food manufacturers even reach that step,
they must remove large debris, soils and the
like. The same general guidelines apply here,
too. Make it easy to reach and clean all parts
of machines. Equipment should disassemble
easily, and any parts that could trap dust and
debris should be minimized or eliminated.
Beyond hot water cleaning, the FDA has
a long list of chemicals approved to sanitize
equipment. These chemicals include iodine,
calcium hypochlorite, ammonium chloride,
ethyl alcohol, isopropyl alcohol and sodium
dichloroisocyanurate. Equipment should
withstand repeated use of these chemicals.
Milk handling operations cannot use certain
chemicals, including trichloromelamine and
either sodium lauryl sulfate or dodecyl-benzene sulfonic acid, but other operations
you serve may use them, which is something
else to keep in mind. Remember that organic
and non-GMO labels may wish to use other
cleaning chemicals, and have to balance this
with FSMA regulations. When working with
a particular industry, be sure to know these
requirements. What you are doing as an OEM
should line up with FSMA requirements and
your customers’ operations to best suit their
needs. Drying time is another concern. Once
the equipment is clean, how quickly can it
get back up and running? If it takes hours to
dry and is out of operation, that is valuable
production time wasted.
Focus on Fruit and
Fruit and vegetable companies are likely
to require the most investment in new
equipment, and should be an area of focus
for OEMs in equipment design. The FSMA
applies new standards to the harvesting,
handling and processing of produce. OEMs
should keep this in mind when designing
equipment for this subset of the industry.
One important development in fruit and
vegetable processing is the introduction of
new rules governing water quality standards.
These regulations mandate no detectable
generic E. coli in water that could end up
on produce. This includes water for hand
washing during and after harvesting, water
used to wash surfaces that touch food and
water used to irrigate sprouts. Water directly
applied to produce other than sprouts can
have a geometric mean of 126 or less
colony-forming units (CFU) of generic E.
coli per 100 mL of water. Additionally, the
statistical threshold is 410 or less CFU of
generic E. coli per 100 mL of water.
All of these new regulations mean more
testing, which means demand for testing
equipment, but also possible production
delays. Water purification equipment
purchases may also rise if manufacturers
find their water supply does not meet
requirements with their current setups.
Sprouts are especially under tight restrictions,
because they have been linked to many
historical instances of food poisoning.
Equipment should reduce contaminants
through enhanced filters and metal detectors.
Because the FSMA changes food safety from
reactive to proactive, thorough data collection
should capture information from critical
control points and from the preventative
controls the FDA has outlined, while also
keeping track of performance. This would
allow companies to have both the adequate
records required by law and analysis that
highlights inefficiencies in production. If an
OEM’s equipment’s data shows where certain
parts of production can be improved, while
maintaining regulatory compliance, it is likely
to be popular in the market.
The FSMA is based on detailed analysis
and one of the notable areas in which OEMs
can excel is offering scientific proof that
their products meet marketing claims. This
includes scientific data on bacteria control
and sanitation. For example, OEMs can
provide data to show how long bacteria can
survive on their product surfaces. Providing
ways to keep records and track tests is
another method in which OEMs can not only
offer equipment that allows companies to
meet FSMA requirements, but also provide a
Because the FSMA is heavily data driven,
communication between various pieces
of equipment, shop computers and office
computers should be easy and seamless.
That way, all employees — from operators
to the CEO — are aware of the details of
operations. An OEM that offers a way to
manage all of the two years’ worth of data
the FSMA mandates, which often currently
lies in spreadsheets, word documents or
in physical filing cabinets, would have an
immense advantage in the marketplace.
Larger companies look for many different
diagnostic and record-keeping tools.
They want critical control points, food
processing, sanitation, packaging, downtime
and performance, and FSMA operational
documentation to be easily captured, viewed
and used across a single interface. Downtime
is of particular importance, as it cuts into
revenue. Providing short training videos
allows OEMs to answer concerns about
worker safety and preparedness.
Working With Foreign Food
Foreign and imported food regulations
introduced by the FSMA mean that
companies involved with using imported food
as a part of their production processes face
a new set of challenges. This is especially
true for small specialty manufacturers.
The FDA outlines that it will work with
foreign governments whenever it deems
their standards meet or exceed FSMA
requirements. Still, the overhead costs of
sending inspectors to different countries to
make sure processes and equipment are
compliant is significant, and while larger
enterprises can often afford this expense,
smaller ones may not be able to. As such,
OEMs that are international can offer a
competitive advantage if the equipment they
sell meets certified global standards that
match FSMA requirements.
What Everyone Has in Mind
OEMs and food manufacturers need
to remember the FSMA is proactive, not
reactive. The processes, practices and
equipment that ensures food contamination
does not happen, and that the food supply is
safe from farm to table, requires coordination
and communication at every step. OEMs can
provide a key resource through sanitation-focused products, interconnected data-driven
processes and consultations.
The food industry is subject to inspections
at least every three years instead of 10,
along with inspections based on reasonable
suspicion and random testing. In addition, the
FDA can call for food recalls under the FSMA,
something brands consider when purchasing
or upgrading equipment. Forecasting the
convergence of productivity and compliance
will enable equipment manufacturers to
deliver highly marketable products that
future-proof brands against regulations and
improve their bottom lines.