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Nilfisk Industrial Vacuums’ Public Comment to the FDA on Preventative Control Measures for Food and Feed Facilities

Thursday, August 4th, 2011

On May 26th, 2011, The U.S. Food and Drug Administration (FDA) issued a release seeking public comment on preventive control measures for food facilities through a public docket opened as part of the FDA Food Safety Modernization Act (FSMA), signed into law by President Obama in January.

The FSMA requires registered food and feed facilities to evaluate the food safety hazards that could affect food and feed they manufacture, process, pack, or hold and to identify and implement preventive controls to address those hazards. The agency opened the docket to solicit specific recommendations from stakeholders on what preventive control measures are appropriate, and any other pertinent information and recommendations, including measures that are workable for small businesses.

The FDA is required to issue guidance with respect to hazard analysis and preventive controls, and information submitted to the docket will be considered in the development of that guidance.

As a stakeholder serving food and feed facilities, Nilfisk Industrial Vacuums found it appropriate and necessary to submit our public comments regarding preventative control measures, as they apply to proper housekeeping. The following is our official public comment.  

August, 2011 

 

Re: Public Comment for Preventive Controls for Registered Human Food and Animal Food/Feed Facilities: Docket No. FDA-2011-N-0238 

 

We appreciate the opportunity to submit our comments regarding the FDA’s Food Safety Modernization Act, as it relates to Preventative Controls for Registered Human Food and Animal Food/Feed Facilities. As a leading provider of HEPA filter industrial vacuum cleaners for more than 50 years, Nilfisk Industrial Vacuums is highly aware of the challenges and concerns today’s food manufacturers face as they attempt to produce a high-quality product, free from contamination, while simultaneously meeting government and industry guidelines. Our Product Manager and Application Engineer regularly field questions from customers looking to us for advice on how to efficiently and cost-effectively keep their plants clean through the use of industrial vacuum cleaners. While we enjoy these calls and do our best to advise our customers, Nilfisk Industrial Vacuums is not a regulatory authority; we can only provide information as it pertains to our products, and therefore see the need for well-defined preventative control guidelines that address housekeeping best practices within food manufacturing facilities. We hope you’ll take our below recommendations into consideration. 

 

COMMENTS:

The below general comments are in regards to these points, as specified in section II of Docket No. FDA-2011-N-0238

  • Implementing process controls
  • Implementing sanitation controls
  • Allergen control (human food) including…procedures and practices to prevent the unintentional incorporation of a major food allergen into a food by cross contact during manufacturing, processing and holding food.
  • Preventative control approaches and practices that are practical for small and very small businesses to implement 

From transferring and preparing ingredients, to mixing, baking, and packaging, food manufacturing facilities often generate large amounts of dust throughout the manufacturing process. If not collected at the source by a vacuum cleaner integrated into the processing system, the dust quickly settles on floors, machinery, hard-to-reach, and overhead areas. This dust is a breeding ground for insects, rodents and many different types of bacteria. For this reason, it is critical that food manufacturers implement a comprehensive maintenance plan that keeps dust levels at a minimum. Currently, food facilities use many different tools for keeping dust at bay, and while some may work well, there are definite advantages offered by certified HEPA filtered  industrial vacuum cleaners that the other methods lack. For this reason, we encourage the FDA to better define best housekeeping practices, and to consider the following:

 

•          While mops, brooms, and compressed air all have their place in maintenance plans, these methods often leave particles of dust and debris behind. Actually, compressed air only moves dust from one place to another; it does nothing to eliminate the dust.  Also, mops and brooms promote growth of bacteria and can easily spread bacteria and pathogens to many areas of a facility. Industrial vacuum cleaners equipped with multi-stage filtration, including a certified HEPA filter, trap and retain collected materials, without distributing it back into the atmosphere.

 

•          In addition to general maintenance, specialized industrial vacuum cleaners can be utilized for source capture to collect dust at the point of generation before it can accumulate in various areas of the plant. This can also improve allergen control, by containing dust (ie. peanut dust) at the source before it can spread to other processes.

