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Simplifying Food Regulation

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Developing an ATP Testing Program
ATP Tester Blog Post Image.png

What is ATP Testing?

ATP testing is a type of environmental monitoring that answers a single question — has this surface been properly cleaned?

How does ATP testing work?

ATP testing works like this: there is ATP in all organic matter. A properly cleaned surface should have a very low level of ATP whereas an unclean surface will result in higher levels of measured ATP. 

Measuring ATP on a surface which has been already cleaned gives you a quantitative answer of how effective your cleaning efforts were.

Food manufacturers use an ATP tester (also known as a luminometer) to verify whether their cleaning efforts are successful. When you detect a high amount of ATP on a surface, then you should re-clean that area immediately and reconsider whether your existing cleaning efforts need upgrading.


How is ATP measured?

An ATP test is conducted using a device called a luminometer. Typically, you would swab a surface several times after your cleaning programs have been completed.  It’s best to take multiple swabs when testing a single area  so that you can get more a more accurate test result.

Next you would place each swab in your luminometer and it would instantly provide a result measured in RLUs (relative light units). This result is achieved by reading the amount of light produced by the sample.

High RLUs = dirtier surface (more ATP)

Low RLUs = cleaner surface (less ATP)

A common starting point for food processing facilities would be to set a passing score as fewer than 150 RLUs (for comparison, a hospital ICU might have a passing score of < 10).  Ultimately, the tolerance for ATP on a surface depends on the sanitation standards for that facility and the operator’s tolerance for risk.  


What does an ATP Test Result Tell You?

It’s important to understand the difference between an ATP test and other types of environmental monitoring tests. An ATP test only gives a sense of how well something has been cleaned. 

For example, a prep table in a food processing facility could show high levels of ATP (i.e. an unclean surface) while providing a negative result on a series of environmental pathogen tests. This is because ATP tests will register any organic matter on a surface, even if none of that organic matter is specifically pathogenic.

To reiterate — an ATP test answers a single question — is this surface clean?


Should I begin an ATP testing regimen in my food processing facility?

It depends. Doing a one-time series of ATP tests across your facility will give you a baseline indication of how effective your cleaning practices are. This can be helpful in adjusting/improving your existing sanitation programs.

However, it’s important that you already have strong sanitation practices in place before you begin routinely testing ATP. Swabbing surfaces which have not been sufficiently cleaned will consistently indicate high levels of ATP and a failing result.

If the sanitation practices in your facility are inconsistent or haphazardly enacted, it’s worth tackling these issues before you launch an ATP testing regimen. 


Implementing an ATP Testing Program

Implementing an ATP testing regimen requires three broad steps:

  1. Map your facility by hygienic zone (e.g. risk).

  2. Determine relevant testing sites. As a starting point, consider the the critical control points (CCPs) and preventive control steps outlined in your Food Safety or HACCP plan.

  3. Determine the cadence of testing.

Building an environmental monitoring plan is a unique process for every food processing environment. You’ll want to consider a few questions when writing your ATP testing plan

  • How difficult is this surface to clean?

  • How close is this surface to the food itself?

Hard-to-clean surfaces which make direct contact with the food (e.g. conveyer belts) will take higher priority than easy-to-clean surfaces which do not have direct contact with the food (e.g. sinks, walls)


 
Best pH Meters for Food Processing
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Our Picks: Best pH Meters for Food Processing

The Basics: pH Meters

pH meters are a common tool in the food processing context.

Since acidity is often used as a means to preserve foods, a pH meter is required to confirm that the correct level of acidity is achieved in the product.

A pH meter measures the acidity of a substance on a scale from acidic to alkaline (a.k.a. basic).

pH is typically measured on a numeric scale from 1 -14 but it can also be measured using a color gradient.

Whether you’re taking pH readings so you can test a chemical concentration or as part of your HACCP plan.

pH range is measured from 0 (acidic) to 14 (alkaline)

pH range is measured from 0 (acidic) to 14 (alkaline)


Do I need a pH Meter?

You need a pH meter if the following circumstances apply:

  • You produce one of the following types of food:

    • Acidified food

    • Fermented food

    • Low-acid-canned-food

  • You use chemicals whose concentrations require testing using a pH meter.

  • You produce a product that uses acid or fermentation as a means of preservation.


