As food safety legislation globally seeks to change food and beverage companies mindsets towards pro-active prevention, it can sometimes seem like the new demands placed on processors are never ending. While internationally recognised food-safety schemes and governments seem to be competing, as to who can come up with the most rigorous standards, it’s important not to get overwhelmed by all of the competing clauses and over-lapping requirements and see what’s really at the heart of all these happenings.
Put very simply, everybody just wants the assurance that the food or beverage they buy is going to always be consistently safe to consume, and the publics (and consequently their governments) patience with sub-standard operators is wearing thin. While the vast majority of processors are conscientious, the minority who view food-safety as a distraction to business will slowly but surely be squeezed out by tightening legislation and more rigorous standards.
The point is, if your organisation has the right culture and mind-set towards food-safety, you’ll more than likely already practising most of the things that the legislation will enforce on those who don’t do so voluntarily. Things like unannounced audits won’t cause trepidation, because you’re doing the right thing on a daily basis and have the evidence to prove it.
The mind-set of pro-actively looking deeper into your processes to search for overlooked factors that could jeopardise your food safety, should be seen as a positive and not something to be avoided, because of the risk of finding something.
Interestingly, in figures released by Campden BRI, for all sites audited globally to BRC Standards in 2016, the number 1 reason for Non-Conformance was evidence of poor cleaning. This was sited in 15.4% of sites throughout the world. To be pro-active, you must verify that everything you say you’re doing is actually effective at doing what you want it to.
The FSMA guidelines out of the USA are very strong on this, with all CCP’s needing thorough verification. A glance through MPI’s specifications for infant formula manufacturers, shows a similar heavy emphasis on verification and re-verification if any step of the process changes. Cleaning being such a critical part of any production process, is no different. Traditional ways of verifying cleaning effectiveness include micro-sampling or ATP sampling of the food contact surface, and this is usually adequate for open-area surfaces. However, for CIP equipment, verification of cleaning is a lot more problematic, because the food contact surfaces are mostly inaccessible for sampling. This has led to a de facto standard of measuring things like conductivity and flow rates, which are related to, but certainly not solid proof of, cleaning effectiveness. Likewise, micro or ATP samples of a CIP circuits final rinse water, will give an indication of how micro-free it is or isn’t, but this can in no way guarantee that the entire circuit has this same status.
So, how do you verify that your CIP regime is truly effective? Is there a technology available that will test every single bit of my circuit and tell me how effective the clean really was?
The answer is YES – and if you’re truly committed to pro-active food safety, you need to know about it!
In 2017 ‘Smart CIP’ was launching to the NZ market. This alkaline cleaner can be used in all CIP situations. Thanks to the patented Persulphate Technology it’s based on, it will verify the hygienic status of all the surfaces it contacts inside your circuit in real-time, as it circulates!
This is achieved by ‘Smart CIP’s’ mode of action, which oxidises anything of organic origin into its mineral form, and in doing so, changes the colour of the solution (which starts out as purple) in an exact correlation to the amount of organic material present. Once the solution has stopped changing colour, your equipment is verifiably free of anything of organic origin. This colour change can be monitored visually or measured with far more accuracy by specific instruments and software.
If its potential usefulness is not immediately obvious to you, then take a step back for a moment and consider how CIP has evolved. Until the 1950’s all pipework, etc. used in a circuit was disassembled and manually cleaned every time it was needed. When the CIP concept was introduced and took a major step forward for processors in efficiency, safety and repeatability.
This gave rise to using best practice methods based around the “four factors” of CIP, known under various different names, but basically are: flow rate, time, temperature and chemical concentration.
The most efficient combination for each of these factors has built up over time through experience, and trial and error of each different type of circuit and the product being processed through it. How effective each clean was, was then monitored by the presence/absence of micros in the rinse water and ultimately the shelf life of the product processed.
Based on generally accepted best-practice methods, a number of ways of measuring these parameters inline were introduced, such as pH, conductivity, flow meters and so on. This was so that factory control systems could monitor them automatically to help ensure repeatability of an accepted method, raise alarms if something didn’t meet a set-point and to provide historical data for auditors, that showed that a certain clean on a certain day, after a particular product run, meet all the set-points and was therefore deemed “effective”.
The problem with all of these parameters being measured is that they are all cleaning ‘inputs’ – e.g. they’re all factors that are introduced into the CIP operation, such as temperature, alkalinity, higher flow rate, on the basis that they’ll hopefully influence the outcome. But if the outcome that’s wanted is complete removal of anything organic from the system, then you really have to measure the “output” from this activity, which is the level of effectiveness of your cleaning program.
If you’re relying only on a record of your cleaning inputs to prove that your outcomes are, acceptable, then you’re only getting half of the picture, and if you’re relying on sampling methods that only test a very small representation of your circuit, to prove that the outcome was effective, you’re also leaving a lot to chance. Admittedly, this is what industry has done for decades, because there has been no better way of doing it, but in reality, it’s akin to looking at a very foggy mirror, you’re getting a fairly good idea of what’s looking back at you, a general outline, but the fine details which are important, are not clear. It’s a representation, but not the full picture.
The day is coming when providing a record of inputs, as evidence of an effective output, will no longer be acceptable to your customers. The fact that the last time you ran this product for Company X a few months back, and the rinse water micro’s came back clear, and you haven’t changed the CIP settings, is no guarantee that it’ll be the same this time. What if you run allergen and non-allergen product through the same equipment? Kosher and non-Kosher? Halal and non-Halal? How can you prove that if no inputs are changed, your current CIP is effective at removing all organic substances from your equipment?
Micro sampling the rinse water does not prove it, in reality this is only saying that a tiny proportion or representation of this circuit did or didn’t grow bacteria. What about that allergen? What about that stubborn organic fouling? ATP sampling the rinse water does not prove it, once again this is only saying that a small representation of the circuit volume contains xxx amount of a type of organic matter, and importantly is only representing soil that hasn’t adhered to a surface and can be rinsed off with water alone.
While definitely an advance on traditional methods, in-line real-time measurement tools, such as Laser Induced Fluorescence to report on bio-burden or Total Organic Carbon analysers, still have the same drawback as ATP, in that they’re only testing for free-floating residue in the rinse water and can’t report on adhered substances.
There’s a new type of sensor that’s permanently fitted inside the circuit and transmits real-time data about the level of fouling it detects on the interior surface. While definitely useful for optimising CIP and potentially reducing cycle times, this can in no way be used as verification that the entire circuit is clean or free of organic substances, as it’s only giving feedback on one small part of it. While practically this can be considered representative of the entire circuit, it can’t report on that slow-flow area that is 20 mtrs back from the sensor, or on the biofilm growing on the worn gasket 2 mtrs after the sensor.
So what makes Smart CIP different to all these methods, and why is it the best method available today for verifying the effectiveness of your CIP? It ‘samples’ and ‘reports’ every single square millimetre of area inside your circuit in real time, through its colour change technology. No representative samples or guesswork involved.
Far from just analysing what rinse water can dislodge and carry, it reports on what a strongly alkaline, oxidising cleaner can react with and dislodge, which is far more meaningful if you want to know if there’s any stubborn residual soiling or biofilms left in your circuit that your normal CIP program can’t move.
Smart CIP will not stop changing colour until every last bit of organic-origin matter it’s come in contact with, has been reduced to its mineralised state, at which point it’s no longer an issue. So when no more colour change is occurring, you can be absolutely confident that your entire system is free of all organic substances.