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Verifying Your Apparel Program As A Preventive Control

This white paper discusses

the impact your apparel

provider can have on your

food safety program and

how to help ensure that

impact enhances your

food safety efforts and

positively affects auditor

and regulatory inspections.

It first addresses the

Management of Pathogens that Play a Role in Foodborne Illness and Recalls, then discusses its

application in Managing Your Supply Chain as a Preventive Control, focused

primarily on the evaluation

and verification of the

apparel provider, and why

that is of benefit to your

customer and your brand.

MANAGING PATHOGENS THAT PLAY A ROLE IN FOODBORNE ILLNESS & RECALLS

The Origination and Spread of PathogensEACH YEAR, THERE ARE THOUSANDS of food and beverage product recalls. In the

U.S. alone, foodborne illnesses cause more than 48 million people to get sick and

nearly 3,000 to die.1 These illness-causing pathogens, such as Escherichia coli (E. coli), Salmonella enterica, and Listeria monocytogenes can enter your plant from a vast array

of sources – from incoming supplies to the clothing of your own personnel.

Such contamination is not new; in fact, a heart-rending example of the viability

of these pathogens can be taken from the highly published fast-food chain E. coli outbreak of 1993 in which one of the deaths was a baby who became ill, not by

consuming the contaminated hamburger himself, but by putting a toy into his mouth

which a child who had eaten the contaminated burger had touched. This along with

incidents of emerging pathogenic outbreaks, such as Salmonella on cantaloupe and E. coli in flour, and norovirus from a worker’s hands or garments show that contamination

can come from many and unexpected sources but be just as serious and harmful no

matter the origination.

It is for this reason that it is important for you to consider including every supplier

that can impact food safety in your supplier management program, not just those

whose goods are directly integrated into or contact your food products, such as



ingredients and packaging, but also

those who provide items or services

that may seem to be less directly

related to the food itself, such as

apparel providers.

Although a worker’s uniform

shirt, pants, or lab coat may not be

expected to directly contact the food,

a garment that has not been properly

cleaned, disinfected, or stored could

bring pathogens or other bacteria

into the processing area. And once a

foodborne pathogen gets into your

plant, it can spread to food-contact

surfaces and products themselves,

potentially putting your consumer

and your brand at risk.

It also is for this reason that the

new Food Safety Modernization

Act (FSMA) includes rules on the

establishment and monitoring of

a supplier verification program.

The purpose of the supply chain

requirement is to verify that any

hazard, that could affect the safety

of a food, is being controlled at some

point in the chain. These supply-chain

controls must be a part of the written

food safety plan of each covered

food facility, and the more that is

controlled upstream the less chance

there is of contamination making its

way to the consumer.

Listeria monocytogenes contamination can cause Listeriosis in the person consuming the food. This infection primarily affects older adults, pregnant women, newborns, and those with weakened immune systems. However, anyone can be affected. The usual symptoms are fever and muscle aches, sometimes preceded by diarrhea or other gastrointestinal symptoms.

Salmonella is estimated to cause one million foodborne illnesses in the U.S. each year, including 19,000 hospitalizations and 380 deaths.2 Most persons infected with Salmonella develop diarrhea, fever, and abdominal cramps 12 to 72 hours after infection. The illness usually lasts four to seven days, with most people recovering without treatment. However, it can become severe enough

to require hospitalization or cause death.

Escherichia coli (E. coli) bacteria are not all bad; most are a natural and important part of the human intestinal tract. But there are six types of pathogenic E. coli, normally transmitted through contaminated food or water, or contact with an infected item, animal, or person. A person infected with pathogenic E. coli will generally have severe stomach cramps, diarrhea (often bloody), and vomiting, but usually recovers within a week. While some infections are mild, others can be severe or life-threatening.

Source: CDC

3 Deadly Pathogens

MANAGING YOUR SUPPLY CHAIN AS A PREVENTIVE CONTROL

Why Apparel Providers Should Be Included in Supplier Verification

MOST DESCRIPTIONS of the food

industry supply chain focus on phrases

such as “farm to table,” “farm to fork,”

or even “stable to table.” As a result,

the supply chain is often considered to

be only that of the ingredients that go

into the food.

