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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
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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
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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.
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© 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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