A Look at the Food Safety Program at Butterball, LLC
By Alice Johnson, DVM
Food Safety Starts with Employee Training
In considering post-lethality exposed product, associates can either be the best defense against or the greatest cause of cross-contamination. This means your best employee can be your biggest risk if he or she does not understand food safety and GMPs. Extremely stringent employee hygiene practices should be implemented and process modifications made wherever possible to assure separation of facility entrances, hallways and break areas between RTE and raw manufacturing.
All employees should undergo a series of training sessions that prepare them to care for their personal safety and to recognize the importance of product safety. Additionally, employees should be educated about the reasons for the practices in their departments. Training should be updated departmentally and employees should be brought together often to discuss any opportunities for improvement that occur to them during their shifts. They should participate in investigations related to environmental sampling results, as they will be involved in implementing any corrective action identified. Further, employees must take responsibility within their departments to ensure that hygienic practices are followed with regard to other associates and visitors.
Employees should be trained to carry out detailed procedures once they arrive at the facility. The GMPs in place outline requirements for removing all jewelry, not chewing gum, labeling chemicals used in the RTE department and following very stringent measures that relate to microbiological hazards. Listeria monocytogenes is the primary pathogen of concern in RTE departments. Appropriate cooking eliminates the pathogen, but the possibility for cross-contamination from people, equipment and the processing environment is always present. Starting with simple practices helps keep product safe.
Employee GMP Procedures Start in the Locker Room
Attention to GMP procedures is critical. To illustrate this fact, employees follow proper GMP measures upon entering the Butterball RTE locker room. They are required to obtain personal items, such as smocks, gloves and safety glasses, from a central distribution area. Their boots are kept clean and stored in a designated area as well. Smocks, hairnets, beard guards, safety glasses, earplugs, gloves, boots and masks are all required and must be worn by associates prior to entering the RTE vestibule. Smocks are laundered internally and cover outside clothing to knee level. Smock color differs from that of the raw side and the smocks do not have outer pockets. All street clothes and hair must be covered.
All of our facilities have been modified where possible so that entry into the RTE production department requires employees to go through a vestibule dedicated to cleaning and sanitization. This entry-only area is isolated, where practical, from both the locker room and the production floor. The first part of the clean-and-sanitize vestibule is a boot scrubber that employees walk through. The scrubbing process requires the bottom and sides of the boots to go through brushes with soap and sanitizer spray. This initial sanitizing step eliminates any debris. After the boot scrubber, employees move to hand-washing stations that are located in an area of the vestibule with a troughed floor and an additional boot sanitizer. This process has eliminated the traditional dip pan, once considered a necessity. Standing in the floor trough while washing hands provides better contact and dwell time for boot sanitizers. In addition, the process helps to keep water off the floor from footbath spills and drips, and limits the number of door foamers needed. Keeping the RTE production floor and department dry is an important microbiological control.
Hand-wash stations vary within the company from a high-tech, motion-sensing machine to a simple knee-operated sink. The equipment used for hand washing is not as important as the technique of washing. Proper hand washing involves the “happy birthday” scrub song with warm soapy water (this ensures hands are washed for an adequate amount of time) as well as thoroughly drying hands with a paper towel. Again, we cannot say enough about employee training and awareness! A sanitizer station is positioned after the hand-washing station and before the RTE door. Sanitize, sanitize, sanitize! Once again, hands, bump caps and any equipment are sanitized prior to opening the door to the RTE department.
Once on the floor, employees go through another “dressing” step within the corral, a marked area that leads into the RTE department. Disposable gowns or aprons, again color-coded, are used in addition to disposable sleeves and gloves. There is a final step for gowns, aprons sleeves and gloves prior to leaving the corral—sanitize!
To further protect product, employees encountering unsanitary equipment must change all disposable items before returning to the work area. Those who handle trash and condemned product are designated and wear specific, color-coded garments. If an employee leaves the RTE department, they must change smocks and go through the RTE vestibule again. Traffic in and out of the RTE vestibule is one-way.
Best Practices within the RTE Vestibule
Now that employees are clean and sanitized, the work begins. Employees going through the pre-department vestibule are focused on the cleaning and sanitizing steps. However, once on the floor and working, it is easy to get distracted and forget key practices. The word “training” again comes to mind. Monitoring and good documentation is extremely beneficial. However, it is easy to get into the habit of documenting for the sake of documenting, without taking time to review the records and look for trends. Understanding trends help us develop additional training or adjust practices as needed to help our associates prevent cross-contamination.
Work instructions are also in place for all jobs within the RTE department. Racks are loaded and unloaded in a manner that prevents possible contamination. Procedures outline product handling to prevent contamination of hands and at what point associates should resanitize.
