Guidelines to validate control of cross-contamination during washing of fresh-cut leafy vegetables

Authors: GOMBAS, DAVID - United Fresh Produce Association; Luo, Yaguang - Sunny; BRENNAN, JIM - Smartwash Solutions; SHERGILL, GURJIT - Taylor Farms; PETRAN, RUTH - Ecolab, Inc; WALSH, RICHARD - Ecolab, Inc; HAU, H - Ecolab, Inc; KHURANA, K - Pulse Instruments; ZOMORODI, BRIAN - Apio, Inc; ROSEN, JOAN - Jc Rosen Resources; VARLEY, RICHARD - Kivar Chemical Technologies; DENG, KAIPING - Illinois Institute Of Technology

Submitted to: Journal of Food Protection
Publication Type: Peer Reviewed Journal
Publication Acceptance Date: 10/25/2016
Publication Date: 1/24/2017
Citation: Gombas, D., Luo, Y., Brennan, J., Shergill, G., Petran, R., Walsh, R., Hau, H., Khurana, K., Zomorodi, B., Rosen, J., Varley, R., Deng, K. 2017. Guidelines to validate control of cross-contamination during washing of fresh-cut leafy vegetables. Journal of Food Protection. 80(2):312-330.

Interpretive Summary: Food safety regulations require processors to identify food safety risks, develop preventive controls, and validate the effectiveness of the controls. While the industry has taken large strides to prepare for the implementation of food safety regulations, critical data gaps significantly hinder food safety progress. One particular challenge is the determination of minimal and sufficient anti-microbial concentrations to prevent pathogen cross-contamination during produce washing operation. Therefore, in this article, the authors (comprising technical specialists from government research institutes, academia, and industry) examined the various factors and considerations for determining the effectiveness of antimicrobial washes, with an emphasis on developing practical guidelines for validation. It is anticipated that the guidelines provided will help the industry in developing science- and risk-based food safety practices to reduce pathogen contamination and spread.

Technical Abstract: The U.S. Food and Drug Administration requires food processors to implement and validate processes that will result in significantly minimizing or preventing the occurrence of hazards that are likely to occur in food production. During production of fresh-cut leafy vegetables, microbial contamination that may be present on the product can spread throughout the production batch when the product is washed, thus increasing the risk of illnesses. The use of antimicrobials in the wash water is a critical step in preventing such water-mediated cross-contamination; however, many factors can affect antimicrobial efficacy in the production of fresh-cut leafy vegetables, and the procedures for validating this key preventive control have not been articulated. Producers may consider three options for validating antimicrobial washing as a preventive control for cross-contamination. Option 1 involves the use of a surrogate for the microbial hazard, and the demonstration that cross-contamination is prevented by the antimicrobial wash. Option 2 involves the use of antimicrobial sensors and the demonstration that a critical antimicrobial level is maintained during worst case operating conditions. Option 3 validates the placement of the sensors in the processing equipment with the demonstration that a critical antimicrobial level is maintained at all locations, regardless of operating conditions. These validation options developed for fresh-cut leafy vegetables may serve as examples for validating processes that prevent cross-contamination during washing of other fresh produce commodities.