Volume 8, Number 3, Winter 1997
Topic for this issue: SAFETY
"
Mega-reg" puts greater emphasis on microbial monitoring and reduction
Pursuing more rapid microbial detection
"Poultry Plus" begins field trials
Poultry process safety management compliance guide now available
Other PSM resources
"Mega-reg" puts greater emphasis on microbial monitoring and reduction
A key element of the new "mega-reg" for the poultry industry is
its mandated microbial monitoring program. Plants have an opportunity to
use microbial testing to go beyond the mandates of the regulation, possibly
employing innovated rapid detection technologies and using test results
to initiate more proactive controls. But before they do that, they need
to gain a better understanding of what is both possible and practical.
As the new Food Safety and Inspection Service's (FSIS) Pathogen Reduction/Hazard
Analysis Critical Control Point regulation for the meat and poultry industries
(or the so-called "mega-reg") takes effect, many poultry processors
are increasingly anxious about its potential impact on their operations.
The overall goal of the new regulation is to reduce the incidence of unwanted
pathogens on product using scientific methods. The four key provisions of
the regulation are establishment of:
sanitation standard operating procedures (SOPs);
a Hazard Analysis Critical Control Point (HACCP) program;
E. coli testing;
Salmonella testing and product performance limits. Few argue with the goal of the new regulation, but many are concerned with
the growing emphasis on microbial performance standards. Many processors
feel that the microbial performance provisions are cumbersome and will end
up costing consumers more than necessary for the products they buy. Others
are concerned about how microbial test data may be used and question where
FSIS is headed next. Setting these fears aside, the industry must face the
fact that microbial monitoring for E. coli and Salmonella is now required.
A key challenge before them is whether they will be able to use these test
results to improve pathogen controls in their operations.
Mandated testing
A key element of the new regulation is the mandated microbial monitoring
program. FSIS plans to use information from these tests to help evaluate
the effectiveness of a plant's sanitation SOPs and HACCP program. The agency
also is committed to lowering overall pathogen occurrence and will likely
use performance standards to achieve this result. The two mandated testing
programs are for E. coli and Salmonella.
E. coli is commonly found in the intestinal tracts of animals, and its
presence on poultry is an indicator of fecal contamination. Plants will
take their own samples and use their own labs for E. coli testing beginning
January 27, 1997. At this point, FSIS only requires that plants begin testing.
In July 1997, FSIS will begin reviewing the E. coli test results to determine
if testing is useful in implementing controllable changes to the slaughter
process.
Salmonella is a common contaminant of processed products. But unlike
the testing for E. coli, FSIS will perform the assays for Salmonella and
will begin testing immediately to determine how each plant is doing. Based
on the tests' results, FSIS will hold a conference to determine if the standards
should be changed. Actual enforcement won't begin until January 1998.
At least 90 percent of the poultry industry will have satisfactory test
results, predicts Dr. Mike Doyle, director of the University of Georgia's
Center for Food Safety and Quality Enhancement. However, those plants with
too many positive test results after three sets of samples are collected
will face FSIS enforcement action, although the type of action FSIS will
take has yet to be determined.
Effective monitoring systems
In addition to performing compliance tests, plants have an opportunity
to use microbial testing to identify long-term trends and correlations between
alternative control actions and pathogen occurrence. Since plants are only
responsible for performing the E. coli test, they will have to determine
if they want to conduct their own Salmonella tests as well. "This unfortunately
could become a catch-22 situation," notes Doyle. "For if a plant
does conduct its own Salmonella testing, it may be subjected to sharing
the results with FSIS, which many plants may be reluctant to do."