Considerations When Choosing a pH Tester

  • Accuracy: Do you need accuracy to 0.1 or 0.02? This is probably the biggest factor in what you should buy.

  • Calibration: Is it easy to quickly re-calibrate (you’ll probably have to calibrate your device before each use if you are recording your results for a HACCP/Food Safety Plan).

  • Portability: Does your pH meter need to be portable or can you choose a plug-in bench top model? Note that smaller, more portable pH testers tend to be less accurate.


Handheld pH Meter

What’s it for: Taking pH measurements when you need accurate results and portability. Perfect for the food processor who needs to take pH readings for a HACCP / food safety plan.

Pros:

  • Higher degree of accuracy (typically 0.01-0.03) than pen-style models. Accurate enough for all food processing applications.

  • Portable

  • Replaceable electrode.

Cons:

  • Two-hand operations is slightly less convenient than pen-style.

Why We Picked Our Winner:

  • High degree of accuracy (Accurate ±0.01)

  • Automatic temperature compensation

  • We’ve been using this model for 3 years with continued accurate results.

  • Extremely long battery life from a single 9V battery

  • Durable construction. Trust us, we’ve dropped it.


Pen-Style pH Meter

What’s it for: Taking multiple readings across different areas in a food production space with reasonable accuracy (0.1±). Pen style pH testers are a good place to start if you need reasonable accuracy and are on a budget.

If you need a pH meter as part of your HACCP or Food Safety Plan, consider a more accurate tester see our Handheld and Benchtop choices below.

Pros:

  • Remarkable portability. Slip it into your pocket.

  • Reasonably good accuracy for an entry-level price point.

Cons:

  • Accuracy of ± 0.1 isn’t sufficient for many food processors.

  • There are lots of cheap pen-style pH testers on the market which are prone to inaccurate results. Consider our pick for Pen Style pH tester

  • You’ll want to keep buffering solutions with your pH meter so that you can calibrate it. So even if you have a very tiny pH meter, you’ll need to haul around these accessories with you if you want accurate readings.

Why We Picked Our Winner:

  • Extremely portable

  • Fully waterproof (this helps in a food processing context).

  • Best tested accuracy and reliability among the pen-style models we tested. Accurate to ± 0.1

  • Affordable price point ~($50)


Basic: pH Test Strips

Overview: Test strips are best for simple measurements that do not require a high degree of specificity. You might use a test strip to get a general sense of pH or if you’re only doing occasional tests and will be happy with a general result.

Pros:

  • Easy use — just dip and compare the strip with the color key on the packaging.

  • No calibration required

  • Small size for on-the-go testing

Cons:

  • Not as accurate as electric pH meters

  • Reactive paper shows the pH of whatever it contacts — whether that’s what you' want to test or not.

  • Typically has a maximum 2 year shelf life. After this time accuracy may vary.

Our Choice:

We prefer Hydrion because they’re the most reliable test strip on the market. They’re a little pricier, but you won’t risk buying an expired test strips like some other producers offer. It’s the most accurate test strip on the market. If you want accurate readings then stick with reputable brands.


 
Picking The Right Storage Containers For Your Shared Kitchen
 

Introduction to Shared Kitchen Storage

Your customers will probably want multiple options based on their business size

Your customers will probably want multiple options based on their business size

Storage can be a thorny area for shared kitchen operators. Food producers are typically interested in storing some combination of equipment, ingredients, and finished product onsite. Often, designated storage spaces are shared among multiple businesses. This requires the shared kitchen user to store their product in a set of containers.

This section is devoted to helping you find the best storage containers for use in a shared kitchen. It is informed by the FDA regulations, collaboration with health agencies nationwide, and the best practices I’ve observed in shared kitchens.

Or, you can skip to the FDA Reader List of Best Shared Kitchen Storage Containers.

Factors to Consider

Here are the major considerations:

  • Material

  • Size

  • Airflow

  • Secure

  • Compatibility with other systems

Material

Food Safe: The material for your storage should be food safe — presumably there will be some contact between raw food (or packaging) and the container it will reside in. Ideally, the container is NSF approved, but if not, you should be able to discern whether it is made from food safe materials by reviewing the product spec.

