What You Need to Know

Correction

A correction means taking action in a timely manner to identify and correct a minor and isolated problem that does not directly impact product safety.

Examples of corrections include:

• Re-cleaning the production line if it appears dirty after the first clean.

• An employee is asked to leave the production area and put on the proper attire before re-entering the production area.

• The temperature of a walk-in refrigerator is adjusted because it is a time of high traffic and the temperature is approaching the critical limit.

Corrections occur in the moment and don't require any documentation

Corrective Action

A corrective action is a procedure that must be taken if a corrective action is not properly implemented. This must be documented and the record should describe:

• What occurred

• How the problem was corrected

• How it will be avoided in the future

• What was done with the product in question

Examples where corrective action is required include:

• A sample of canned salsa is tested and the pH exceeds the requirement of <4.3.

• A refrigerator is found to have exceeded the temperature requirement of ≤41ºF for several hours.

• The producer of bottled juice realizes that during the last production run, numerous bottles were not properly sealed by the capping machine, possibly due to defective packaging.

For more about corrective actions, see our full guide

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Correction or Corrective Action?

The following examples illustrate how an operator may choose between a correction and a corrective action

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Scenario	Type of Action Required	Why	Recommended Action
Cookies on a conveyer oven are finished in 8 minutes instead of the required 10 minute cook time	Corrective Action	The cook step is (presumably) a preventive control used to kill bacteria present in raw cookie dough. Because the product failed to achieve the 10 minute cook time, then the preventive control has failed and a corrective action is required.	1. Adjust the belt temperature to reseet to 10 minute cook time. 2. Test to confirm the belt speed has increased the cook time to 10 minutes. 3. Re-cook the cookies for an additional 2 minutes (or discard) 4. Record this on a corrective action form.
Cookies on a conveyer oven are completed in 12 minutes instead of the required 10 minute cook time	Correction	Since the product was overcooked, it still achieved the preventive control that requires a >10 minute cook time.	Adjust the belt speed to reduce the cook time to 10 minutes. Consider testing the overcooked product for quality
Sheet pans are observed to be unclean immediately after being run through the dishwasher	Correction	This is a minor problem that poses no risk to the safety of the food if it is corrected.	Re-run the dishes through the dishwasher and confirm they are clean.
The dispenser for dishwasher sanitizer chemical is discovered to be empty after a day of production	Corrective Action	It is possible that many utensils and dishes were used in production without having been sanitized. This directly impacts food safety of product that was produced and so corrective action should be taken.	1. Refill the sanitizer chemical in the dish machine and confirm it is being applied during the cycle. 2. Assess why the sanitizer ran out and whether chemical levels should be checked more frequently to avoid this problem recurring. 3. Evaluate the food that contacted the un-sanitized utensils/dishes and determine whether it should be discarded, re-worked or served. If the food cannot be proven to be safe then it should be discarded.

Resources

Corrective Action Template

More About Food Safety Plans

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What is E. Coli?

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.

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Resources

FDA “Big Bad Book on Bugs” E. Coli Section

More about Food Safety

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What does a “Kill Step” or "Lethality Step" mean in Food Safety?

When I was first managing a commissary producing 10,000 meals per day, our engineer was always talking about the “kill step.” I never knew what he was talking about but I have since realized it is one of the most important steps in food safety.

Most efforts we take in food safety are related to harmful bacteria. And most efforts are related to minimizing (but not stopping) the growth of harmful bacteria.

A strategy that minimizes bacteria growth is refrigeration. Most bacteria can’t reproduce quickly in cold, but they still reproduce, albeit at a slow rate. This is the reason that perishable food doesn't last indefinitely in the fridge. Of course, without refrigeration, bacteria grows quickly at room temperature and we intuitively know this is bad (i.e.leftover chicken left out overnight).

The most important thing to remember is this: if you leave food on the counter overnight and then put it back in the fridge, it won’t kill the bacteria that grew while it was sitting out, it’ll just slow down the growth process from the moment you put it back in the fridge.

This graph should help illustrate what I mean:

What's Happening in this Graph?

1. You have chicken leftovers in the fridge. There is some bacteria in the leftovers, but it is still safe to eat. You can also see that bacteria growth is slow during these periods because of the cold.

2. You accidentally leave the leftovers on the counter overnight. Eek! We can see by the steepness of the line that bacteria count is growing RAPIDLY during this time, because bacteria are happy and reproduce quickly at room temperature.

View fullsize

3. In the morning, you see that you left the leftovers out all night. At this point, the bacteria level is unsafe to eat, but you put them back into the fridge anyway. While this slows down the growth rate of the bacteria, there is still an unsafe amount of bacteria in the chicken. Remember the refrigeration slows down bacteria growth rates, but it does not kill existing bacteria. So why did you put it back into the fridge? (keep reading!).