Assuming plants do decide to aggressively pursue process microbial monitoring,
they will have a number of options for screening techniques. In addition
to the standardized culturing techniques that will be used for the mandated
testing, plants also have an opportunity to investigate some of the emerging
rapid detection techniques. These technologies employ an array of detection
principles and can give results in hours versus days. If test results are
generated in a more timely fashion, plants may have an opportunity to implement
more dynamic techniques to control elevated microbial levels in a more cost-effective
manner. For example, many plants are already using bioluminescence to track
the effectiveness of sanitation programs. This technique allows plants to
get an almost immediate result on microbial loads that indicate the effectiveness
of sanitation steps taken. This eliminates potential disruptions and costs
if poor sanitation is later discovered by more traditional testing means.
Some researchers are also working on innovative tools that could possibly
provide a similar break-through for more continuous on-line process monitoring.
Proactive control schemes
Since poultry processors have control over many aspects of their supply
and distribution chain, they are in a good position to implement controls
that could impact overall pathogen loads.
To be effective, plants need to focus on pathogen sources and try to
isolate the causes. "This means going all the way back to the farm," Doyle
says. If it turns out that growout management procedures can increase pathogen
risk, companies may have to implement better controls over contract growers
to ensure more consistent performance, says Craig Wyvill, director of Georgia
Tech's Agricultural Technology Research Program. Some argue that reducing
the microbial loads at this stage doesn't matter because when the product
gets to the plant, everything is mixed together and can cross-contaminate.
But Doyle argues that if lower populations and lower incidence of pathogens
occur at the onset, the likelihood is that there will be less to spread
around.
Ultimately plants would like to be able to isolate products with unacceptably
high pathogen loads and apply end-product treatment to destroy the pathogens.
At the moment, plants only have a choice of applying blanket treatment
(such as chemical additives or irradiation) to all product or performing
no treatment at all. If rapid detection techniques, like the biosensor do
achieve sufficiently fast response capabilities, it may be possible one
day to isolate groups of product in-process for specialized treatment, notes
Wyvill. Such treatment might be as simple as diverting that product group
to cooking operations.
Outlook for the future
In the short term, most processors can be expected to take only those
steps necessary to comply with the new regulation. In the long term, however,
the industry and the research community need to focus on the next steps.
Should the emphasis be on controls, better monitoring, or a better under-standing
of cause-and-effect relationships? "The answer may well be all three," says
Wyvill, "but we will have to see what begins to emerge as overall implementation
of the 'mega-reg' lets us learn more about what is both possible and practical."
Pursuing more rapid microbial detection
From a practical standpoint, laboratory tests are time consuming, frequently
taking anywhere from 24 to 48 hours to complete. Reporting requirements
do not pressure plants to compress time schedules, and, in fact, plants
have little choice in testing methodology. But if plants want to use test
results to adjust their control program, then a more rapid test would
be better.
Researchers at Georgia Tech are continuing to make exciting progress
in their efforts to develop a low-cost, rapid-response microbial biosensor
for detecting microbial quality. Their efforts remain concentrated on an
innovative detection technology called "integrated optics," a
photonic version of the integrated circuit. One of their application goals
is to develop a true microbial sensor that can be employed on the processing
plant floor or in the field to deliver a more dynamic microbial screening
tool.
The integrated optics biosensor incorporates laser diode technology,
a planar waveguide design, and advanced immunoassay chemistry that are applied
to the waveguide surface. Using the patented concept of optical interferometry,
the sensor directly detects binding of molecules to its specially designed
waveguide surface. The sensor detects microorganisms from minute changes
in the speed of the laser beam as it passes through regions of the waveguide
whose optical properties have changed with molecular binding.
Because the design measures direct molecular binding, it is proving to
be more dynamic and sensitive than current colormetric or fluorescing-based
rapid detection techniques.
Recent accomplishments
In the past year, the research team has reported:
The biosensor has achieved a 10-fold im-provement in sensitivity. The
current prototype can now detect as few as 1,000 cells per milliliter, and
projections show it capable of detecting down to 100 cells per milliliter,
thanks largely to surface chemistry improvements, better assay designs,
and active detection advances.