 

•          Housekeeping should be as easy and ergonomic as possible (lightweight and user-friendly)

•          Industrial vacuum cleaners can be equipped with food grade hose and accessories customized for the food industry, such as those for overhead cleaning and hot oven cleaning.

•          Currently there is no homogenous color coding system for the food industry. Manufacturers create their own coding system (eg. blue wall brushes for cleaning allergen production lines). We recommend the creation and implementation of a standard color coding system in the food industry in order to decrease cross contact of allergens and bacteria.

 

•          Not all industrial vacuums are equal.

•          The food industry should use industrial vacuums equipped with High Efficiency Particulate Air Filters (HEPA) that at a minimum remove 99.97% of particles, down to and including 0.3 microns. These filters should be tested and approved by a private testing body.

•          High quality HEPA filter industrial vacuum cleaners are often available in stainless steel. Stainless steel vacuums won’t chip like painted vacuums (another possible source of contamination) and are easy to clean.

•          Currently, many manufacturers use “shop-style” vacuums in some capacity. While these may be adequate to collect dust, they are often known for their short lifespan, which often cost manufacturers more in the long run through replacement costs. (See supporting document for ROI analysis)

•          Also, shop-style vacuums should NOT be used to collect hazardous dust, such as flour and grain (reference OSHA’s Combustible Dust NEP). Using these vacuums to collect combustible dust can cause a fire/explosion due to their plastic construction, exposed motors and tendency to overheat.  

 

 

SUPPORTING MATERIALS

Please view the attached supporting materials:

- Published Article: Survey Says: Clean for Safety and Profitability

- Published Article:Left in the Dust: Industrial Vacuum Cleaners Outperform Mops, Brooms, Shop-style Vacuums

- Case Study: McDonald’s Bun Facility Finds Vacuum Worthy of High-Tech Operation

-Video Case Study: Harris Woolf Almonds Receive AIB Recognition with the use of an Industrial Vacuum Cleaner 

 

 

Sincerely,

 

 

Paul R. Miller 

Vice President & General Manager

Nilfisk-Advance America, Inc.

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Food Manufacturers Speak Up!! The FDA is seeking YOUR opinion on the FSMA

Tuesday, June 14th, 2011

Are you in the food industry and want your voice to be heard in regards to the Food Safety Modernization Act? Now’s  your time to speak up!!!  The proposed rule on preventative controls is expected this fall.

Earlier this year, President Obama signed into law the FDA Food Safety Modernization Act (FSMA), which requires food manufacturers to take certain actions, including evaluating the hazards that could affect food manufactured, processed, packed or held by a facility and to identify and implement preventative controls to significantly minimize or prevent occurrence of such hazards. In accordance with the FSMA, the FDA is now tasked with creating specific guidance on preventative control best practices.  In order to represent the diverse needs and challenges of the industry, the FDA is seeking the public’s comments that will inform the development of guidance on hazard identification and control measures associated with specific types of food for specific methods of manufacturing. They are seeking general comments in regards to:

  • Conducting a hazard analysis to determine the hazards associated with specific human/animal food
  • Implementing process controls to prevent, eliminate or reduce to acceptable levels the occurrence of any hazards that reasonably likely to occur
  • Validating food/feed safety controls
  • Implementing sanitation controls
  • Implementing supplier controls
  • Allergen control
  • Environmental monitoring for Salmonella and for Listeria
  • Preventative control approaches and practices that are practical for small and very small businesses to implement?

Comments may be submitted either electronically or in writing until August 22, 2011. Submit electronic comments at http://www.regulations.gov/#!documentDetail;D=FDA-2011-N-0238-00011.