Recommended Tools

If you are measuring temperatures manually then I recommend getting a thermocouple for reliable readings. I use this Cooper Atkins Thermocouple with a K-Type Probe

4. At lunch, you throw the chicken into the microwave and nuke it for 4 minutes, remembering that you left it out all night on the counter. This, my friend, is the kill step. Cooking (in this case, chicken) to 165º F doesn't slow bacteria growth, it actually kills all of the bacteria that already grew on the chicken.  At 165º only 1 in 100,000 Salmonella bacteria will survive. We call this a "Log 5" reduction because it reduces the count by 5 zeros. In effect, it "resets the clock" and reduces the bacteria count to safe levels. We see on the graph that the bacteria count plummets to almost nothing.

5. The leftovers are so goddamn hot that you went to write a blog post and forgot all about lunch for an hour. During this time, the leftovers cooled down to about room temperature, which triggered rapid bacteria growth. However, because you killed almost all of the salmonella bacteria in the leftovers, the total bacteria count remains low, despite exponential growth rates. It's still safe to eat even though it sat out at room temperature. This is fairly intuitive.

6. You remember the food and eat your (lukewarm) lunch. It tastes good and you didn't expose yourself to any food safety risk.

IMPORTANT NOTE

While cooking is an effective kill step for most harmful bacteria, it does not necessarily make food safe to eat. The kill step described above would be ineffective in eliminating entero-toxins which have already formed in the food.

When designing a kill step, it's important to first understand what hazards you are aiming to treat. This way, you can be sure that your kill-step effectively treats all hazards.

What Did We Learn?

• Applying a ‘kill step’ drastically reduces harmful levels of pathogens in food. In the example above, reheating food in the microwave kills harmful bacteria that may have grown in the food.

• Slow bacteria growth doesn't necessarily mean the food is safe to eat (as in step #3). Putting food with unsafe levels of bacteria in the refrigerator won't kill the pre-existing bacteria.

• Fast bacteria growth doesn't necessarily mean food is unsafe to eat, as in Step #6. Think about your elementary school lunchbox (not refrigerated!). It's OK to have rapid bacteria growth for short amounts of time IF you're starting with a low bacteria count OR if there's a kill step after.

OK, So What is a Kill Step?

Here are some examples of "Kill Steps" used to reduce bacteria counts in food production:

• Cooking

• Use of chemicals: For example, using anti-microbial produce wash reduces bacteria counts in vegetables that will be served raw.

• Pasteurization: heating something up without meaningfully changing it's composition to kill bacteria

• Freezing: The majority of fish intended for raw consumption is frozen for a period of 7 days to kill harmful parasites. Note that freezing isn’t effective as a kill step against bacteria.

It's important to remember that different microorganisms have different tolerances for specific treatments. Another way of saying this is: what would kill a human may not kill a cockroach (and visa versa in some cases).  Freezing kills specific parasites present in raw fish, but it doesn't kill Listeria Monocytogenes, it just slows down the growth rate. Depending on the food being manufactured, multiple kill steps may be used to address different hazards in the production process.

What Happens When You Don't Use a Kill Step

Almost all food production operations use a kill step. The reason is because we don't know the preexisting microorganism counts when we receive a product in our facility. For example, we don't know whether the vegetables that we serve raw had safe or unsafe levels of E. Coli in them when they were purchased from our supplier.  Even if our process implies good food handling practices and low bacteria growth, we still may be putting our customers at risk because our supplier did not take precautions. This graph explains the risk we take on when we don't have a kill step:

It's impossible to know the level of bacteria growth in a purchased ingredient without conducting expensive lab tests. What we can do is choose reputable suppliers, take the temperature of incoming deliveries to confirm they weren't mishandled in transport, and include a kill step in our production process. By including a kill step in our process, we are not relying on our suppliers to have a 0.00% error rate.

In order to eliminate that risk, we include a kill step so we know our food is safe to deliver to customers, even if we received unsafe products from a supplier.

So What's the Kill Step in My Process?

Before you pick a kill step, you need to be aware of what specific microorganisms are found in the foods you produce. The good news is that specific types of harmful bacteria only exist in specific food groups, so if you make raspberry jam, you don't need to worry about bacteria that lives in shellfish. You can look up what types of bacteria exist in the food you produce in this FDA Training Manual on page 485-486.

Once you know what the hazards exist in your process, you can investigate what is an appropriate kill step and implement it.

Do you use a kill step in your production? Comment below

More on FDA REader

Resources

Guide to pathogenic bacteria in food from the FSPCA Manual

FDA Draft Guidance for Preventive Controls

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