The biosensor has proven it can accurately measure the binding of whole
cells to the biosensor surface. The whole cell method is not a common approach
in many con ventional ELISA protocols and brings with it the elimination
of some time- consuming sample preparation steps, making its per formance
more dynamic.
The biosensor is proving to be very economical. Current projections estimate
a full system cost to be in the range of a few hundred dollars to less than
$5,000. Cost per test should be competitive with if not cheaper than conventional
ELISA kits.
The biosensor surface can be regenerated for reuse. The prototype has
been reused five times in preliminary tests with little sensitivity degradation
and has the potential to be reused hundreds of times.
The biosensor's structure is designed to perform accurately and reliably
in harsh environments like those on the processing floor.
More to come
While progress to date has been significant, Georgia Tech researchers
are pursuing a number of additional improvements that could provide further
performance enhancements.
Phase-lock detection techniques are being developed to bring the biosensor's
sensitivity down to a detection level of 100 cells per milliliter, a threshold
well below that of conventional ELISA tests.
Researchers are looking at techniques to increase binding efficiency
on the waveguide surface through increased surface area coverage and permanent
antibody binding.
The next version of the sensor chip will have 24 to 28 channels. This
means the biosensor will be able to conduct 24 simultaneous tests instead
of being limited to a single test per chip. This will allow the biosensor
to simultaneously screen for more than one organism or test for the same
organism using multiple channels to eliminate the potential for false positives.
"Poultry Plus" begins field trials
Poultry Plus is a multimedia CD-ROM designed to educate students about
the complexity and importance of Georgia's poultry industry. It also can
be used as a resource for teaching general science and mathematics skills.
The CD-ROM is currently undergoing field evaluation in a number of north
Georgia middle and high schools. A national distribution is planned after
the field trials are completed.
Educating students throughout the nation about how the poultry industry
works, its contributions to the economy, and potential career opportunities
are the long-term goals of Poultry Plus. A multimedia CD-ROM (one that combines
more than one medium of communication) aimed at familiarizing students with
Georgia's poultry industry, Poultry Plus is scheduled for field trials in
the first quarter of 1997. This interactive instructional resource targets
middle- and high-school students with challenging math and science problem-solving
tasks. Developed for both the Macintosh and the Windows-95 platform, Poultry
Plus is an "edu-tainment" product designed to entertain while
teaching students.
Developed jointly by the poultry industry, teachers from northeast Georgia,
researchers from Georgia Tech Research Institute and Georgia State University,
the Pioneer Regional Educational Services Agency, the Georgia Poultry Federation,
and the Georgia Poultry Processors Association, Poultry Plus educates students
about the complexity and importance of Georgia's poultry industry both locally
and globally.
Poultry Plus is a community-based instructional resource that will be
released first in northeast Georgia, an economic region of Georgia where
the poultry industry is a significant contributor to the local economy.
Students will be taught the basic concepts of an industry they have contact
with and will be further challenged to use this information in a broader
context.
Topics covered
Students are presented with text, photographs, and video in an engaging
format which describes the procedures required to grow and process a chicken
for the consumer. In the first section, titled "From The Farm...," students
are taught the basics of hatchery production, breeder production, broiler
production, and waste and recycling management. Incorporated within these
lessons is information pertaining to the science and operations skills needed
to efficiently select and produce poultry in today's integrated operations.
In section two, titled "To The Market...," students learn the
mechanics of poultry processing. Also included in this module is a section
on the history of the processing industry and a section describing the customer-
and consumer-relations aspects of the poultry business.
Use in the classroom
All sections of the CD-ROM allow the student to move in a linear (i.e.,
as one reads a book) or a non-linear (i.e., as one browses an encyclopedia)
fashion. This built-in flexibility allows for diverse teaching strategies.
Teachers may direct a group of students to move through a specific section
or may allow individuals to move through the entire piece as they wish.
