Transcript Cross contamination

Graham Walker
Director of Training
The Royal Environmental Health
Institute of Scotland
Food Standards Agency Guidance
E.coli O157 - Control of Cross
Contamination
Guidance for food business operators
and enforcement authorities
Cross contamination
• Following the Scottish and Welsh E.coli O157
outbreaks
• FSA consulted on its approach to cross
contamination control between 14 July and 5
October 2009
• There was a particularly high level of response
to the consultation
Controlling Cross Contamination
Risk approach based on:
Every consumer needs to be protected from
the risk of an isolated instance of low level
contamination of food by E. coli O157
This statement also applies to other pathogenic
micro-organisms
Preventing Cross Contamination
Required level of protection:
The best possible protection requires complete physical
separation between raw and ready-to-eat food
operations.
This would include preparation areas, equipment,
utensils, cleaning facilities, storage facilities for foodstuffs
and other materials, food display areas, and staff.
Preventing Cross Contamination
Required level of protection:
Separation of raw and ready to eat (RTE)
foods and their preparation to the highest
degree physically possible, which includes
dedicated (single purpose) use of complex,
hard to clean, equipment such as vacuum
packers, mincers and slicers.
What type of business does the
guidance apply to?
The guidance applies to food
businesses of all sizes and categories
where both raw food and
ready‐to‐eat foods are handled.
Raw food
Raw food in this context would
include raw meat and any raw
ingredients that are potential
sources of E.coli O157, such as raw
root vegetables, fruit or other
vegetables that are likely to have
been contaminated by soil.
Ready-to-eat
Ready-to-eat foods are foods that
will not be cooked or reheated
before being eaten and include foods
such as cooked meats, sandwiches,
cheese, salads and desserts.
Pennington Report 2009
“For a vac packer, I do not think that such
a demonstration is possible to allow its
use for ready to eat foods and raw meat.”
Separation:
• Designation and
maintenance of a
microbiologically clean
area
• Strong parallels with
infection control
• Everything in the clean
area must be a safe
contact surface for
hands, clothing and
equipment as well as
food
Separation is the only reliable
control
Greatest extent physically possible:
Size of establishment must be adequate
‘Dual use’ of complex equipment should
never be considered safe.
Small utensils must be for separate
designated use unless heat disinfected
between use
Separation is the only reliable control
Minimum level of limited exceptions
Equipment washing sinks if disinfected before
used to disinfect ‘clean area’ equipment
Non food contact wall and worktop surfaces.
Staff, provided there is a full hand-washing
regime
E. coli O157 Cross Contamination
Decontamination considerations:
A misplaced reliance on cleaning with
chemicals to sanitise surfaces in contact
with raw and cooked meats was a very
important issue in the Central Scotland
outbreak. Pennington report 2009
Enquiry into the Aberdeen
Typhoid outbreak
1964
“Only detergents and sterilisers whose
bactericidal properties have been proved
should be used in food premises”
Selection of cleaning agents &
disinfectants
Appropriate European standards, e.g. BS EN 1276 or
BS EN 13697 – FBOs should use this as part of their
purchasing criteria.
Food Business Operators must strictly observe
manufacturers’ instructions for use.
Manufacturers can market to a recognised
standard but will need to provide clear usage
instructions.
Disinfectants
• BS EN 1276
–
–
–
–
Suspension test
5 minute contact time at 20°C*
5 log reduction in viable counts
Test organisms include E. coli
• BS EN 13697
– Surface test
– 5 minute contact time at 18 – 25°C*
– 4 log reduction in viable counts
– Test organisms include E. coli
*Can be conducted at alternative temperatures and for
different times to suit intended conditions of use
Approach to cleaning and
disinfection
Two stage approach only
1. Clean to a visibly clean standard
2. Disinfect using suitable disinfectant in
accordance with the manufacturer’s
instructions
Use of a single stage sanitiser is not
sufficient
Additional considerations
Hygienic design
Machinery supplied for use at work
from 1995 should be CE marked to
indicate that it was designed to comply
with the European Machinery Directive,
Directive 2006/42/EC, and all previous
Versions BS EN 1762-2:2005 +A1:2009
Additional considerations
Hygienic design
Manufacturer must:
• Specify the intended use
• Design for hygiene considering intended use and
foreseeable misuse
• Provide cleaning instructions as part of the design
Additional considerations
Additional considerations
Effective Hand Washing
Hand washing is a critical control:
• at all safety-critical points
• It must be consistent and an appropriate
technique.
Clean hands should not make contact with taps.
Alcohol hand gels cannot be substituted for hand
washing.
Hand Washing
Reference: Hand Hygiene. A guide for healthcare staff Health Protection Scotland
Cross Contamination Culture
A loss of control due to any lapse in procedures
would:
• Necessitate active intervention to protect
consumers from an imminent risk
• Call into question the ability of the Food
Business Operator to continue to rely on
current procedures.
Cross Contamination Culture
Lead to a presumption that operations would
not be allowed to continue until the food
business operator implements effective and
credible procedures.
Training and supervision
Training of applicable staff in the specific
procedures required to control crosscontamination involving E. coli O157 will be
crucial to effective cross-contamination
control.
Training and supervision
Effective hand washing technique is critical to
cross-contamination prevention.
Staff must know when hand washing is
essential and how to do it properly.
It is critical that all relevant staff are trained
and verified as competent in hand washing
technique before being deployed to work
unsupervised in any safety-critical areas.
Training and supervision
Disinfection techniques set out in the
guidance will require training of all staff that
carry out safety-critical cleaning and
disinfection.
It is essential that staff are trained and verified
as competent before being deployed to dilute
and apply disinfectants, or to undertake hot
water or steam disinfection.
Training and supervision
Where the food business operator cannot rely
fully on training then supervision of staff is
required, as necessary, to ensure food is being
safely prepared,
This might be the case where staff are new to
a particular duty.
Training and supervision
Staff responsible for the development or
maintenance of the HACCP-based food safety
management procedures should have
adequate training in the application of HACCP
principles.
Link to the Cross Contamination
Guidance
E.coli O157 Control of Cross-Contamination
Guidance for food business operators and
enforcement authorities
http://www.food.gov.uk/foodindustry/gu
idancenotes/hygguid/ecoliguide
REHIS Response
• Update course syllabuses and resource packs
• Develop a Control of Cross Contamination
Course (Intermediate level)
• Develop a Cleaning and Disinfection Course
(Elementary level)
Any questions
Contact me
0131 229 2968
[email protected]