Submit written comments to:
The Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852

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Bun Facility Finds Nilfisk Industrial Vacuum Worthy Of Its High-Tech Operation

Tuesday, May 24th, 2011

As featured in Food Manufacturing’s e-newsletter, Today in Food Mfg. and Manufacturing Business Technology

Supplying hamburger buns for the fast food giant McDonalds, the Turano Bakery facility in Orlando, FL must run an exceptional operation in order to bake a quality and consistent product that billions have come to expect.

For nearly half a century, the Turano family has followed European traditions to bake the freshest, highest quality artisan-style breads such as Ciabatta, Focaccia, Hearth-baked Peasant breads, and a variety of rolls. Sharing a favorite family recipe from past generations, they use authentic time honored techniques to ensure exceptional old world flavor in each and every bite. Their extensive line of specialty breads and rolls are delivered fresh daily throughout the Chicagoland area. In addition, Turano Breads can be found across the United States on a frozen basis through food distributors and top national restaurant chains.

The bakery’s state-of-the-art facility, equipped with an automated inspection system and wireless data communications program that allows plant management to adjust the operation as needed, even from home, give Turano the ability to produce approximately 1,100 soft buns a minute, which are then distributed to nearly a thousand McDonalds in the southeast. With such high expectations, there’s no room for error or downtime, even when it comes to maintenance.

According to Jeff Benny, Sanitation Manager, Turano Bakery initially used shop-style vacuums for general cleaning of excess flour that decorates virtually any size baking operation. Unfortunately, these low-cost commercial vacuums frequently overheated, sparked, and broke down, resulting in workers having to take more trips to the dumpster than cleaning their 100,000 sq. ft. facility.  In fact, Jeff estimates they went through 6 to 10 shop-style vacuums in a 1 year period alone.

Fortunately, Jeff was familiar with Nilfisk Industrial Vacuums and his local Florida rep, Rick Stegbauer, from a previous job.  Jeff reached out to Stegbauer, hoping he could visit the plant and assess their needs for a high-quality vacuum that could stand up to their cleaning challenges and not end up in the trash. Stegbauer immediately scheduled a visit to demonstrate several of Nilfisk’s food industry vacuum cleaners. After trying several of them out, Turano settled on the Nilfisk CFM 118, single-phase, portable vacuum cleaner, a favorite in the industry.

“Rick was just great,” said Jeff Benny. “Following the sale, he played an active role in making sure the vacuum was set up right and our staff knew how to use it. He conducted onsite demos and training that really showcased the capabilities of our new investment.”

Since purchasing the Nilfisk vacuum, Jeff is just amazed at how it has transformed cleaning in the plant.

118_Turano“Our mechanics use it to clean around the Larramore flour reclaimer system, which manages the dusting flour before the buns enter the proof box. Cleaning the Larramore used to be a 2 hour job. Now, it is done in 45 minutes.”

Jeff’s team has also found many other uses for the Nilfisk vacuum, including the packaging area, which now only takes 2 hours to vacuum, compared to the previous method of messy blow down which could take a several hours. He also estimates that overall general cleaning of the facility has decreased from three hours down to an hour and a half in the makeup areas.

With so many quality assurance procedures to implement and daily tasks to complete, Jeff  and the rest of the Turano Orlando team enjoy knowing they don’t have to worry about the vacuum cleaner failing. 

“The Nilfisk CFM 118 fits right into the strict efficiency requirements of this Turano facility,” Jeff remarks. “It’s a dream come true.”

Want to read another Nilfisk CFM 118 success story in the food industry? Check out Curds and Whey: Nilfisk CFM 118 Combats Dusty Whey Powder.

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Food Safety Act Puts Focus on Prevention

Wednesday, January 5th, 2011

Taken from FoodSafety.gov

food safetyEven before the President signed the Food Safety Modernization Act, the passage of this legislation set in motion sweeping improvements to the security and safety of our nation’s food supply.

Each year, foodborne illness strikes 48 million Americans, hospitalizing a hundred thousand and killing thousands.

