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FOOD SAFETY
SUPPLEMENT

Franois Bourdichon
Food Safety Consultant

Zoning classification in
the food processing area
A food processing area is commonly segregated for technological and hygiene purposes and so the design is meant to
obtain production in the most economically achievable hygienic conditions. The rationale for plant design has been
continuously challenged in recent years by a risk mitigation approach to put all identified hazards under control,
to correct initial design of factories when those hazards were unknown or ignored and to promote hygienic design
in new factories.

Zoning is the distinct division of a facility into process areas with different implemented to prevent pathogen contamination, this is not the sole
hygiene levels. Appropriate zoning of process areas with its barriers and hazard to be considered. Allergen management, pest control and foreign
cleaning procedures is designed to protect products from potential matter management also require a proper zoning approach. Addition-
hazards originating in the factory environment and its surroundings. ally, depending on food product composition, the process, and the
Zoning is an important prerequisite of HACCP plans. The appro- pathogen and spoilers of concern, cleaning practices are also
priate zoning of process areas with its barriers has to be designed to different between food operation factories, even within the same
protect each type of product and its consumers and prevent contamina- factory. A cheese manufacturing site, chilled and wet, with Listeria
tion according to potential hazards as defined by the HACCP study. monocytogenes as a pathogen of concern in the environment does not
But which hazards should be addressed? While zoning is commonly undergo the same sanitation schedule as a confectionary site, which is a

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low moisture food production environment with Salmonella spp. as the  Zone 1: Reception/delivery/storage/processing of packed product in
pathogen of concern. areas with strong contamination risks
At least four criteria can define a spot within a processing site: high  Zone 2: Storage/processing of packed products/secondary
risk zone, soy free, controlled and cleaned, and non-food contact packaging areas, storage of packed raw material/storage of liquids
surface. As for cleaning tools, these must be identified to be compliant in closed systems
with those four criteria as well. Zoning classification is not always simple!  Zone 3: Low moisture foods: Storage/processing of open
semi-finished products and unpacked end products
Zoning in the ISO 22002 Food Safety  Zone 4: Wet products: Open processing of microbiologically
Management System standard sensitive products
Zoning is defined by ISO in the 22002 Part 1 (2009) Standard1 as the
demarcation of an area within an establishment where specific Design and layout
operating, hygiene or other practices may be applied to minimise the Proper hygienic design and layout of premises and rooms are essential
potential for microbiological cross-contamination. The recent version 7 to ensure that entry of hazards (pathogens, spoilers, allergens) into the
of the BRC Standard2, Appendix 2 Guidelines on defining production establishment is controlled (e.g. minimising the potential for entry and,
in the case of entry, preventing the hazard
from becoming established in the environ-
ment through proper design and cleaning
procedures). Physical separation within
the food establishment based on specific
hygiene requirements will help minimise
transfer from one area to another, using
physical barriers, such as walls, doors, split
conveyers, air filters etc.
Alternatively, separation of areas and
control of dust can also be achieved by the
appropriate design of ventilation systems and
airflow. Overhead structures should be
designed to minimise the accumulation of
Figure 1: Proposed air handling and cleaning classification for low moisture food production with highly dust and dry materials, especially when
contaminated material (e.g. almonds, nuts, cocoa, etc.)
they are directly above exposed products.
risk zones, proposes a classification of risk zones within the processing Panels, walls, and floors, should be designed to eliminate hollow areas
and storage facilities, with corresponding levels of hygiene and that could serve as microbial harbourage sites or accumulation of
segregation to reduce the potential for product contamination. allergen residues.
Separation is made between open product areas, enclosed product
areas (e.g. warehouses and storerooms) and non-product areas Principles of air handling to zoning
(e.g. canteens, laundries and offices). More specifically, open product The movement of dust from one area to another should be prevented or
areas are classified as: high risk (chilled and frozen), high care (chilled and minimised using air filters and by maintaining a positive air pressure in
frozen), ambient high care and low risk. the area requiring a more stringent hygiene control relative to the other
While reminding that factory hygiene, finish of buildings, equipment, areas in the establishment (Figure 1). Properly designed air handling
protective clothing and staff hygiene should reflect the potential risks to systems control airborne particulates and odours, minimising the
the product, the proposed decision tree only focuses on pathogen risks to products from airborne contamination by pathogens and
contamination potential, not spoilers or spoilage microorganisms4.
allergens. For example, raw meat intended to be While reminding that factory Irrespective of the air flow rate, care needs
cooked before consumption would be classified hygiene, finish of buildings, equipment, to be taken that the air is moving from high to
in a low risk area, where it is still reasonable to protective clothing and staff hygiene low care areas or from low to higher dust
expect raw meat, to be cooked or not, to be should reflect the potential risks loading areas. Attention should also be given to
hygienically operated to ensure it is not spoiled to the product the location of the air intake for the establish-
before cooking. ment in relation to sources of contamination.
Pathogen management is more complicated and highly related Where air is used in the facility or in processing lines for specific purposes
to the production type and its specific risks. For example, on the proposal such as for cooling or transportation of products, direct contact with the
of the Working Group for Machinery and Equipment in the Confectionery product is possible and the air quality should be appropriate considering
Industry, zoning can be commonly separated, regardless of dry or wet the intended consumer of the finished product produced. Processing
zones in the following scheme3: sites should always aim to work with positive pressure, traditionally
 Zone 0: Reception/storage/processing of open products with strong F5 filtered air in case of open product areas. Three levels of pressure
microbiological contamination at least should be considered:

