HAZAN: Management (the owner) is the only one who has the legal authority, responsibility, and accountability to assure, through “due diligence,” that everyone in the operation strives for zero defects in task performance. In order for owners to say that they did their best, they must be able to show leadership in food safety in their operations. The following are necessary components of the management system that must be in place in order to strive for zero quality defects in safety, customer satisfaction, and operational effectiveness.

1. Management commitment: There is a posted food safety QA policy. The kitchen is open for customer observation. There is a short food safety checklist for customers to record their observations. The owner responds to each suggestion.
2. Quality assurance policies, procedures, and standards manual: There is a written, up-to-date quality assurance policies, procedures, and standards manual with a log sheet to document each change to the manual.
3. Management oversight: The manager does a walk-through of the food operation regularly to look for new hazards and verify that employees are following hazard controls in accordance with the HACCP-based quality assurance policies, procedures, and standards manual.
4. Training: Employees are trained to mastery of assigned food safety responsibilities according to the quality assurance policies, procedures, and standards manual before being asked to do a task. A training record is kept. There is continuing education.
5. Operation: Employees are coached with positive reinforcement. The manager keeps a record of compliments / positive reinforcement that he or she gives to employees. Records of process performance are kept to show process stability.
6. Continuous quality improvement: There is analysis of performance / process stability. There is a formal process to decide what to change or replace. R&D is done to decide on the best change. Improvement is implemented in a controlled manner.

Environment, Facilities

HAZAN: While insects, rodents, filth, and dirt are contaminants that can get into raw food in the facility, the hazard controls in the process must control them, because they are already in the food coming from suppliers. Hence, the facility is not a critical control point for these contaminants; it is a quality control point. The hazards that need control are the various sources of chemicals such as boiler water, air conditioning water, cooling and petroleum-based lubricants, pest controls, etc. In addition, the water used in the food processes must be free of hazardous levels of pathogens. Below are the critical controls.

1. Control hazardous chemicals to keep them out of food.
2. Assure that the water supplier has a HACCP plan.

HAZAN: In the broad sense, once equipment has been purchased that can perform to achieve necessary process standards such as holding all food at 7 50ºF and cooling food to <45ºF in 15 hours, then, the ongoing critical control is maintenance of the equipment to maintain the equipment’s original performance capability.

1. Maintenance of equipment capacity to heat / cool food. Controls are regularly calibrated.

Personal Hygiene

HAZAN: Because people can be shedding high levels of pathogens with no symptoms of illness, the rule, “when you are sick, stay home,” is not an effective control. The correct controls include 1) effective fingertip washing to reduce fecal pathogens to a safe level and 2) controlling Streptococcus from the throat and Staphylococcus aureus transfer to a safe level of <100 organisms per portion of food by blocking a cough or sneeze with one’s shoulder, for instance, or using a single hand wash (without the fingernail brush). The single wash before handling ready-to-eat food also controls transfer of the low levels of raw food pathogens to ready-to-eat food.

1. Double hand wash with fingernail brush to reduce fecal pathogens 10-5.
2. No coughing or sneezing onto food or food contact surfaces (cough / sneeze into shoulder).
3. Single hand washing at work station to reduce food pathogens 10-2 after touching contaminated surfaces, raw food, skin / nose, etc.

Food Contact Surfaces
HAZAN: Raw food contact surfaces become contaminated with low levels of pathogens from food, the worst probably being 1,000 Campylobacter jejuni per 8 square inches from fowl. Fortunately, on raw food, it is an acceptable risk control strategy to assume that there are at least 100 times higher levels of spoilage microorganisms. If one washes, rinses, and sanitizes a food contact surface to reduce the spoilage organisms to <100 APC per 8 square inches, the pathogens will be at an acceptable level of <1 per 8 square inches.
I have found that a scrub brush rinse of a cutting board under flowing water gives about a 10-3 reduction of organisms on a surface, and washing with detergent reduces APC another 10-2 to 1. Rinsing after washing removes no organisms from the surface, just detergent. Sanitizing reduces microorganisms about 5 to 1. Air-drying gives another 10-to-1 reduction. “Clean as you go” controls contamination from one task to another. Storing cutting boards dry prevents multiplication on a wet surface.

Wiping a dirty surface with a sanitizer cloth is ineffective. The surface must be free of soil first. This is done by dilution. Microorganisms multiply in used detergent wash water. However, at 70ºF, they multiply only about once every 2 hours (Table 1). If the water is changed when it is dirty, or every 4 hours maximum, there will be a maximum of 2 multiplications of microorganisms. This is very safe. Keeping the sanitizer in a squirt bottle to flood the surface keeps the sanitizer at strength and uses it in the most effective way, after a surface is clean.