Maintenance employees are dedicated to RTE. Any work performed in the RTE department is treated as if it is a production day. This includes our contractors. All tools and handheld equipment are cleaned and sanitized with alcohol when entering the production area. After alcohol, special sanitizer wipes are also used on tools, clipboards, thermometers, control boxes, etc. when entering the RTE department. Equipment wheels and frames are scrubbed and sanitized when entering the production floor, and a sanitizing spray follows behind the equipment as an additional precaution.
The emphasis we place on employee practices applies to general sanitation as well. Extensive pre-operational cleaning and sanitizing is performed daily, with programs in special equipment cooking or fogging performed on a scheduled frequency.
While we use observation for basic monitoring to ensure that GMPs are followed with regard to employee actions, we go further with microbiological verification—we use an environmental sampling program.
Our three laboratories across the U.S. work around the clock on microbiological sampling. These labs follow AOAC-prescribed sampling procedures. We periodically send samples to outside labs as part of a validation for our own results.
The L. monocytogenes testing program is a general sanitation verification process. This testing cycle is designed to indicate whether the facility’s cleaning methods and employee practices effectively reduce the growth of Listeria and other bacteria. Routine surface, equipment and employee checks are performed throughout the processing lines to ensure that all harmful organisms are located and eradicated. Trained associates perform these tests daily to seek and destroy pathogens detected on vital processing surfaces.
Environmental Monitoring Plan
Our environmental monitoring plan complements the general sanitation process by thoroughly examining three zones to identify potential areas where Listeria can develop. Zone 1 includes areas where poultry products are in direct contact with the processing equipment, while zones 2 and 3 are considered “non-direct” locations. These areas or pieces of equipment are further away from processing lines, but still pose risks for Listeria growth on surfaces such as drains, floors, pallets, forklifts, conveyor belts and tabletops.
Throughout each zone, employees conduct weekly checks at sampling sites, or niche points, where potential risks for Listeria contamination exist. Although zones 2 and 3 do not involve direct contact with poultry products, performing sanitation tests on these surrounding areas proactively locates bacteria growth on surfaces that can potentially spread to vital processing areas.
Routine equipment examinations also coincide with the company’s general sanitation and environmental monitoring plans. Before new equipment is installed, it is evaluated for its sanitation and maintenance needs. Factors that influence the purchase of equipment include both cleaning ease and whether the facility is equipped to implement effective cleaning procedures for it. Each quarter, all equipment pieces are fully disassembled for “swab tests” on various machine parts. This inspection allows the facility to locate additional Listeria growth areas that may not be identified through the normal sanitation processes.
Enhanced sampling is conducted when the plant is undergoing construction or new equipment is introduced. If positive sample results are found, a thorough investigation occurs, including a total “tear down” of equipment and microbiological sampling prior to intensified cleaning. We like to design our sample plans to find the problems and microorganisms, not to prove that they are not present. Our sampling program is updated at least once a year, and new sample sites are added. Continuous negative sample results could mean that we are not looking hard enough, and if a problem is there, we want to find it!
If there is an occurrence, the investigation is expanded to involve others from various company locations to assist in the investigative process. The expertise of associates throughout our company is invaluable; it really helps to have extra pairs of eyes and a wealth of experience when brainstorming about issues such as the possible location of the organism. In addition, we routinely map our facilities to note any specific areas of concern. Again, sampling and documenting for the sake of doing it will not find the nasty bug. To find and destroy is the name of the game.
All said, the Butterball, LLC food safety program utilizes technologies to reduce the ability of bacteria to grow on the product, and to even be present there in the first place. All further-processing facilities have technologies in place to reduce the potential bacteria on the product’s surface, which is where Listeria is most likely to be. These technologies are applied after the product is already cooked to make doubly certain that the products are safe.
Using a variety of food protection processes, technologies, antimicrobial procedures and, yes, basic hand washing practices, our food safety system provides healthy and safe products for its many consumers. The company’s commitment to food safety will help it continue to succeed in struggle against contamination and remain a strong food safety leader among U.S. poultry producers.
Alice Johnson, DVM, is vice president of food safety, government regulations and public affairs of the Butterball, LLC executive team. She joined Butterball in 2007 and previously worked as the president and chief executive officer of the National Turkey Federation. She has more than 20 years of experience in regulatory issues in the meat processing trade, including positions with the National Food Processors Association, the American Meat Institute and the USDA. She earned a Bachelor of Science in biology from Pfeiffer College and a Doctor of Veterinary Medicine from Tuskegee Institute.