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 Highest: Processing zone, high care/high


risk. The airflow shall begin from the
highest level of hygiene to lower, i.e. from
open air production zones to pack-
aged goods
 Intermediate: Storage rooms, raw
material, packaging,
finished product
 Slightly above 0Pa: Entry areas
(personal, goods)

It is quite difficult in some cases to give


precise values of what correct pressures
should be but if proper separation between
zones cannot be obtained, no differential of
pressure can be monitored. Airflow only can
be considered for a low moisture food facility
and should be verified regularly that it fits
its purpose.

Cleaning and sanitation procedures


A processing site should not be segre-
gated only by the levels of operational
hygiene expected in different areas, but also
upon different cleaning procedures in place
(Figure 2, uses powdered infant formula
production as an example), as prerequisite
programs for pathogen management, if not
as a CCP for allergen management (cleaning
being the only control measure to lower the Figure 2: Proposed zoning for powdered infant food formula. Adapted from Mullane et al. (2007) Int. J. Food
Microbiol. 116: 73-81.
risk). The type of cleaning practices to be used
in different hygiene areas should be decided upon the hazard analysis sometimes used to flush the interior of equipment used to handle high
to mitigate pathogen contamination. viscosity, low moisture products such as peanut butter or chocolate, but
For low moisture foods like powder, a safe environment is not it cannot be considered as a sanitation step. Separate tools should be
necessarily a clean one, as for high moisture food facilities. In that provided for the dry cleaning of floors. Tools and vacuums that are used
specific case, water is the enemy, as it can revive microorganisms present for cleaning food contact surfaces should not be used to clean non-food
in ingredients. If not correctly done, cleaning procedures can be contact surfaces. Dry cleaning tools should be cleanable, durable,
counterproductive and enhance risk. without loose parts, designed for purpose, dedicated to the area, and
Codex Alimentarius suggests following the definitions for cleaning stored in a dedicated place.
procedures based on the amount of water used vs the considered Portable vacuum cleaners are recommended to remove non-fat and
microbiological hazards: non-viscous residues and should be dedicated to specific areas, to be
 Wet cleaning: The removal of soil, including food residues, dirt, tested as part of an environmental monitoring program. Cleaners should
grease or other objectionable matter using water and detergents be well maintained so they do not become carriers of contamination
 Controlled wet cleaning: The removal of soil, including food with their filters properly maintained on a regular basis. While water
residues, dirt, grease or other objectionable matter using a limited should be avoided as much as possible, alcohol-based disinfectants
amount of water provide a means to disinfect equipment. Compressed air can also be
 Dry cleaning: The removal of soil, including food residues, dirt, used for dry cleaning in special situations (e.g. to dislodge dust from
grease or other objectionable matter by actions such as sweeping, inaccessible points). It then should be dried and filtered to exclude
brushing, scraping, or vacuuming the residues from equip- microorganisms and moisture prior to use.
ment surfaces and the food establishment environment without Controlled wet cleaning procedures should be used when residues
the use of water cannot be further removed by dry cleaning. Only the minimum amount
of water should be used, with specific procedures to collect water to
The objective of dry cleaning is to remove residues without the use of prevent it spreading to other non-wet cleaned areas. As such, water
water by using tools or cleaning aids that do not involve the application aerosols and high pressure water systems should not be used. Where
of water or other aqueous solutions, e.g. dry abrasives. Hot oil is possible, parts of equipment should be removed and wet cleaning

