The purpose of Tony Wesner, chief operating officer of Rose Acre Farms, traveling to five area meetings of the United Egg Producers (UEP) over a two-week period was to share what the company learned from their recent egg recall with the industry. Wesner expressed an attitude of “a rising tide lifts all boats” to motivate his company to reveal their experiences with the U.S. Food and Drug Administration (FDA) egg recall. After prefacing his presentation with the fact that they don’t know it all and hope to receive suggestions from the audience, he continued to describe what went right and what could have been done differently.
A team and plan are crucial in preparing for potential recall
Have a team ready in case of a recall. United Egg Producers (UEP) provided Rose Acre with assistance throughout the experience. Outside consultants, some with FDA experience, were utilized to guide Rose Acre on next steps and collaboration with the FDA. Although not mentioned by Wesner, one might conclude a public relations firm could be a valuable partner to help with recall messaging.
Investment in an efficient “track and trace” system proved invaluable. The FDA wanted to ensure that eggs from the Hyde County farm did not get cross-loaded or mixed with any other Rose Acre eggs at other farms or further distribution points between the Hyde County farm and customers. Rose Acre was able to account for all eggs during the recall period, and at times had to demonstrate that eggs from other facilities were not sold to customers in specific sites. Wesner said that without these important tools, the recall could have unnecessarily ended up involving more production sites, resulting in an exponential increase in expense.
Treat production houses and the processing plant as isolated entities from a biosecurity perspective. Wesner advised that there should be no human or equipment interaction or exchange. This obviously requires separate entries and two sets of showers, rest rooms and break areas.
Study traffic patterns. Where have the tires on the forklift been, and where are they going? Rose Acre is redesigning the layout of its processing plant in order to minimize cross-contamination possibilities to isolate incoming materials and establish quarantine areas as needed to hold materials until quality control testing requirements have been satisfied.
Sanitation is mandatory
Set high standards for all incoming material suppliers and be sure they are in compliance. During their own internal investigation, Rose Acre personnel learned that workers had observed small lettuce remnants on incoming pallets, which could easily introduce contaminants to the processing plant and/or farm. Returnable plastic crates had arrived wet, which also could have been a source of contamination. Ask the question — where have these materials been, and how have they been sanitized?
Water is your enemy. Wesner mentioned this important lesson as all 20 Salmonella suspect/positive swabs of the 170 taken in the egg processing facility were from wet areas or materials. These swabs were taken from wet spots on the floor, drains, condensation on rusted metal and wet cleaning supplies. There was no Salmonella detected on any of the processing equipment parts with egg contact.
Sanitation is key — not only on the eggs themselves, but also the equipment, too. | Terrence O'Keefe
Follow all documented procedures and ensure all employees are well-trained on implementation. One FDA citation noted that a disinfectant was used at a higher rate than described in the company’s procedures.
Be sure the night shift sanitation crew appreciates the importance of doing their job. This employee group is absolutely essential and needs to feel the appreciation of management for their important role. An occasional visit to thank them is invaluable.
The company’s sanitation standards need to be higher and more closely monitored than those of the United States Department of Agriculture (USDA) in-plant inspectors. While Rose Acre policies are more strict than those of the USDA, Wesner warned that some companies may use that threshold as an approval to start processing. He reminded owners that in a recall there is no finger-pointing — you own the problem and your response.
Know your feed ingredient sources and consider them as possible vehicles of contaminants. Rodents are common in grain storage facilities. Salmonella has been isolated from soybean meal. Analyze how your feed is produced and what steps are needed to ensure contamination does not occur.
“We must change the culture,” Wesner said, inferring that while egg producers may consider themselves to be farmers, the FDA is inspecting to a food processing standard. All employees must be engaged and committed to learning and executing a biosecurity and food safety plan. It’s a team effort, and Wesner urged attendees to “get employees to look at everything through different eyes. We need to think in a different way.”
Consider areas of possible contamination risks
Consider air intakes and exhaust as possible sources of contamination. A vertical air intake coated with slimy residue could introduce a contaminant to the egg processing machinery and plant. Look from the top of pipes on the outside as well as through the bottom inside the building — just don’t be satisfied with a partial inspection. Rose Acre is considering new technologies, such as dry hydrogen peroxide, to be sure air introduced into the processing room is as clean as possible.
Evaluate entrances and materials used to decontaminate footwear. Wesner observed that powders can be messy, and shoe scrubbers may be tough to sanitize. Depend on manufacturers and their instructions for guidance, but you must own your procedures and operations.
Thorough cleaning and disinfection of egg processing equipment is a daily requirement that must follow all documented protocols without fail. If it needs to be disassembled to clean, be sure that step is not missed. The FDA expectation is that the entire machine (including under the machine) is covered with sanitizer.
Employees should be trained on cleaning all equipment, and companies should allow time for the sanitation process to take place. | Terrence O'Keefe
Evaluate processing equipment. Look for equipment designed to get rejected eggs out of the system as early as possible. Use both chemical and ultraviolet sanitation on the line. Wesner observed there is some question about ultraviolet efficacy, especially on ends of eggs, but if you have the tools installed, he feels it’s best to use them.
Keep your disinfection solutions fresh and properly diluted. An operator may think they are doing a good job, but if the solution isn’t properly prepared, bacteria might survive or even thrive. Standard operating procedures regarding dilution and replacement are essential, and it’s even more important for them to be followed precisely.
Share your learning across the company. “Every time we decide to change a procedure or make a physical improvement, we need to then see if we can use that learning in our other farms. We need to be sure our entire company is making the best effort everywhere,” Wesner said.
“No matter that we all know what part of the chicken an egg comes from, we must start considering our operations to be producing a ready-to-eat food,” Wesner advised. The food safety challenges of cage-free production will obligate producers to examine their operations and continue to evolve processes and procedures to improve food safety of shell eggs.