It’s the Law — You Can’t Produce Food in a Dirty Plant

There is an entire page of the federal food code dedicated to what FDA defines as an “adulterated food,” i.e. a food that can make people sick. Most of the sections and subsections deal with additives (or lack of proper additives) to the food itself, but often overlooked is section A subsection 4:

21 U.S.C. 342(a)(4)
§342. Adulterated food
A food shall be deemed to be adulterated
(a) Poisonous, insanitary, etc., ingredients
(4) if it has been prepared, packed, or held under insanitary conditions whereby it may have been contaminated with filth, or whereby it may have been rendered injurious to health.

This means it’s a violation of the Federal Food, Drug, and Cosmetic Act to produce products labeled as food in an environment that is unsanitary and could lead to cross-contamination of food products with pathogens like Listeria monocytogenes. There have been several recalls across different food industries over the past few years that mirror exactly that scenario.

The last bit of bad news is how common some of these pathogens are. E. coli is present in most animal fecal matter, making everything from rodents to birds to livestock a potential point source of contamination. Listerien is also another organism that’s common to the environment. It can survive in the soil and will grow at low temperatures and in relatively low moisture environments. It’s also a prolific Biofilm former which creates an additional set of problems. With how much foot, forklift and other traffic food production facilities have, it may seem like a fool’s errand to isolate and control any organism in the environment.

The good news, however, is that a robust environmental control and monitoring program isn’t impossible; it requires diligence and a multifaceted approach that mirrors the multifaceted nature of environmental pathogen growth. Good data-based swab monitoring programs will help you identify areas where traffic flow patterns or sanitary design issues need correction, and utilizing EPA-registered sanitizers and disinfectants will help you control unwanted pathogenic guests in your facility.

Sterilex creates products for the food industry that are designed to assist in the battle for environmental pathogen control, like the industry-leading PerQuat® line of products. To learn more about our products and how you can implement them into your sanitation and disinfection process, visit