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conducted in a dedicated room. Complete and active drying of all areas  Zone 4: Non-food contact surfaces, Environment E3: Surfaces
and components involved should be done after controlled wet cleaning. remote from product contact surfaces outside the processing room
When the product by itself has a high range of moisture, and when but which could impact processing areas through the movement of
the production environment must be considered wet, then wet cleaning people, equipment or materials
does apply. Water use should yet be minimised and isolated to specific
areas wherever possible and complete drying of all areas should be done Depending of the ecology of the factory and the target consumer,
after wet cleaning. the microbial hazard of concern can be either Listeria monocytogenes in
wet and/or chilled production sites, Salmonella
Monitoring effectiveness in the environment of low moisture food
Food processing establishments should put in Food processing establishments plants, Cronobacter spp. in infant food plants.
place an environmental monitoring program to should put in place an environmental Indicators can also be monitored, i.e. germs
verify the effective implementation of zoning monitoring program to verify the showing similar ecological characteristics.
to maintain production in a hygienic environ- effective implementation of zoning Enterobacteriaceae show similar resistance
ment. Environmental monitoring allows to maintain production in a to drying as Salmonella spp. and are more
hygienic environment
undertaking corrective actions in a timely common in processing facilities. Consequently,
manner. The purpose of the monitoring the monitoring of Enterobacteriaceae as
program is to find where target organisms are present in the well as Salmonella in the environment may provide an early
environment. Decision criteria and their rationale should be articulated indication that the conditions necessary for Salmonella colonisation
prior to the establishment of the program, from no action (no risk of may exist, and hence provide an earlier indication of potential
contamination), to intensified cleaning, to
source tracing (increased environmental
testing), to review of hygienic practices,
holding and testing of product, up to product
Frankfurt am Main 15 19 June 2015
disposition. Cleaning procedures should also
be monitored (e.g. ATP bioluminescence
where applicable or visual observation) and
verified (swabbing for enterobacteriaceae
and allergen residues). Cleaning verification is
not environmental monitoring.
While it is reasonably expected to find
positive results out of the swabbing, since
microorganisms are ubiquitous in the environ-
ment, one has to be able to differentiate the
degree of concern depending on the location.
Two approaches are currently proposed in
the different guidelines, from the Codex
Alimentarius, Health Agencies or professional
syndicates5-7. The separation is made between
food contact surfaces (FCS) and non-food
contact surfaces (nFCS). Since the early 2000s,
a US driven approach suggests four zones for
Meeting Point of
an environment program (confusingly, the Industrial Biotechnology
term zone is used to describe environments
as well as areas of hygienic segregation):
 Zone 1: Food contact surfaces Surfaces
in the plant that are in direct product
contact after the lethality or microbial
reduction step
 Zone 2: Non-food contact surfaces, Environ-
ment E1: Surfaces in the plant closely
adjacent to product contact surfaces
Be informed.
 Zone 3: Non-food contact surfaces,
Environment E2: Surfaces in open post-
Be inspired.
lethality product processing areas, but not
closely adjacent to FCS Be there.
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problems 8,9. The same approach is valid for Listeria spp. as an