The historic legislation the President has signed directs the Food and Drug Administration, working with a wide range of public and private partners, to build a new system of food safety oversight – one focused on applying, more comprehensively than ever, the best available science and good common sense to prevent the problems that can make people sick.

The idea of prevention is not new. FDA has established prevention-oriented standards and rules for seafood, juice, and eggs, as has the U.S. Department of Agriculture for meat and poultry, and many in the food industry have pioneered “best practices” for prevention. What’s new is the recognition that, for all the strengths of the American food system, a breakdown at any point on the farm-to-table spectrum can cause catastrophic harm to the health of consumers and great disruption and economic loss to the food industry.

So, we need to look at the food system as a whole, be clear about the food safety responsibility of all of its participants, and strengthen accountability for prevention throughout the entire food system – domestically and internationally. The new law meets these needs in numerous ways.

  • For example, processors of all types of food will now be required to evaluate the hazards in their operations, implement and monitor effective measures to prevent contamination, and have a plan in place to take any corrective actions that are necessary. Also, FDA will have much more effective enforcement tools for ensuring those plans are adequate and properly implemented, including mandatory recall authority when needed to swiftly remove contaminated food from the market.
  • We (Congress) will, in accordance with the law, establish science-based standards for the safe production and harvesting of fruits and vegetables to minimize the risk of serious illnesses or death, and we will set standards for the safe transportation of food.
  • Moreover, with the signing of the law, FDA will for the first time have a congressional mandate for risk-based inspection of food processing facilities.  For example, all high-risk domestic facilities must be inspected within five years of enactment and no less than every three years thereafter.  

The legislation significantly enhances FDA’s ability to oversee the millions of food products coming into the United States from other countries each year.  (more…)

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Beetles Invade! …. Formula? Similac issues voluntary recall.

Tuesday, September 28th, 2010

Last week, I “tweeted” about the Similac formula recall as a result of beetles.  Not surprisingly it got a lot of hits, most likely from extremely worried mothers. According to Abbott Laboratories, the recall of more than 5 million pounds of the company’s powdered formula, came after reports by two consumers of contamination and an internal quality review of an area in the Sturgis, MI plant where beetles or their larvae were found.

Pretty gross, I know. Unfortunately, just like you get annoying pests  in your house, manufacturers, including the food industry, get bugs in their facilities.  Actually, food processing plants can be a bug wonderland, with plenty of places to hide and an ample food supply. Fortunately, most plants are extremely vigilant to keep insects out of their plants through comprehensive pest control and sanitation programs. And because using chemicals in a food plant should only be a last line of defense, a strict maintenance plan that includes an industrial vacuum cleaner can play a critical role in bug prevention.

Take for instance, Harris Woolf Almonds. As a major processor of almonds, their facility generates lots of almond dust, a breeding ground for insects.  They use to clean their plant daily with mops and brooms, but not only was it extremely time-consuming and inefficient, it never completely eliminated the almond dust that settled on machinery, walls, and floor. Not to mention that brooms easily spread bug larvae, and water left behind from mopping could easily attract insects. Several years ago, the almond processor invested in a Nilfisk CFM 137 (now the S3). Equipped with wands and nozzles to reach overhead and tight spaces, the vacuum has been able to collect every last bit of almond dust, about 75% faster than sweeping. In fact, shortly after incorporating the vacuum into their maintenance plans, they received Superior recognition from AIB International.

According to Copesan, a pest control company, every dollar spent on insect pest prevention will, most likely, return additional dollars in reduced product losses. So managing pests is actually an investment and not an expenditure. Prevention is one critical factor in any effective pest management program. Prevention of pests means prevention of losses — losses of product, reputation and time. Prevention takes many forms. Two basic forms are exclusion and sanitation. Keeping the pests outside, along with proper sanitation inside, helps prevent infestation and leads to a more organized, more efficient and safer work place.

For more information:

www.foodprocessingvacuum.com

Managing Insect Pests in Food Storage Facilities

Keep the Bugs Away, Food Processing magazine.