Strong: You want a material that is going to be strong enough to endure the abuse of a kitchen. These containers will be full of heavy items, slammed down on tables, and dragged across wire shelves. It should be strong and also capable of enduring the temperatures of a refrigerator or freezer. While I recommend using metal bun-cabinets for easy storage, the cold can burn your hands when it has been sitting at -10ºF.

Color: Finally, it’s worth considering the color of the container. Since these containers might crack and they will be in close proximity to food, it’s best to get a color that will easily stand out (like blue). This is not necessary, but if color is a consideration, pick blue, the best color for minimizing foreign object contamination.

Water/Rust Proof: The storage container is going to get dirty and require washing. If it goes in the freezer, it will get covered in ice. Pick something that won’t rust and that can tolerate a lot of moisture. Wood and cardboard are no-no’s. Plastic and certain types of metal tend to work best.

Shape/Size

There are a few considerations when it comes to picking a storage solution. Ultimately, the most important considerations are what you are actually storing. You’ll want to make sure that your storage containers don’t affect the product stored inside them.

Weight An oversized plastic tote might fit all of your ingredients and equipment with ease… but it’s impossible to lift onto the shelf. If your container will live on a shelf, then pick a storage container that you can comfortably lift when it’s full.

Shape Avoid shapes that will minimize the amount of usable space, such as a box with walls that taper. Make sure the containers that you choose maximize the total space available on the shelf or in the space where they will live. Remember, finding the right storage container is being realistic about what is being stored.

Vented

If your storage container is going to live in a refrigerated or frozen environment, then it needs to be vented. Refrigeration works by blowing cold air across the surface of the food items in the space. If food is stored in a solid-walled container — e.g. a typical plastic storage box— the container will insulate the food and prevent it from cooling down.

This is a problem. Airflow is important for cooling purposes. This is why milk crates are crates not solid walled boxes.

The storage container should be vented to allow air to pass through it and across the surface of the food inside.


 
Breaking Down Shared Kitchen Terminology
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Shared Kitchen? Cloud Kitchen? Ghost Kitchen? Commissary Kitchen? Black Box Kitchen? Incubator Kitchen?

Unfortunately, these terms are often used interchangeably throughout the food industry. Not only in news articles but in government regulation, there are a litany of confusing and inconsistent definitions.

Fortunately, they have one commonality: They refer to a food production space which includes some shared infrastructure across multiple businesses.

Some of these terms have a more specific definition or were created to reflect a particular context. The sections below are an attempt to sort this out so we can find consistency in this sector:

Shared Kitchen:

At it's broadest, this entails multiple food businesses operating in a single location which makes use of some shared infrastructure. This term encompasses all of the other terms described in the article and I favor it as the overarching industry descriptor for these business models.

Other equivalent terms include: shared-use kitchen, licensed commercial kitchen (LCK) and commissary kitchen. However, the term commissary kitchen or simply commissary may also refer to a large food processing space operated by a single tenant. For this reason, I prefer not to use this term to describe shared processing spaces.

Incubator Kitchen

This refers to a shared kitchen specifically designed for early-stage food businesses where the site management takes an active role in growing the tenant businesses. Adopting the term incubator from the tech industry, the term Incubator Kitchen implies that the management supports the entrepreneurs to refine their idea and their business model. This may include taking an equity stake in the fledgling businesses but not necessarily.

Incubator Kitchen ≠ Shared Kitchen

Incubator Kitchen is often mistakenly used interchangeably with shared kitchen, especially when the majority of tenants in a shared kitchen are early-stage businesses. However, this does not alone make the business an “incubator kitchen” and the use of this term is misleading when the site management’s offering does not actually “incubate” these businesses in any meaningful way.

There’s a second reason for this term’s popularity: “incubator” is a buzzy term from the tech-sector that people associate with rocket ship growth trajectories, venture capital, and million dollar buyouts. In other words, it’s good marketing.

Here’s an easy way to differentiate the two: the goal of an incubator kitchen is to develop and grow the tenant businesses operating in the space, not maximize occupancy. If the operator is measuring success through occupancy, they probably aren’t an incubator.


Ghost Kitchens, Dark Kitchens, Black Box Kitchens & Cloud Kitchens

For simplicity, I’ll use the term ghost kitchen throughout this section.

