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FDA MANUAL OF INTERPRETATIONS
Interpretation Number: 07-XI-.02-101
Guide Contents
National Shellfish Sanitation Program
U.S. Food and Drug Administration
Shellfish Safety Team
Division of Cooperative Programs
Office of Compliance
Date: January 15, 1999
Revised: December 8, 2002
Model Ordinance Chapter XI. 02. B. (1)
Reference: Chapter XI. 02. B. (2)
Key Words: Food contact surfaces, cleaning,
sanitizing, equipment construction
Question: 1) What is a food contact surface?
2) What constitutes effective cleaning and
sanitizing of a food contact surface?
3) What constitutes acceptable construction of shellstock grinders and
parts thereof are considered food contact surfaces?
Interpretation:
-
1) A food
contact surface means a
surface of equipment or a utensil with which food normally comes into
contact;
or a surface of equipment or a utensil from which food or liquid may
drain, drip,
or splash into a food; or onto a surface normally in contact with food.
Food
contact surfaces include, but are not limited to, equipment and
utensils such
as; shucking knives and handles, shucking hammers and handles, shucking
blocks,
ice scoops and shovels, ice bins, skimmers, blower tanks, shucking
pails, shellstock
grinders.
-
2) Food-contact surface shall be
clean to sight and touch. Cleaning and
sanitizing shall occur prior to use each day and any time during use
when contamination
may have occurred. At a minimum, food contact surfaces shall be cleaned
and sanitized
every four hours. More frequent cleaning may be necessary depending on
the characteristics
of the equipment and its use and the amount of food residue
accumulation. At
the end of each day, food contact equipment and utensils shall be
washed and rinsed.
Food contact surfaces shall be effectively washed to remove or
completely loosen
soils by manual or mechanical means such as the application of
detergents; hot
water; brushes; or high pressure sprays. If washing in sink
compartments is
impractical such as when equipment is fixed or utensils are too large,
washing
shall be done using an alternative manual procedure. In such instances,
washing
shall be facilitated by 1) disassembling equipment as necessary to
allow access
of the detergent solution to all parts and equipment components and 2)
utensils
shall be scraped or rough cleaned to remove food particle accumulation.
The cleaning of food contact surfaces shall occur prior to sanitizing
in order
for the sanitizer to be effective in destroying vegetative bacteria.
Sanitizers
may be applied by immersion, spraying or brushing. Sanitizer
concentration
shall be in accordance with the manufacturer's directions on the label.
-
3) Parts of a shellstock grinder
which are considered food contact surfaces include; the blade, the area
behind the blade including the motor shaft from the blade to the motor
housing, and the inside surface of the housing or cover surrounding the
blade. These food contact parts shall be manufactured from high impact
materials that are easily cleanable and non-corrosive. The grinder must
be constructed to be easily disassembled and assembled to facilitate
inspection, maintenance, cleaning, and sanitizing.
Guidelines for grinder construction:
- The motor shaft should be of corrosion resistant material.
- Juncture point where the motor shaft enters the blade chamber
must be sealed to reduce dirt and detritus deposition around the shaft.
- The blade must be made from a single piece of high impact
non-corrosive material. Blade teeth must be an integral part of the
blade, or if grinding surfaces are used instead of teeth, they must be
welded to the face of the blade with all welds ground smooth.
- The housing around the blade assembly must be constructed of
material that is corrosion resistant.
- Bolts or screws must be constructed of corrosion resistant
material to prevent rust and corrosion.
- The inside surface of the blade housing must be smooth, and if
welded ground smooth for easy cleaning.
- The blade housing must be designed with an easily removable cover
that will open up the entire blade assembly area to
facilitate inspection, cleaning, sanitizing, and maintenance.
Rationale:
Each shellfish dealer is responsible for assuring that all food contact
equipment and utensils meet the design, construction, repair, and
cleaning requirements of the NSSP, Guide for the Control of Molluscan
Shellfish. Food contact surfaces must be cleaned and sanitized at a
minimum frequency and in accordance with proper procedures to prevent
contamination of shellfish by microbial pathogens and chemicals.
Consistent with the FDA Food Code, cleaning and sanitizing shall occur
at least every four hours and where necessary more often, depending on
the accumulation of food debris or exposure to other contaminants.
Under the NSSP Guide for the Control of Molluscan Shellfish and 21 CFR,
Part 123, shellfish dealers are responsible for monitoring and
maintaining records of the cleaning and sanitizing of food contact
surfaces.
Other References:
- 21 Code of Federal Regulations, Part 110 - Current Good
Manufacturing Practice in Manufacturing, Packing, or Holding Human
Food, U.S. Food and Drug Administration.
- 21 Code of Federal Regulations, Part 123 - Fish and Fishery
Products, U.S. Food and Drug Administration.
- 1997 Food Code, U.S. Food and Drug Administration.
- Food Equipment American National Standard NSF International Standard
ANSI/NSF, NSF International, Ann Arbor, MI, 48113.
Contact:
U.S. Food and Drug Administration
Center for Food Safety and Applied Nutrition
5100 Paint Branch Parkway (HFS-628)
College Park, MD 20740
Distribution:
Shellfish Specialists
Regional Federal State Program Managers
Division of Federal State Relations
Office of Seafood
Interstate Shellfish Sanitation Conference
Laboratory Evaluations Officer
Canada / Chile / Republic of Korea / New Zealand