ADVANCEMENT OF THE SCIENCE
GUEST COMMENTARY
A Call for Action to Increase the Scrutiny of Surface Cleaning and Cleaning Agents in Retail Food Establishments
Juan Goncalves, PhD
A ccording to the most recent Food and Drug Administration (FDA, 2022) Retail Food Risk Factor Study, proper cleaning and sanitization of food contact sur- faces in retail establishments remain an unmet need, with up to 60% of delis, fast food, and full-service restaurants failing to comply with the cleaning objectives for food contact sur- faces set forth by the FDA model Food Code . While these results could reflect shortcom- ings with proper chemical sanitizer use, its critical preceding cleaning step (i.e., the eec- tive removal of soils and particles that allow for viruses and bacteria such as norovirus or Salmonella to survive and infect individuals) is likely a significant performance culprit (Todd et al., 2007). Indeed, if tools were available to accurately evaluate proper cleaning of en- crusted grease and food soils beyond a qualita- tive “clean to sight and touch” guideline, the actual incidence of environmental sanitation violations would most certainly increase (Kim et al., 2021). This practice gap is critical, for without a proper cleaning step, visible and invisible food soils that linger on glasses, utensils, dishes, and general food contact surfaces can inhibit or quench quaternary, chlorine, iodine, or lac- tic acid sanitizing chemistries, thus rendering food contact sanitizers ineective (Araújo et al., 2013; Lambert & Johnston, 2001). Further, because foodstu is much less heat conductive than glass, ceramic, or metal surfaces, food soils on contaminated surfaces can also insu- late these surfaces from achieving the proper temperature thresholds required to inactivate bacteria and viruses in applications that lever- age hot sanitization strategies. Accordingly, overlooking the cleaning step can result in a false reassurance of sanitation and heightened risk for foodborne infection transmission. Unfortunately, the regulatory framework described in Chapter 4 of the Food Code appears to lack enough granularity to help
end users and health inspectors evaluate the cleaning process outcomes. “Clean to sight and touch” might meet the need from an intent perspective, but its real-life execution is much more complicated. Invisible soils such as starches and specific proteins can eas- ily be missed on dirty surfaces. Indeed, many soiled surfaces appear to be clean, which has been widely documented in the healthcare industry as a major risk factor for infection control professionals in the struggle to miti- gate transmission of infectious pathogens (Sherlock et al., 2009). Further, touching a surface can reintroduce contaminants onto areas that had previously been cleaned. More importantly, this cleaning success criteria relies on the sensorial perception from food establishment employees and health inspec- tors on if surfaces meet the criteria. Unlike registered sanitizers and disinfec- tants whose public health claims have been judiciously scrutinized by the U.S. Environ- mental Protection Agency (U.S. EPA) to ensure they perform as advertised, cleaning agents and products typically used in retail food establish- ments (i.e., products that are not registered by U.S. EPA or lack public health claims) are not required to undergo performance validation by regulatory agencies. This lack of clean- ing performance oversight by reguatory enti- ties aects the vast majority, if not all, of the cleaning agents and products used in the first compartment of commercial kitchen sinks or in mechanical warewashing machines, among others. As a result, the performance of clean- ing and detergent products against food soils is not assessed by independent entities. So, what options are we left with? Instru- ments that can measure cleanliness on a sur- face do exist, but they are costly; complex to use, calibrate, and maintain; and are primar- ily left for applications in healthcare or food manufacturing. Their main practical focus has in many cases been reduced to training
cleaning sta rather than quantifying soils (i.e., was a target surface left untouched by the cleaning sta?). Further, their relevance and accuracy have sometimes been the sub- ject of scrutiny among the scientific commu- nity (Omidbakhsh et al., 2014). What is more beneficial in this cleaning and detergent product performance vacuum is a combination of the following frame- work we call the four Ps: product, procedure, place, and practice. Product Not everything that foams is a cleaning agent, and not every cleaning agent is good at clean- ing. Commodity cleaning agents and prod- ucts are formulated with limited amounts and types of ingredients that fail to tackle the incredibly large number of soils encountered in a retail food establishment. These com- modity products do not always keep up-to- date with changes in food marketplaces or regulatory trends. For example, moving from animal-based fats and oils to plant-based ones (e.g., canola, soy, corn, coconut, sunflower) to combat the adverse health eects of the for- mer created an unintended cleaning issue. Plant-based oils interact with oxygen and moisture in the air and the heat of the cook- ing process functions to “cure” these oils, hardening them onto the ware surfaces. These hardened oils might not be removed easily with commodity cleaning agents and prod- ucts and could create the need for additional labor or rewash to improve results. Whenever possible, using cleaning agents and products with a demonstrated strong history of supe- rior cleaning performance and innovation is best. Otherwise, user directions for many food contact sanitizers—such as “preclean visible soils”—places the burden on the end user to guess when soils have been visibly cleaned. An important case is the use of single-deter- gent sanitizer or cleaner sanitizer products
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Volume 85 • Number 9
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