I wrote this blog in lieu of a conversation I had with a FSIS inspector who claims to be a twenty-five-year veteran of the agency.
I wrote this blog in lieu of a conversation I had with a FSIS inspector who claims to be a twenty-five-year veteran of the agency. Furthermore, he claimed to never have heard of Less than Daily sanitation.
As a common practice, establishments have conducted complete cleaning and sanitizing of their operations on a daily basis. However, there has never been FSIS regulations that required an establishment to conduct cleanup every twenty-four hours or within any other specified period.
Establishments can choose to extend their production operations without conducting “traditional” cleaning every twenty-four hours. They can select an alternative cleaning frequency provided they ensure that, as a result of the methods utilized, insanitary conditions are not being created that may result in adulteration or contamination of product.
The most logical and appropriate application of Less than Daily (LTD) sanitation is on ovens and smokehouse. The reason being that the walls, ceilings, racks, trees, sticks and hooks are receiving a lethality treatment especially when producing fully cooked product.
Establishments utilizing an alternative sanitation frequency would still conduct “traditional” cleaning except it would be less frequent, for example one time per week.
When developing an LTD sanitation program on certain pieces of equipment, an establishment should consider all factors that may impact its program. In most cases, FSIS expects that microbial factors affecting sanitary conditions will be the primary focus of LTD sanitation programs. It is well known that bacterial growth is a function of time, temperature, and environmental factors (available nutrients and moisture). In addition, bacteria found on food contact surfaces will affect the condition of the product. Microbes cannot be directly observed by organoleptic methods; therefore, it is likely that most LTD sanitation programs will need to include sampling methods to measure levels of bacterial contamination on food contact surfaces.
When developing a sanitation program, the establishment should consider all factors that may have an impact on the program and address them when developing a Sanitation SOP. A microbiological baseline study may provide a starting point for such consideration. Baseline testing, while not required, is highly recommended as a means to develop criteria that can be used to evaluate the ongoing effectiveness of a LTD sanitation program. Using the criteria developed from the baseline study, ongoing microbial testing may be an effective means to demonstrate that all food contact surfaces are cleaned often enough to prevent the creation of insanitary conditions and adulteration of product. If the establishment chooses not to conduct a baseline study, it may be difficult to demonstrate that the use of a LTD sanitation procedure will meet the sanitation regulatory requirements.
The regulations do not require baseline studies, nor are there any requirements for levels of testing in a baseline study. However, a baseline study can serve as a basis from which the establishment can determine the microbiological operating levels and limits for its facility under normal operating conditions.
A baseline study should include both initial micro analysis along with ongoing micro analysis. Types of micro analysis typically include Total Plate Count (TPC) and Aerobic Plate Count (APC). However, many factors (e.g. pH, water activity, product characteristics) could affect the product and therefore affect the type and amount, of data that the establishment ultimately decides is needed to ensure that the alternative cleaning procedures are effective and that sanitary conditions are maintained.
It is also important to remember that a written prerequisite program is needed for implantation of Less than Daily Sanitation. Type and frequency of micro analysis along with a method for evaluation of data generated should be included in the program.