These terms all refer to the same thing: a food processing facility which has no dine-in retail component. Typically, all of the food produced in a ghost kitchen is delivered to the customer, often via a food delivery service such as Seamless, Grub Hub, or Deliveroo.

A ghost kitchen is not necessarily a shared kitchen — a single delivery-only food production space would still be a ghost-kitchen but not a shared kitchen. However, these terms overwhelmingly imply a cluster of ghost kitchens in a single location. And when those tenants make use of common infrastructure (such as refrigeration, dishwashing, or cooking equipment), then they would fall into the category of “shared kitchen".

Regardless of whether they fall under the “shared kitchen” umbrella, multi-unit ghost kitchens tend to be focused on delivery food service with restaurants making up the bulk of their users. The equipment and layouts of these kitchens generally supports this type of user although a food business not requiring a walk-in retail component (such as a small-scale manufacturer) could also operate out of this space.

Finally, it’s worth noting that Cloud Kitchens is also the name a of a prominent ghost-kitchen provided started by uber founder Travis Kalanick.

The Bottom Line

The shared kitchen industry is still in its infancy and the terminology continues to formulate. If you subscribe to a different definition than the ones provided above, that’s fine. However, it’s important to acknowledge that there is currently a lack of consensus on naming conventions and that while terms may be tossed around interchangeably, they can have a specific connotation.


 
Interstate Commerce and FDA Jurisdiction
Interstate commerce refers to products that cross state lines prior to consumption, or products composed of ingredients that have crossed state lines.

Interstate commerce refers to products that cross state lines prior to consumption, or products composed of ingredients that have crossed state lines.

What is Interstate Commerce?

If a product crosses state lines between the start of the manufacturing process and when it is received by the individual who purchases it, then it has entered "interstate commerce".

Additionally, if the product is composed of ingredients from out-of-state, then it is considered to be a part of "interstate commerce" -- even if the product was created and consumed in state.

The technical definition of interstate commerce is:

"(1) commerce between any State or Territory and any place outside thereof,

and

(2) commerce within the District of Columbia or within any other Territory not organized with a legislative body."

FD&C Act [21 U.S.C. 321(b)] 

Examples of food that enters interstate commerce:

  • A frozen pizza business that has a website and ships to buyers nationwide.

  • A food processing facility that operates in New York and supplies cookies to bakeries in New Jersey.

  • A distributor that holds food products created by local food producers in a warehouse and distributes them to a local retailer who, in turn, sells them in several states

 

How Does Interstate Commerce  Relate to the FDA?

Whether a product enters interstate commerce is a major factor in determining whether a food business falls under FDA Jurisdiction. The other major factor is what type of food business it is. 

However, it is worth noting that all domestic facilities that engage in food processing, production, packing, or holding, must register as a Food Facility.

Additionally, the FDA may regulate any product that is adulterated or misbranded, even if that product doesn't enter interstate commerce.


Understanding E. Coli in a Food Processing Context

What is E. Coli?

The Escherichia Coli bacteria shown under a microscope

The Escherichia Coli bacteria shown under a microscope

We all know that E. coli is a threat to human health that is transmitted by food. But what foods specifically? How is it controlled and how can we protect ourselves from it as eaters and food producers?

The Basics:

Escherichia coli is a bacteria that produces a toxin called “Shiga”, that can cause food borne illness and even death.

Associated Foods:

  • Raw ground beef

  • Raw seed sprouts

  • Raw milk

  • Unpasteurized juice

  • Foods contaminated by fecal matter

Transmission: 

Human-to-Human or via contaminated food.

Incubation Period: 

Usually 3-4 days after exposure, but it can range from 1-9 days.

Symptoms:

  • None (it can be asymptomatic)

  • Diarrhea

  • Bloody Diarrhea

  • Kidney failure

Control Measures (i.e. how we stop it)

  • Cooking food to 155º for 15 seconds will kill E. coli.

  • No bare hand contact with ready-to-eat (RTE) foods

  • Strong employee health policies (i.e. no sick employees handling food)

  • Hand washing

  • Prevention of cross-contamination

  • Pasteurization or treatment of juice

The Bottom Line:

E Coli is a dangerous bacteria that can be transmitted via food and cause tremendous harm. At the same time, it’s something we can control quite easily and, if you are taking appropriate precautions, should not be something to worry about.

If you have more questions about how to control E. coli, ask in the comments section below.