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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