The CD-ROM can also be used as a resource for a variety of subjects such
as general sciences and mathematics. The Customer/Consumer Relations section
contains information pertaining to consumer buying habits that are useful
in social science classes, and the first three modules covering the hatching
and breeding process are applicable to the biology of reproduction. The
waste and recycling management sections are useful in both fields. Computer
skills are inherently improved as students gain an understanding of how
multimedia CD-ROMs work and are used.
An important part of Poultry Plus is the problem-solving module. The
problems were designed using the problem-solving approach outlined in both
the state and national Standards for Sciences and Mathematics. Problem-solving
skills are enhanced by finding solutions to real-world poultry-industry
concerns such as reducing water usage in a processing plant or estimating
the costs and benefits associated with plant expansion. Also included on
the CD-ROM are an instructor's guide which contains various lesson plans
for both classroom and field applications and a teacher's guide suggesting
ideas on how the product is best used.
Distribution
Now in the final stages of internal testing, Poultry Plus is scheduled
for distribution to a selected group of teachers for field evaluation in
early February. Two final modules are also planned for completion in 1997.
Discussions are already underway with the Georgia Poultry Federation and
Georgia Ag in the Classroom to explore a national distribution mechanism
once the field trials are completed.
Poultry process safety management compliance guide now available
A new compliance guide for poultry process safety management has been
generated by researchers at Georgia Tech. Its goal is to help poultry
plants comply with OSHA standard 29 CFR 1910.119, "Process Safety
Management of Highly Hazardous Chemicals."
Chemical accidents can result in major releases of hazardous materials,
such as the 1984 poisonous gas incident in Bhopal, India, in which more
than 2,000 people were killed; the 1989 explosion in Pasadena, Texas, which
killed 23 and injured 132; and the chlor'ination-reactor explosion in Institute,
West Virginia.
Georgia Tech researcher David Jacobi notes: "These incidents and others
pointed out to safety-and-health and environmental regulators that there
needed to be a management structure involved to control or limit the catastrophic
release of hazardous materials." OSHA standard 29 CFR 1910.119, "Process
Safety Management of Highly Hazardous Chemicals," does just that.
However, "this is probably one of the most complex standards OSHA has
ever put out," Jacobi cautions. "Companies may need to invest
substantial economic and human resources to meet the standard."
To help the poultry industry meet the standards, researchers at Georgia
Tech have put together a compliance guide on process safety management (PSM).
The guide was developed as a result of an industry need that researcher
Paul Middendorf became aware of during technical assists for poultry facilities.
Plant personnel indicated that they were having difficulty knowing where
to begin in implementing the complex OSHA standard. Middendorf and Jacobi
developed the document, with the support of the Agricultural Technolgy Research
Program.
Because the standard is so complex, the compliance guide from includes
not only the standard itself but guidance materials that
outline requirements;
provide a compliance checklist;
provide informational resources;
include regulatory interpretations to address industry-specific concerns
of poultry processors.
How the standard applies to the poultry industry
Although the OSHA standard was not specifically designed for the poultry
industry, poultry plants may use sufficient quantities (above the OSHA
threshold level) of several of the chemicals listed in the standard. Fortunately,
according to Jacobi, "there are a limited number of materials that
poultry plants need to deal with." The most common chemicals in poultry
plants that may exceed the threshold amounts are ammonia (used in standard
mechanical refrigeration systems) and chlorine and chlorine dioxide (used
for disinfection in water-treatment systems). Other chemicals that plants
may or may not use in sufficient quantity to fall under the standard
include (but are not limited to) formaldehyde (sometimes used in hatcheries
for
disinfection and sterilization), hydrochloric acid, and propane. Poultry
plant managers can consult the list of chemicals and threshold quantities
in the mandatory appendix to the standard to see if their plants are
subject to the requirements of the OSHA standard.
If poultry plant managers find that their plants are subject to the requirements,
plant managers are required to implement a process hazard analysis (PHA)
to determine what, if any, of the steps in the usage process could result
in a potential or unexpected release of hazardous chemicals. Plant personnel
must conduct hazard analyses for each process.
