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Monday, 20 May 2013

Sanitation Standard Operating Procedures (SSOP)


Sanitation Standard Operating Procedures (SSOP)
Sanitation standard operating procedure (SSOP) develops the basics for maintaining a food facility that has a clean, sanitary environment that is free from food hazard. In addition to these is two regulatory programs, a company should establish its own standard operating procedure (SSOP) where the company  establishes how things are to be done, when they are to be done, who will do them and what levels of operation a procedure is out of control and needs to be properly adjusted.
            Before developing a HACCP plan, it is essential to have a sound base of good hygienic and manufacturing practice. This means that all basic hygienic practices, encompassing facilities and operation, need to be in place and operating effectively.
            Sanitation standard operating procedures (SSOPs) are written procedures that an establishment develops and implement to prevent direct contamination or adulteration of product.
            As per FDA guidelines, title 21 in the Code of Federal Regulation (CFR) part 123 and 1240 specifically underline the need for SSOP for any establishment processing and importing fish and fishery products.
            The establishment must also maintain daily record sufficient to document the implementation and monitoring of the SSOPs and any corrective action taken. The establishment is required to maintain these written procedures on file, and they must be available for inspection. It is the establishment’s responsibility to implement the procedure as they are written in the SSOPs. If the establishment or inspection agency feels that the SSOPs fail to prevent direct contamination or adulteration of products, the establishment must implement corrective actions that include the appropriate disposition of product, restoration of sanitary conditions, and measures to prevent recurrence. It is also required that SSOPs should describe the procedure that the establishment will take to prevent direct contamination or adulteration of product.
            Some hazard that cannot be effectively controlled by CCP’s, cab be effectively controlled by procedure which control sanitation. These controls are called sanitation control procedure or SOP’s.
a)      The sanitation SOPs shall describe all procedure an official establishment will conduct daily, before and during operation, sufficient to prevent direct contamination or adulteration of product(S).
b)      The sanitation SOPs shall be signed and dated by the individual with overall authority on-site or a higher level official of the establishment.
 This signature shall signify that the establishment will implement the sanitation SOPs as specific and will maintain the sanitation SOPs in accordance with the requirement of this part. The sanitation SOP shall be signed and dated upon initially implementing sanitation SOP and upon any modification to the sanitation SOPs.
c)      Procedure in the sanitation SOPs that are  to be conducted prior to operating shall be identified as such, and shall address at minimum, the cleaning of food contact surfaces of facilities, equipment, and utensils.
d)      The sanitation SOPs shall specify the frequency with which each procedure in the sanitation SOPs is to be conducted and identify the establishment employee(S) responsible for the implementation and maintenance of such procedure.
  
 A written SSOP plan explaining the sanitation concerns, controls, in-plant Procedures and monitoring requirements is necessary based on the following Guidelines,

a.      Description of sanitation procedures to be used in the plant.
b.      Scheduling these sanitary procedures.
c.       Provide a foundation to support a routine monitoring programme.
d.      Encourage prior planning to ensure that corrections are taken when necessary.
e.      Identify trends and prevent recurrent problems.
f.        Ensure that everyone, from management to production workers understand sanitation.
g.      Provide consistent training opportunities for employees.
h.      Demonstrate commitment to buyers and inspectors.
i.        Lead to improved sanitation practices and conditions in the plant.
         
        As per 21 CFR, part 123 11 (a) of the FDA, each processor should have and implement a written SSOP or similar document that is specific to each location where food products are manufactured. It is also the duty of each processor to monitor the conditions and practices during processing with sufficient frequency to ensure that sanitation is maintained or conformed to what is described in SSOP plan.
            FDA combined the sanitary problems commonly encountered in to eight areas. These are generally referred to as Eight Key sanitation condition. They are,
1.      Safety of water that come in contact with food or food contact surfaces.
2.      Condition and cleanliness of food contact surfaces, including utensils, gloves and outer garment.
3.      Prevention of cross contamination.
4.      Maintenance of hand washing, sanitizing and toilet facilities.
5.      Protection of food, food packaging material and food contact surface from adulteration with lubricant, fuel, pesticides, cleaning, components, sanitizing  agent, condensate and other chemical, physical and biological contaminants.
6.      Proper labeling, storage and use of toxic components.
7.      Control of employee health condition that could result in the microbiological contamination of food, packaging material, food contact surface etc.
8.      Exclusion of pests from the food plant.

