature of the
water. Above pH 7.5 very little chlorine occurs as active hypochlorous acid, but rather
-
as inactive hypochlorite (OCl ). Therefore, the pH of the water should be kept between
6.0 and 7.5 to ensure chlorine activity.

Effect of pH on Chlorine Dissociation Products

100
% Chlorine present as HOCl

80
or OCl-

60

40

20

0
0 1 2 3 4 5 6 7 8 9 10
pH HOCl
OCl-

Organic material in the water will reduce the activity of chlorine so periodically
replacing or filtering the water is important to maintain cleanliness.

Alternatives to hypochlorite are available for produce water disinfestation.

Chlorine dioxide is not approved for use on cut produce but can be used in wash
water or in contact with intact produce. Chlorine dioxide is less sensitive to pH and
organic mater than is hypochlorite and is active at lower concentrations. Chlorine
dioxide generation systems are generally more expensive than hypochlorite. Sodium
hypobromite (bromine based) is also approved for use in place of sodium
hypochlorite but I am not aware of any use of bromine for water sanitation in the
produce industry. Ultraviolet light systems are available for water sterilization as well
as for use on produce surfaces. Ultraviolet light leaves no chemical residues and is
not affected by water chemistry. However, it is only surface active and so requires
clear water to be effective. Ozone is approved for use as a water sterilant but not for

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use directly on product. Ozone is a very good sterilant but is subject to environmental
and worker exposure regulations.

Activities and environmental sensitivities of wash water sanitizers.

pH Organic Matter Biocidal Activity
Hypochlorites 6.0-7.5 Very sensitive Oxidizer
Chlorine dioxide 6.0-10.0 Sensitive Oxidizer
Ozone 6.0-8.0 Somewhat sensitive Oxidizer
Peroxyacetic acid 1.0-8.0 Somewhat sensitive Oxidizer
UV light Not affected Somewhat sensitive Disrupts DNA

Facility Sanitation. Cleanliness of all work surfaces and equipment is an

important quality assurance and product shelf life issue. Product infested with high
populations of bacteria is likely to become decayed and/or slimy sooner than similarly
handled cleaner product. However, the chief environmental safety issue is probably
the possible presence of the bacterium Listeria monocytogenes within the processing
facility. Listeria is a common environmental contaminant that thrives in cold, wet
environments such as those encountered in fresh-cut processing facilities. Once
established, Listeria can be difficult to eliminate and constant sanitation and testing
are necessary to prevent its establishment. Listeria is most likely to be found in
drains, refrigeration drip pans and any place where cold water accumulates and
stands. A comprehensive environmental sanitation program may include specific
swab tests for Listeria and vigorous sanitation of all areas where Listeria is likely to be
found. Again, prevention is the best defense against disaster.

Specific recommendations for sanitizing compounds, their proper application

and sanitation schedules can be found in the IFPA Food Safety Guidelines.

HACCP

Hazard Analysis Critical Control Point programs are designed to prevent

chemical, physical and microbiological hazards in the processing of foods. HACCP is
not a quality assurance program and should be operated separately from the QA
program. However, HACCP can only function properly along with the proper
implementation and enforcement of GMPs and a comprehensive sanitation and QA
program. Once these are in place, HACCP can be introduced.

HACCP is a highly structured program that depends on identifying possible

hazards and preventing them through proactive measures and constant monitoring
and documentation. When done properly, it is the best method for preventing food
borne illness due to consumption of fresh-cut produce. The seven steps of HACCP
are as follows:

#1. Assess hazards.

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#2. Determine critical control points (CCP) where potential hazards could occur.
#3. Establish critical limits that must be met at each CCP.
#4. Establish procedures to monitor each CCP.
#5. Establish corrective actions to be taken should a CCP be outside its critical limit.
#6. Establish record keeping systems to document the HACCP program.
#7. Periodically verify records to review and improve the HACCP program.

Clearly HACCP is a multilevel system that requires substantial commitment

from management and workers to operate effectively. When done well, HACCP is a
powerful tool to assure food safety.

Sanitary Plant Design. A poorly designed facility may be nearly impossible to

keep clean. Inaccessible spaces, overhead members, immovable equipment and
poor drainage make sanitation a very difficult proposition. Attention to sanitation
during the design process can save time and resources and prevent problems later.
For example, all exposed pipes, wires and drainage lines should be at least two
inches away from walls and ceilings to allow access for cleaning and sanitizing. All
drains should have removable grates over them for easy cleaning and sanitizing.
Motors should not be mounted over produce handling areas. All equipment should be
installed at least 6 inches above the flow to allow for access from beneath.

Consulting firms are available to aid in sanitary design as are several printed
resources. Once again, prevention of unsanitary conditions is the best strategy to
avoid problems.

Resources

Current Good Manufacturing Practice (CGMP) regulations. The regulations are current
through February, 1994. The CGMP regulations are issued under Title 21, Code of
Federal Regulations, Part 110 (21 CFR 110). Amendments to the regulations appear
in the Federal Register. You may subscribe to the Federal Register or order 21 CFR
100-169 by submitting the current cost by check or money order to:
SUPERINTENDENT OF DOCUMENTS, U.S. GOVERNMENT PRINTING OFFICE,
WASHINGTON, D.C. 20402, or by telephoning the Government Printing Office at 202-
783-3238 to charge on Visa (copyrighted) or Mastercard (copyrighted).

Guidance for Industry: Guide to Minimize Microbial Food Safety Hazards for Fresh
Fruits and Vegetables. Additional copies are available from:
Food Safety Initiative Staff, HFS-32, U.S. Food and Drug Administration,
Center for Food Safety and Applied Nutrition, 200 C Street S.W. Washington, DC
20204. (Tel) 202-260-8920. (Internet) http://www.fda.gov
References

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Sanitation Handbook. 1970. USDA-CMS. Washington, D.C.

J.A. Troller. 1983. Sanitation in Food Processing. Academic Press. New York.

D. Zagory & W. C. Hurst (Eds.). 1996. Food Safety Guidelines for the Fresh-cut
Produce Industry. Third Edition. IFPA, Alexandria, VA.

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