The 15-gallon VT60CR contains critical cleanroom features, such as a unique four-stage filtration system, that allows it to meet cleanroom standards up to and including Class 10.  The water-, rot-, mildew- and corrosion-resistant main filter captures particles down to 1 micron and is covered by an exclusive splash guard to protect against excessive moisture and further extend the life of the HEPA filter. For added protection in the cleanroom environment, the optional ULPA exhaust filter prevents toxic particles from becoming airborne. 

Other features and benefits include: 

• Multiple collection and disposal options,including a polyliner or 5-gallon disposable pail for bulk nuisance or hazardous material.
• Detachable trolley features sturdy polyethylene construction and large, smooth wheels for easy decontamination and added maneuverability.
• Pliable rubber inlet tube is designed to relieve caking and clogging caused by the collection of damp or sticky material. 

For more information on this cleanroom vac and pharmaceutical contamination control,  visit our pharma focus site at  www.pharmaceuticalvacuum.com!

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.

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

Even 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.

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

Among the improvements is the requirement that importers verify the safety of food from their suppliers and the authority for the FDA to block foods from facilities or countries that refuse our inspection. FDA will also be working more closely with foreign governments and increasing its inspection of foreign food facilities. FDA’s new import tool kit will have a huge impact on food safety given that an estimated 15 percent of the U.S. food supply is imported, including 50 percent of fresh fruits, 20 percent of fresh vegetables and 80 percent of seafood.

Very importantly, the FSMA calls for the strengthening of existing collaboration among all food safety agencies whether they are Federal, state, local, territorial, tribal, or foreign. Among other provisions, the legislation directs the Secretary of Health and Human Services to improve training of state, local, territorial and tribal food safety officials and authorizes grants for training, conducting inspections, building capacity of labs and food safety programs, and other food safety activities. Building and leveraging the capacity of these food safety partners is how we can have a well-integrated, national food safety system that is as effective and efficient as it can be.

Now, the task falls to the FDA to carry out the direction we’ve been given. We are hard at work planning how we will put this law into effect. As we look to make the improvements called for in the legislation, we must ask ourselves many questions. What resources do we already have? What resources will we need? Where will those resources come from? Already we know that the legislation did not include sufficient fee resources to cover the costs of the new requirements. In that, we will look to Congress to work with us to ensure that FDA has what’s needed to achieve our shared food safety and food defense goals.

This law represents a sea change for food safety in America, bringing a new focus on prevention, and I expect that in the coming years it will have a dramatic and positive effect on the safety of the food supply. 

By Margaret A. Hamburg, M.D., Commissioner of Food and Drugs

For more information and tips on food contamination prevention, visit the food safety part of our blog and our food contamination focus site at www.foodprocessingvacuum.com.

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

• 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!

From high-temperature cleaning nozzles, FDA-approved polymer-constructed hoses, overhead cleaning wands, to accessories for floors, equipment, pipes, corners, and other hard-to-clean areas in food processing plants, we have the vacuum cleaner accessory to match any outfit…I mean application.  And our line wouldn’t be complete without our popular color-coded vacuum cleaner nozzles, which allow the  user to easily match the right nozzle with the right application to prevent cross-contamination.  

Chances are, we have the right attachment for whatever you need to clean. If you’re looking to clean the plant floor, we offer tools for bare floors and carpeted floors; dry floors and wet floors; rough surfaces and delicate surfaces. Or, if you need to get into all the nooks and crannies at your plant, we offer specialized tools ranging from crevice nozzles to curved wands for overhead cleaning. It’s truly the largest product offering of its kind for the food processing industry.

And best of all, they never go out of style! For more information, visit www.foodprocessingvacuum.com

To meet their maintenance needs, NWFPA attendees will want to stop by booth # 320 where Nilfisk CFM will display several of their food processing vacuums, proven to be successful in a variety of food industry cleaning applications.

• The Nilfisk GWD 220, is a double-motor wet/dry vac with a 20-gallon stainless steel collection container. It can be fitted with an upstream HEPA filter and requires no filter change between liquid and dry collection.
• The Nilfisk CFM 137 is a compact, full-feature vacuum useful for general plant maintenance, overhead cleaning, and the collection of fine powders and debris. The vacuum offers high filtration performance, noise control, quality construction and user-friendly controls.
• The Nilfisk CFM 118EXP is an explosion-proof vacuum suitable for collecting hazardous materials, thus decreasing the risk of a combustible dust accident. Composed of 304 stainless steel, the 118EXP is CSA certified for use in Class I, Group D, and Class II, Groups E, F, and G environments.

All Nilfisk CFM vacuums can be equipped with special hose and accessories, including those for use in hot ovens and overhead cleaning of pipes and machinery. For more information, visit www.foodprocessingvacuum.com.

For more information, visit www.foodprocessingvacuum.com.

From cleanrooms to production, to packaging, the pharmaceutical industry has many different needs and requirements when it comes to combating contamination. Pharmaceuticalvacuum.com addresses these needs with a one-stop site that provides video, application photos, links to government regulations, and pharmaceutical vacuum tutorials.

For more information, visit www.pharmaceuticalvacuum.com.

Through video, frequently asked questions (FAQs), application photos, articles, and links to industry resources such as FDA guidelines and trade publications, www.foodprocessingvacuum.com is a one-stop site for manufacturers looking to learn more about contamination control and the role an industrial vacuum plays in safeguarding facilities.

The micro site will be updated on a continuous basis, in order to stay on top of industry news and trends. For more information, visit www.foodprocessingvacuum.com.

Note: The company has also developed two other micro sites, www.explosionproof-vacuum.com, dedicated to the prevention of combustible dust-related fires and explosions, and www.pharmaceuticalvacuum.com, which addresses contamination control in pharmaceutical processing facilities.