Harris Wolf Almonds/Nilfisk CFM  Industrial Vacuum Case Study

 

 

 

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Longopac Continuous Collection Bag on Nilfisk CFM Industrial Vacuum Cleaners

Thursday, August 12th, 2010

One of the new features of our new S2 and S3 industrial vacuum cleaners is the Longopac Collection System.  This is an “endless” collection bag that can be filled, cut, sealed, and then dispensed to your desired length for new use. This system is very popular in the building and construction industry, but there are also many uses for it in the food and pharmaceutical industries.  Want to know more? Check out the below video and visit www.newnilfiskvacuums.com or www.nilfiskcfm.com.

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Automatic Shut-Off System on S3 Industrial Vacuum Cleaner

Friday, July 16th, 2010

Our new S3 vacuum can be equipped with an automatic solid-level sensor that shuts off the industrial vacuum cleaner when maximum capacity is achieved.  This feature is great for increasing productivity since workers don’t have to worry about overfilling the vacuum—instead, the vacuum tells them when it needs to be emptied. Perfect for collecting large amounts of grain or whey powder in the food industry. Check out the below demonstration and to get more information on the new S3 vacuum, visit www.NewNilfiskVacuums.com!

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Did you know…Nilfisk CFM Food Processing Vacuums

Thursday, July 8th, 2010

Did you know…
Nilfisk CFM HEPA vacuums and portable dust collectors for the food industry:

  • Are trusted by food industry giants like Kraft, Hershey and Nestle?
  • Are the number one choice for companies implementing cleanroom environments?
  • Feature advanced filtering technology with HEPA filters that guarantee the most thorough cleaning, capturing bacteria down to 0.3 microns?
  • Feature optional ULPA filters that collect 99.999% of all ultra-fine particles – down to and including 0.12 microns?
  • Are engineered for maximum efficiency, protecting filters from premature clogging?
  • Are available as intermittent-duty portable vacuums for general cleaning, continuous-duty models, wet/dry vacuums, and more?
  • Deliver the largest assortment of attachments, filters and hoses in the industry – including:  accessories for overhead cleaning, stainless steel construction, and food-grade, FDA-approved, polymer-constructed hoses?

Find out more at our new food industry focus site, www.foodprocessingvacuum.com!

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Food Industry Sees Increase in Capital Budgets; Safety to blame

Thursday, July 1st, 2010

Good news for the food industry! Business is booming. Food Processing magazine recently conducted a survey of 32 public companies in their Top 100 list and uncovered 13.6 million dollars budgeted for capital expenditures. Overall, captial spending is up almost 20% in the industry, compared to last year’s decline of 8.7%.

The reason? Well, some companies, like PepsiCo have completed mergers, which make them a larger company than they were last year–$60 billion larger. But safety has also played a critical role. As FP mentions, noone wants to be the next Peanut Corp. of America, and extra meausures have been put in place to improve sanitation and cleanability. (Hello food processing vacuums!)

Along the lines of safety, but not mentioned in the article, is combustible dust. Imperial Sugar made combustible dust a very critical issue in the food industry and got every plant manager listening and wondering if their flour, whey powder, dried milk, cinnamon, peanut dust, etc., etc. was “combustible.” Not surprisingly, Imperial Sugar’s capital expenditures budget is way low this year (compared to previous years), since they’ve had to put their money towards rebuilding the Port Wentworth facility. So, noone wants to be next Imperial Sugar either, and are budgeting money to invest in the proper equipment like explosion proof vacuum cleaners, venting systems, etc.

Read the entire report here…

2010 Capital Spending Outlook: Pent-Up Demand Causes an Explosion in Projects
Dave Fusaro, Editor in Chief; After last year’s drop in capital expenditures, budgets for the Food Processing Top 100 survey group are up 19 percent for 2010.

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Visit Process Expo for Free!

Wednesday, June 30th, 2010

Process Expo

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