Thus sanitation stranded operating procedures (SSOP) should address each of the following points,
·         Written sanitation standard operating procedures (SSOP) describe those procedures the establishment conduct daily to prevent direct contamination or adulteration of the product.
·         Pre operational procedures are identified. Pre operational procedures address the cleaning of food contact surface of facilities, equipment, and utensils.
·         The SSOP frequency is specified for each procedure.
·         The employee(s) responsible for implementing and maintaining the procedure are identified.
·         Record are identified and kept, on a daily basis; this record document implementation and monitoring of SSOP and any corrective action taken.
·         The individual with overall authority on-site, or a higher level official, signs and dates the SSOP up on initial implementation and signs and dates any new modification.

There is no mandatory or specified method or form for sanitation monitoring. It is up to the processors to develop suitable monitoring procedures based on the eight key sanitation condition specified. The success of the monitoring dose not depends on the approach, but on the evidence it yields to reflect routine and appropriate sanitation practices.

1.      Safety of water
            It should be the primary concern for any fish processing unit that the water used for processing should be safe and clean. SSOP regulations also clearly indicate the necessity of water safety. A complete SSOP plan regarding the source of water and the treatment followed in necessary for all processing plant. It should also consider the cross connection between potable and non potable water supplies. In seafood processing plant, cross connection have been found in many places such as hard plumbing between potable and non potable water lines, cleaning hoses lying in water pooled in the processing floor. As per SSOP regulation the key sanitation condition to be addressed include:
a.      Safe supply of water that contacts food and food contact surface.
b.      Safe supply of water for production of ice.
c.       There no cross contamination between potable and non potable water.
            The plant should have written SSOP procedure to monitor all the source of supply, means distribution, water quality, of plumbing etc and should have written corrective action, in case of any breach in safety of water used.
  2. Condition and cleanliness of food contact surfaces:
Food contact surfaces in food processing plants include all equipments, utensils and other facilities used for processing of fish. This also includes worker clothing, their hands and packaging materials. This is a very important concern since contamination of food can come from numerous indirect routes that are not always obvious during processing.
The main aim for this SSOP component should be the processing unit should have adequate monitoring which assures that the food contact surfaces of every kind, including gloves, outer garments, tables, utensils etc are properly designed, constructed and maintained to facilitate sanitation, easy to clean and that they are adequately and regularly cleaned and sanitized. The facilities should be made from materials which do not contaminate the food processed. The selection of material for the fabrication of these surfaces should be done with utmost care. The material should not be toxic, should not corrode or erode during processing.
There should be written cleaning schedule to be followed. Detergent and sanitizer used should be food grade. Phenolic compound should never be used for cleaning food contact surface. Frequent monitoring should be in place to see that cleaning schedule is effective. All the observation should be recorded in daily sanitation record and should be made available for inspection.
3. Prevention of cross contamination.
            This aspect relates to practices that are adopted to prevent product contamination. This includes the employee practices, physical separation of raw material and cooked product, plant design etc.
            Raw sea food contains micro organism that cause food spoilage. It may also contain pathogen which causes human illness. Pathogen can come only from contamination of fish and fishery product after harvesting due to poor handling practices. People who handle fish can harbor pathogens in their skin and hands, hair, respiratory tracts etc. These microorganisms have no means on their own to move around in a food processing plant, they must be physically carried from one place to another. Cross contamination is the transfer of biological or chemical contamination to food product from raw food, food handlers, or food handling environment. 
            Hands, gloves aprons, utensils, food contact surface etc. are some of the item, which comes in to contact with wastes, floor, or any other sanitary objects that can contribute to product contamination. Employees should be properly trained on how to sanitize their hands properly.
Sanitation of gloves, outer garments, food contact surfaces, food handling equipment are also should be cleaned and sanitize regularly to prevent contamination. All residual products and wastes should be removed frequently; proper detergent and food grade sanitizers should be used for cleaning and sanitation. Suitable monitoring measures should be in place to inshore employee hygiene at the beginning of shift and periodically during the work hours. This evaluation should insure that employees are clean, and are wearing appropriate attire including hair restraints, and are not wearing jewelry or other ornaments that could contaminate the product. Employee practices should be monitored periodically throughout the work to ensure that cross contamination does not occur. Effective monitoring should be done to see those employees are following hygiene practices properly, that inappropriate activities such as drinking, eating, and smoking does not occur in food processing areas and that employees working with raw products do not go or move equipments to areas where cooked or ready to eat products are handles.