There can be a problem in operation with warm meat-slicing machines or buffet meat-carving stations with warm, wet cutting boards. There is the possible growth of the spores of Bacillus cereus and Clostridium perfringens. If these kinds of items are cleaned every 4 hours or within a time to limit multiplication to <10 generations, there will be acceptable control. The standard deli slicing machine slices only pasteurized, cold meat, and the spores are not a problem. If the deli slicer is cleaned once a day (i.e., after 12 hours), that will control the hazards.

Using the 1997 FDA code’s 41ºF / 7 days and 45ºF / 4 days, and putting 4 hours at 110ºF, all of which allow for about 10 multiplications of pathogens, Table 1 gives the equivalent time for 10 multiplications of pathogens at all hazard temperatures from 30 to 125ºF (Snyder, 1997). Appendix A-i provides a table to calculate the number of multiplications of microorganisms during a food / dirty-water holding step.

1. As raw, contaminated food tasks are completed, wash, rinse, and sanitize immediately to reduce pathogens on surface 10-5 (“clean as you go”). Store dry.
2. Keep wet cleaning towels in 1-gallon minimum detergent-and-water buckets and change when water gets dirty or at least every 4 hours. Have separate buckets for ready-to-eat food areas and raw food areas. Keep sanitizer in a squirt bottle.
3. Control the growth of pathogens on hot (80 to 120ºF), wet surfaces such as buffet lines, cutting boards, and hot roast beef slicing machines, in use, to <10 generations before cleaning. (See Table 1.) Calculate the total process growth using the microbiological multiplication calculator. (See Appendix A-i.)

Purchasing – Receiving
HAZAN: Raw food is contaminated. Government inspection of raw food is not effective for hazard control. The correct strategy is for the supplier to have hazard control and to tell the manager the probable and upper limit of contamination in terms of the ICMSF mMnc. If pathogens are at a safe level in the raw food, the food can be eaten as received (e.g., oysters, clams, fish, beef). If the supplier will not provide a HACCP, assume the following contamination in raw food.

Salmonella:   10/gram
Listeria monocytogenes:   1/gram
Staphylococcus aureus:   100/gram
Clostridium perfringens:   100/gram
Bacillus cereus:   100/gram
Clostridium botulinum:   1/gram

In all cases, if multiplication is limited to <10 generations in the unit, the resulting levels of pathogens would only be at the upper level of safety.  There is also a problem of allergens in food.  There must be an ingredient label with each “recipe” item.

1. Supplier HACCP: Demand HACCP plans from all suppliers and have them certify maximum spoilage and pathogen contamination in ICMSF terms of mMnc.  Each item must be identifiable, along with all ingredients.
2. If food is to be eaten as received, get a supplier pathogen “safe level” HACCP certification.

Storage and Pre-preparation
HAZAN: Before the food is consumed, there will be some multiplication of pathogens. Table 1 provides the limits based on FDA 1997 food code recommendations. Setting a cold limit of <55ºF will ensure that any operator with a HACCP program will be able to meet control limits 100% of the time with current refrigeration equipment. Otherwise, HACCP cannot be enforced. Food is no more hazardous at 55ºF in 1.7 days than it is at 45ºF in 4 days, or 110ºF in 4.7 hours. Adding old food to fresh food is a very poor quality and safety practice. The FDA has no prohibition regarding this. Therefore, I include this as a control. By making the general statement, “separate ready-to-eat food from raw food,” I establish this critical control.

1. Label with date received. Keep raw food temperature <55ºF and control food temperature and time so that there are <10 multiplications of pathogens on raw food. (See Table 1.)
2. Old food is not added to fresh food.
3. Separate ready-to-eat food from raw food.
HAZAN: Fruits, vegetables, and raw foods are contaminated. Washing fruits and vegetables gives limited and variable results. The best process is the double wash–soak in the first sink and agitate, then, rinse in a colander in the second sink. This will only give a 10-2 reduction at best. Adding chemicals to the wash gives variable results that are not much better. Heating food in <6 hours to >130ºF controls multiplication during cooking. Pasteurization according to Table 2 will make any food, including the surface of fruits and vegetables, safe. (Fruits and vegetables are assumed to be safe under the surface in the tissue / cells of the food.)

1. Double wash fresh fruits and vegetables to get a 10-2 reduction.
2. Heat quickly enough to prevent pathogen multiplication (continuous heating from 50 to 130ºF in <6 hours).
3. Pasteurize food for 10-5 Salmonella spp. reduction. (See Table 2.) If the salmonellae are in low-water-activity food (perhaps <0.92), the pasteurization value needs to be increased. Each process must be individually evaluated.