While the safety and quality of

those supplies and suppliers is

certainly critical to the safety of

the final product on the consumer’s

table, there are a number of supplies

that don’t originate at the farm

or stable but can be just as

important in the safety of the final

product. Even food manufacturers

who extend their supply-chain

programs to food-contact supplies,

such as packaging and equipment,

don’t always take it any further. But

there are other sources by which

your product can be contaminated if

not held to documented safety and

quality standards before they reach

your plant.

When discussing garments, for

example, although you require that

your employees wear clean uniforms

1 Burden of Foodborne Illness: Findings, Centers for Disease Control and Prevention (CDC), 2016. http://www.cdc.gov/foodborneburden/2011-foodborne-estimates.html

2 Salmonella, CDC, 2016. https://www.cdc.gov/salmonella




Delivery & Sorting

Disinfection

Steam to 260F

or lab coats each time they enter a

processing area, do you know the

process by which your supplier washed

those garments? Were they disinfected

as well? What food-safety standards

are upheld in the facility in which the

garments are sorted, cleaned, and

stored – prior to delivery to your plant?

While FSMA focuses primarily on

ingredients and raw materials in its

requirements for supplier verification,

its mandate that “a manufacturing/

processing facility have a risk-based

supply chain program for raw material

and other ingredients for which it has

identified a hazard requiring a supply-

chain applied control” can be just as

applicable to virtually any supplier who

provides items that will be brought

into the processing area or used in

the vicinity of raw or unpackaged

food. If even the potential of a hazard

exists, shouldn’t it be identified and

controlled?

Such consideration is further

advanced by the FSMA Preventive

Controls rule’s oft-cited statements of

employee hygiene as a key factor in

food safety. In fact, the rule requires

that this be included in the hazard

analysis and evaluation of the written

food safety plan, stating: “A facility

subject to the rule must conduct a

hazard analysis to identify and evalu-

ate known or reasonably foreseeable

hazards for each type hazard for each

type of food manufactured, processed,

packed, or held at the facility to deter-

mine whether there are any hazards

requiring preventive controls.”

CONSIDERATIONS FOR EVALUATING AND VERIFYING APPAREL PROVIDERS

WITH FACILITIES REQUIRED to include

their written supply-chain management

program as part of the food safety

plan, it simply makes sense to integrate

the two, applying the in-house apparel/

hygiene program to apparel providers

as well.

Thus, a food facility should seek to

work with providers whose operations

implement food-safety systems based

on recognized practices in sanitation

and contamination elimination. Such a

system could include:

• Apparel design that minimizes

the potential of foreign-object

contamination, such as snap-front

shirts and wrap-around gowns that

tie so there are no buttons that

could fall off into food.

• Color options to help prevent

cross contamination in the plant

through color specification by area

and easy identification of employ-

ees in high-risk zones.

• Proper wash loads, temperatures,

and controls to disinfect with an

EPA-registered laundry disinfec-

tant that can kill key pathogens

including Listeria monocytogenes, Escherichia coli 0157:H7, and Sal-monella enterica in the wash cycle.

• Documentation that can be in-

cluded in the facility’s food safety

plan for supplier verification, and

shared with third-party auditors to

help demonstrate compliance and

attain certification for protective

apparel/laundry requirements.

• Separate storage of clean/soiled

FDA goes on to specifically state

that one of the written hazard evalu-

ations that must be considered is the

effect of “sanitation, including em-

ployee hygiene,” on the safety of the

finished food. And employee apparel

is specifically noted in the Current

Good Manufacturing Practices (cGMPs)

which FSMA has transformed from

guidance to regulation. Title 21, Part

110.10 requires that workers wear outer

garments suitable to the operation

in a manner that protects against the

contamination of food, food-contact

surfaces, and food-packaging materials.

If the garments coming into your

plant are not sanitary, you could be out

of compliance with the mandate from

the start.

For complete FSMA rules, visit fda.gov.

Soiled Garment Pickup

A BEST PRACTICESAPPAREL SUPPLY

PROGRAM

Clean Garment Delivery

Inspection & Covers

garments – both within the laun-

dry plant and throughout trans-

portation – to meet segregation

best practices and help prevent

cross contamination.