Time is short
"
We are rapidly approaching the final deadline for one of the major components
of the standard-PHAs," Jacobi warns. Processing plant personnel have
only a few months left in which to complete PHAs. According to the standard,
at least twenty-five percent of the initial PHAs must have been completed
by May 26, 1994; 50 percent by May 26, 1995; 75 percent by May 26, 1996;
and 100 percent by May 26, 1997.
Middendorf and Jacobi feel that after the final compliance date, OSHA
will probably increase inspections to verify compliance. The standard was
intended to focus on the petrochemical industry initially, because of the
combustible, flammable, explosive, and highly hazardous materials that are
associated with this industry, and Middendorf and Jacobi anticipate that
OSHA will certainly target areas where petrochemical operations abound (such
as the southwest). However, they feel that the southeastern region (of which
Georgia is a part) will also see increased OSHA activity-inspectors can
identify compliance easily in the poultry industry because usually only
two major chemicals, ammonia and chlorine, are involved. Thus, poultry plants
may prove a good test run for OSHA.
How plant personnel can implement PHAs
Plant managers are responsible for putting together a team of people
that involves:
frontline employees;
supervisors;
maintenance personnel;
plant engineers;
safety-and-health managers.
These plant personnel work together to identify the scope of the issue,
developing a PHA that involves the entire manufacturing scheme:
all points in the process where a release could occur;
the likelihood of such a release occurring;
methods of detection, if any;
methods of control, if any;
the necessary response by designated individuals, which may include evacuation
by employees.
Jacobi states, "One thing Paul and I want to emphasize in the standard
is that it requires a strong team approach from many different people at
many different levels in the plant environment."
How the Georgia Tech compliance guide can help poultry processors meet
the OSHA standard
The OSHA standard itself is reprinted in Georgia Tech's compliance guide.
The appendices to the standard are included, and there are some mandatory
and nonmandatory guidance sections at the end of the standard. Information
about the organization of the standard and OSHA's intent is included.
Besides the OSHA standard and appendices, the compliance guide includes
other information that will help poultry processors meet the standard.
For example, the compliance guide includes background information that
will help processors understand why the standard was developed.
In addition there is a detailed overview of the standard as it applies
to the poultry industry. This overview includes:
information on chemicals that poultry processors use that are on the
standard's list of chemicals;
an overview of employee involvement;
process hazard analyses and methods, including what PHAs must address,
the procedures, follow-ups, and operating procedures;
training;
contractors;
the pre-start-up safety review;
mechanical integrity;
hot work;
management of change;
incident investigation;
emergency planning and response;
compliance audits;
trade secrets.
Poultry industry-specific reference information includes:
examples of manufacturer's safety data sheets (MSDSs) for chlorine and
ammonia;
ammonia health hazards;
an example flow diagram for ammonia refrigeration;
a sample process hazard analysis for ammonia refrigeration.
Jacobi believes that one of the most useful sections of the compliance
guide is that on references and resources for process safety management,
including private sources and consensus industry associations. Jacobi notes
that "all of these are good sources for people to go to for assistance,
both for documents (software in some cases) and training. Also we encourage
people to contact OSHA. Don't be afraid to contact OSHA. If you don't want
the information coming to your work address, have them send it to a home
address. OSHA can send you several introductory publications that can help
you." Middendorf emphasizes how helpful these introductory publications
are: "They provide an overview of what is required, including background
information to help you understand why it has been implemented."
Jacobi states that "one other document from OSHA that is very, very
useful and that has been adapted in our guidance document is OSHA's compliance
directive." The compliance directive is OSHA's internal guidance document
for enforcement to its own personnel-specific instructions on how to identify
deficiencies in programs, how to identify hazards, and how to cite them.