indicator for the pathogenic species Listeria monocytogenes. Entero-
bacteriaceae are not good indicators for Listeria, but are classically
monitored in high moisture food facilities for the spoilage and hygiene
issues their presence could cause.
Preferential locations for sampling should focus on areas where
harbourage or entry leading to contamination is likely to occur. Sampling
locations should be reviewed on a regular basis and additional ones may
need to be included in the program, depending on special situations
such as major maintenance or construction activities or where there is
observed indication of poor hygiene. The frequency of the environmental
monitoring program should be adjusted according to the findings and
their significance in terms of risk of contamination. In particular, the
detection of pathogens in the finished product should lead to increased
environmental and investigational sampling to identify the
contamination sources. The frequency should also be increased in
situations where an increased risk of contamination can be expected,
Drainage management e.g. in case of maintenance or construction activities.
for the Food & Beverage industry
Conclusion Food for thought
While the cleaning procedures and environmental monitoring detailed in
the present article mostly refer to microbial hazard management for
pathogens and spoilers, the approach is similarly valid for allergen
management. While segregating a factory for production purposes, one
must consider not only the ecology of the finished products and raw
materials, but also the ecology of the factory itself, and the consumer
target, either for the stringency expected or specific hazard.
The control measures in place should be properly validated
to be fit for purpose, monitored to ensure hygienic and safe production,
verified for compliance and regularly reviewed. Zoning might be
understood as basic and easy to achieve, yet proper care should
be taken to avoid recurrent issues from flawed design or in case of
change of production.

About the Author


Franois Bourdichon is a Food Safety and Hygiene Consultant
with 15 years of experience in the food, dairy, infant nutrition
and confectionary industries. His work focuses on
prerequisites, which are often the forgotten part of the Food
Safety Management System. Without these strong bases
properly implemented, the whole approach cannot be as
efficient or resilient as possible. He can be contacted at:
francois.bourdichon@gmail.com.
Providing the range of drainage products
that incorporates the latest EHEDG design
principles, we are committed to delivering the References
ultimate in hygienic performance and to putting 1. ISO/TS 22002-1:2009. Prerequisite programmes on food safety. Food Manufacturing.
HygieneFirst. 2. BRC Global Standard for Food Safety Version 7 (2015). Available at:
http://www.brcglobalstandards.com/.
Our commitment encompasses every aspect of the drainage process from 3. Working Group for Machinery and Equipment in the Confectionery Industry.
initial design and installation to cleaning and maintenance. Its a philosophy Recommendations for Air-Conditioning in Production and Storage Areas in the Confectionery
Industry (04/2002).
we call HygieneFirst and its why our drainage systems maximise
durability and minimise operational costs while preventing the hygienic 4. EHEDG. Guidelines on air handling in the food industry. EHEDG Update / Trends in Food
Science & Technology 17 (2006) 331336.
issues that could put your facility at risk.
5. Almond Board of California (2010). Pathogen Environmental Monitoring Program (PEM).

www.aco-foodprocessingdrainage.com 6. Health Canada (2011). Policy on Listeria in ready to eat foods.


7. United Fresh Produce Association (2013). Guidance on Environmental Monitoring and Control
of Listeria for the Fresh Produce Industry.
8. GMA (2009). Control of Salmonella in Low Moisture Foods, pp 1-81.
9. GMA (2010). Industry handbook for safe processing of nuts.

New Food, Volume 18, Issue 1, 2015