• Identification of preventive con-

trols and/or critical control points

(CCPs) in the process to address

cross-contamination sanitation

concerns or help ensure potential

hazards are controlled.

• Third-party auditing, while not

necessarily a “must have,” can

provide additional assurance that

the supplier is focused on food

safety and ready to demonstrate

its compliance activities.




© 2016 Aramark. All rights reserved.

PROTECTING YOUR CUSTOMER AND YOUR BRAND

A Trusted Partner in Food and Uniforms

Aramark is in the customer service

business across food, facilities and

uniforms, wherever people work, learn,

recover, and play. United by a passion to

serve, our more than 270,000 employ-

ees deliver experiences that enrich and

nourish the lives of millions of people

in 21 countries around the world every

day. As a leading provider of uniform

services, thousands of food processors

across the country rely on our uniform

rental services to enhance their food

safety efforts. Our food industry apparel

is designed to help reduce the risk of

product contamination and our wide

selection allows customers to choose

the garments that are most appropriate

for their processes and facilities.

Advancing Clean to Improve Food Safety

In anticipation of the growing demand for

documentation from food manufacturers, we

developed a HACCP plan for uniforms laundered

for food plants. VeriTEX QCTM is our HACCP-based, third-party audited

laundry and delivery process. This closely monitored process helps prevent

cross-contamination from the moment our Route Sales Representatives

pick up soiled uniforms to the time they drop off clean employee apparel.

We recently elevated our wash formula used to launder our primary food

processing garments to an EPA-registered laundry disinfectant that achieves

a complete kill of certain organisms during the wash cycle, including Listeria monocytogenes, Escherichia coli 0157:H7 and Salmonella enterica.3 Using an

EPA-registered laundry disinfectant is just one of the quality control steps we

have in place to help ensure food processing employees have clean uniforms

to wear every day.

If you are interested in discovering how VeriTEX QCTM can help enhance your

food safety efforts, reach out to us today.

800-ARAMARKaramarkuniform.com/foodprocessing

ABOUT ARAMARK

3 The formulation meets EPA requirements for laundry disinfection (complete kill in 9 out of 9 carriers with a 6-log or greater organisms per carrier kill rate) for the following organisms during the wash cycle: Acinetobacter baumannii, Escherichia coli 0157:H7, Klebsiella pneumoniae, Listeria monocytogenes, Methicil-lin-resistant Staphylococcus aureus (MRSA), Pseudomonas aeruginosa, Salmonella enterica and Staphylococcus aureus. This formulation and VeriTEX QCTM only apply to select items and are only provided to customers of Aramark Uniform Services who require and request their products be processed as part of our HACCP process.

While you can’t, of course, be onsite

at every supplier’s facility while

they are working with the items and

products that will be brought into

your plant, you can set standards

and specifications for each supplier

– from food to frock – to help assure

that the food safety standards you

set for your plant are begun well

upstream in the supply chain.

Escherichia coli (E. coli), Salmonel-la enterica, and Listeria monocyto-genes can be brought into your plant

in a multitude of ways, and with

these pathogens, as is so often the

case in food safety, the best offense

is a good defense, i.e., implementing

policies to help prevent contamina-

tion from being brought in, rather

than having to react – recalling and

discarding product – to a contami-

nant after it arrives at your plant.

approach that identifies and address-

es CCPs and preventive controls

will enhance the preventive controls

efforts within your plant to help keep

your operations safer, positively

impact results of audits and inspec-

tions, and protect your customers

and your brand.

Thus, you should consider

including every supplier that

can potentially impact food

safety in your supplier man-

agement program – not just

those who provide ingredi-

ents or packaging, but also

those who provide nonfood

products and services.

While FSMA’s supplier ver-

ification requirements do not

specifically call out apparel

supplies, it does provide a

basis for the evaluation of all

relevant suppliers to extend your own

preventive controls upstream. Incor-

porating the applicable provisions of

that rule along with the evaluation and

verification of your apparel provider

against recognized practices (such

as those listed in this document) and

ensuring they implement a systems

This white paper provides summary information and should not be used in place of reviewing applicable laws, rules, regulations and/or safety standards. Each business is unique and ultimately needs to determine the safety processes and procedures applicable to its operations and workforce.

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