It's public domain. Industries can use this document to help them avoid
hazards. The compliance document is revised periodically. Middendorf adds, "Just
as important are the letters of interpretation, which come out as people
have problems and concerns." Letters of interpretation are issued when
people write OSHA about their problems and concerns, and OSHA then publishes
responses. Poultry processors can use these as a reference. These responses
are available on a CD-ROM. Jacobi cautions that the letters of interpretation
don't have the force of law like the standard, nor does the compliance directive, "but
they are the best things we have to understand how OSHA works-how OSHA intends
to enforce the standard."
The Georgia Tech compliance guide also includes a section on process
safety management audit guidelines. This section is very similar to what
is found in the OSHA compliance directive-a guide or checklist that compliance
officers use. "If you ask anyone in your facility who you would rather
have fill out a checklist-plant personnel or OSHA inspectors-the answer
is obvious," Middendorf comments. This detailed checklist will help
the process safety management team comply with the standard (different individuals
will work on different sections of the checklist). The checklist includes
references to appropriate sections in the standards so that plant personnel
can refer to the standards as necessary.
How to get a copy of the compliance guide
The compliance guide is available to Georgia poultry plants free of charge.
There is a nominal charge of $6 to non-Georgia plants to cover printing
and shipping charges.
To receive a copy of the compliance guide contact:
Craig Wyvill, Director
Agricultural Technology Research Program
GTRI/ATRP
Atlanta GA 30332-0823 USA
(404) 894-3412
FAX (404) 894-8051
Email: craig.wyvill@gtri.gatech.edu
Other PSM Resources
For more information and assistance on how to apply the standards, several
government resources are available:
OSHA CD-ROM
Beginning with the A-92-2 CD-ROM, available April 6, 1992, you can purchase
either the single disk, or enter a 1-year subscription. The single disk
price is $28.00; the subscription price is $88.00. The subscription provides
this disk as well as quarterly updates, mailed automatically to subscribers
from the Superinten-dent of Documents, Government Printing Office.
The CD-ROM includes the following:
Air Contaminants (Preamble, Standard and Z-Tables of 1910.1000)
Bloodborne Pathogens (Preamble and Standard of 1910.1030)
Chemical Sampling Information
Consultants (Expert Witness)
Compliance Directives
Federal Register Index
Field Operations Manual/ Field Inspection
Reference Manual
Library Catalog
OSHA Standards and Recent Preambles
OSHA Technical Manual
Process Safety Management (Preamble and Standard of 1910.119)
Standards Interpretations
Variances
You can purchase this CD-Rom from the Superintendent of Documents by calling
(202) 783-3238 and ordering Stock Number 729-013-00000-5.
NIOSH Pocket Guide to Chemical Hazards, Third Revision
Available June 1994, from NIOSH (800-35N-IOSH), Publication No. 94-116.
This guide contains the following information for 677 chemicals (including
the OSHA regulated substances): chemical structures, formulas, identification
codes, synonyms, exposure limits, chemical and physical properties, incompatibilities
and reactivities, measurement methods, respirator selection, signs and symptoms
of exposure, and procedures for emergency treatment.
Cost: One free copy per requestor
OSHA Web Site:
http://www.osha.gov
The OSHA Region IV Technical Support Contact for Process Safety Management
is Terry Wilkens (Atlanta): (404) 347-2882.
OSHA Area Offices:
In Georgia, the area offices are:
West Atlanta Area (Smyrna), Director: Tom Brown, (770) 984-8700;
East Atlanta Area (Tucker), Director: Ray Finney, (770) 493-6644;
Savannah Area, Director: Luis Santiago, (912) 652-4393.
Credits
Dara O'Neil, Editor
Rae Adams, Contributing Editor
Nancy Davis, Contributing Editor
Kevin Marshall, Contributing Editor
Authored by the Office of Food Industry Programs
Craig Wyvill, Director OFIP
Georgia Tech Research Institute
Atlanta, Georgia 30332-0823 USA
Telephone: 404/894-3412
Copyright © Georgia Tech Research Corporation, 1998. All Rights Reserved.
URL: http://atrp.gatech.edu |