There should be adequate separation of raw and cooked or ready to eat product handling or processing activities. There should be adequate separation or protection of these products while storing.
            All the observation and monitoring should be recorded in sanitation control records. It should provide evidence that company’s sanitation program are effective and adequate. Any deviation in the procedure, should be suitably intervened, corrected and recorded.
4. Maintain of hand washing, hand sanitizing and toilet facilities:
            Seafood processing facilities generally require significant amount of manual handling of product. Unfortunately human hands are used for more than just handling foods by plant workers. When engaged in these activities, hand may become contamination with harmful micro-organism. Hence adequate hand washing facilities are must in processing area. Food processing facilities must establish an effective hand washing program. The availability and maintenance of adequate toilet facility commensurate with number of employees are essential part of SSOP to prevent the spread pathogenic organism and cross contamination. The sanitation control employed in these aspects should be monitored and recorded daily.
5. Protection from adulterants:
            This aspect of SSOP is followed to ensure that food, food packaging material and food contact surface are protected from various microbiological, chemical and physical contaminant such as a lubricants, fuel, pesticides, cleaning components, sanitizing agents, condensate, floor splash etc. as per Food Drug and Cosmetic Act of US, Section 402 item a (1) and a (4) clearly states that any food is treated adulterated, if it had been prepared , packed, or held under unsanitary conditions whereby it may have become contaminated with filth, pathogens and thus become injurious to health.
            The processor should be aware of all avenues which would cause his food product to be adulterated such that it may be unsafe to eat due to possible indirect or unforeseen contamination from such thing as lubricants, fuel, pesticides, condensate and residues or aerosols from toxic cleaning compounds. Plant employees must be trained to anticipate and recognize these possible indirect routes of contamination. Procedure must also be aware that contaminating food contact surface, ingredient and packaging materials is equivalent to contaminating the finished product. Each of these aspects should be monitored and recorded daily. Any deviation observed should be corrected immediately and recorded.
6. Proper labeling, storage and use of toxic compounds:
            Chemical used in most food processing plant include cleaners, sanitizers, rodenticides, insecticides, machine lubricants, food additives, etc. they must be used according to manufactures instruction, have proper labeling, and be stored in a safe manner away from processing or food handling area. All relevant government regulations relating to the application, use and storage of these products should be followed and recorded. The containers should be properly labeled. The label should indicate the name of the compound, name address of manufacturer / distributor, instruction for proper use and procedures to be followed in case of spoilage.
            These chemical should be properly stored in an area of limited access away from food handling or processing area. It will be a good idea to keep this in a locked room or cage, with the keys given only to identified personnel. Adequate records have to be maintained.
7. Control of employee health:
            The condition ensures that contamination of food product will not happen through employees having symptoms of an illness, wounds other affliction that could be a source of microbial contamination. This includes diarrhea, fever, vomiting, jaundice, sore throat, open skins, sores, cut, boils, dark urine etc. The employee health should be regularly monitored by a medical officer and record of their health track has to be maintained.
 If an employee is determined to have the symptoms of diseases, the supervisor should,
a.        Report the matter to the authorities
b.      Reassign and relocate and employee to a non food processing area or send employee home until the health condition has changed or tests are negative.
c.       When lesions are present, an employee should be reassigned, sent home or an impermeable cover must be placed over the lesion.
8) Exclusion of pests:

            Suitable procedures should be in place that pests are excluded from relevant areas of the plant to the extent possible and should also confirm that procedures are followed to prevent infestation. The pests include rodents, birds and insects. The presence of rodent’s birds, insects or other pests in the processing plant is unacceptable.

            Observation related to exclusion of pests made while monitoring must be documented and should be made available during an inspection. Evidence of correction is a required part this record. Record should provide evidence that company sanitation program is adequate, that it is followed scrupulously and that problem are identified and corrected.
            Therefore communicating and promoting the need for an efficient food safety system such as HACCP is prime importance for the food processing industry. SSOPs and GMPs are currently recognized as an essential system for the effective implementation of HACCP. It is the responsibility of the food producers to take the measures necessary to supply consumers with a safe product. It is important the measures are consistent with standard internationally recognized to facilitate trade

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