Task Group on Warewashing Equipment Teleconference Meeting Summary. July 27, 2011

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1 Participants Joel Hipp (Hobart Corp), Moe Gendy (Champion Ind.), Wes Nelson & Jeff Ellingson (EcoLab), Tony Gagliardi (Consultant Public Health), Chris Winkler (Jackson MSC, Inc), John Hockaday & Kirk Northcutt (Auto-Chlor) & April Gravelle (Manitoba Health), Todd Stephens (South Carolina Department of Health), Russ Payzant (American Dish Service), & Mike Kohler & Lorna Badman (NSF). Action Items: 1. W. Nelson will check on the alkalinity issue and report 2. J. Hipp will contact FDA to determine if they have specific organisms in mind or if the comment is more general in nature. 3. J. Hipp will reach out to the FDA to determine how they will move forward with the Food Code. 4. J. Hipp will communicate with the FDA to determine a day the FDA can participate on a teleconference. 5. M. Kohler & J. Hipp will develop language for open tanks. Discussion J. Hipp welcomed everyone. L. Badman read the anti-trust statement and took roll call. The TG reviewed the May 4, 2011 summary and no modifications recommended. Soil Load Test W. Nelson informed the TG that the testing is currently being conducted. The testing should be complete within the next 4 6 weeks. A report or information will be given to the TG for review. The food soil in ASTM D is being used. It was noted that a 2009 version is available. EcoLab will evaluate the differences between the 2 tests and make modification accordingly. A note will be included in the report on whether the test differs. The TG agreed with the approach being used. The following variable are being varied: detergent concentration ( ppm); food soil concentration ( ppm) 4 or 5 points in the range are being selected; rinse flow rates standard rate and less than the standard rate; and evaluating glasses (NSF soil removal test is being used) for passing results. EcoLab will check on the alkalinity of detergent. Reduced minimum temperature 1

2 L. Badman researched the history of the temperature requirements in NSF 3 with very little rationale for the temperatures chosen. The TG decided to discuss the FDA s concerns. NOTE Below are the FDA s statements (in italics) and the TG s response to the FDA s statements (in bold). Food Code - FDA has concerns with removing or modifying temperature limits. They may be more comfortable with adding an interpretation. An exception to a rule may be another option they consider. The FDA will need to determine the best way to modify the temperature limits whether it be an exemption, an interpretation or some other option. They would like to see the TG consider potential impacts on all machines in Standard 3. The modification will only affect hot water machines, which have varying temperatures. All high temperature machines (under counter, conveyor, rackless conveyor machines etc) need to pass the 3600 HUE test. NSF test uses the buttermilk which reacts differently at different temperatures. High temperatures will help to break down soil such as fats and oils. When dual sanitizing machines are tested for soil removal, only the low temperature version is tested, not the high temperature. If the low temperature mode passes, it is not likely to fail with a reduced, high temperature version. They are concerned that this will reduce the level of protection. Are performance tests alone enough protection? A 3600 HUE is required no matter of the temperature. If temperatures are higher than they need to be, a safety factor is built into the machine but this is not mandatory. Some machines might be passing today at F but may not pass at 150 F. The performance test is still the same. J. Hipp does not believe this is a health risk. A lower temperature might miss a level of organism reduction. Some organisms require a higher temperature to kill. Indicator organisms might not be inactivated at lower temperature. The HUE is cumulative. A kill chart demonstrates the higher the temperature the better the kill. The Standard currently allows a one 2

3 temperature machine final rinse at 165 F. The decision needs to be based on scientific data. Organisms may have changed. J. Hipp will contact FDA to determine if they have specific organisms in mind or if the comment is more general in nature. It was suggested that research be conducted to find out where organisms have caused an illness relating to dirty dishes. It is difficult to link illness to dishes. Food borne illness is under reported. There are no examples that dirty dishes make someone sick, contaminated food can be linked. The TG should ask what constitutes a good standard. Are there some things that are necessary and some that are not? The Standard is good and by lowering the temperature it is believed it will not change. The machine needs to be marked appropriately and pass the requirements in the Standard. This will help to maintain consumer protection. The performance test is the benchmark. Reason statements are included in the Standard when balloting. An informational Annex could be added to the Standard explaining why the modifications were made. NSF 3 was a specification document (time and temperature) not a performance Standard. The Standard changed in the 1990s. A good standard constitutes if the minimum requirements are enforced on the certified equipment and serves all the stakeholders involved. This is a big step. The TG agreed. It will be a big change, especially for regulators. What is the history behind the minimum temperature requirements? The TG has previously discussed this topic. With the potential of taking away a level of protection, should something be added as an enhancement? J. Hipp doesn t believe any enhancements are needed. The 3600 HUE (less is required for pasteurization) creates a built in enhancement (safety factor). What is 3

4 being gained at a higher temperature? A higher requirement should be needed for milk since milk is for human consumption. A food borne outbreak has not been traced back to dishes. The 3600 HUE is still required. The request is based on lower temperatures. It appears the TG needs to be negotiating. If a requirement is removed then one has to be added. This should be based on science and not negotiations. Machines are not one that needs to be higher maintenance. Owners do not place importance on maintaining the machines. It takes constant supervision to maintain the temperature. Restaurants have been closed due to issues with the machines. The machine is not operating if the machine is not at temperature. Enforcement is taken based on field test. If all the machines were at F a burden would be removed for those involved. The goal is to save energy not flexibility on the field. Will the reduction in tank temperatures affect the washability test? Many machines are dual sanitizing machines and the washability test is done at the lowest temperature mode ( F). A high temp machine ( F) taken to a lower temperature ( F) will not have an issue. The regulatory community has concerns regarding the theory of reducing the requirements whereas the industry does not. It was suggested the temperature achieved in the field was 160 F. It was suggested to create a pamphlet on testing warewashing for the regulatory community. The State of Michigan has a copy of pamphlet. The pamphlet still exists and is available through NSF. M. Kohler will look into having it posted on the NSF website. J. Hipp will reach out to the FDA to determine how they will move forward with the Food Code. It was suggested that the temperatures be reduced and not eliminated. Lowering the temperature minimum would serve everyone. The new temperature would need to be based in science. The TG was reminded that the surface of the wares is lower than the minimum temperature required at the manifold. J. Hipp will communicate with the FDA to determine a day they can participate on a teleconference. 4

5 Open Holding tanks T. Stephens submitted an issue paper regarding open holding tanks (see FE ). This design has been used in Europe and is starting to be sold in the US. These machines have a holding tank. These tanks contain rinse water. The top of the tanks are not covered. Contamination from debris, mold, insects and/or vermin is the concern. The tanks cannot be visually inspected and not accessible for anyone other than a service person. T. Stephens would like the open to be readily accessible without the use of tools. A perforated screen cover would work. The operator needs to be able to maintain the tank. The open reservoir on top of the machine needs to be accessible. There is an opening at the back of the tank. If a tank can be purged, no vermin can get in, T. Stephens would be happy with that solution. Water could be held in the tanks for several months like shut down or break. A drain in tank would allow the tank to be emptied. A screen cover, perforated cover or a hatch cover over the opening. With an air gap, the screen itself could prevent the flow. If something accumulates inside the air gap, the air gap could be foiled. The tank is open to the air. If the air gap fails there could be contamination. Some TG members could not see this being an issue. Anything on a dishwasher that is not wiped down is going to get dirty. There are particles in the air. These particles could get on the air gap. The goal is to minimize contamination. The air gap needs to be accessible for cleaning. A hatch is more viable because the operator can clean. General requirements could be added such as: The final water reservoir shall have a drain, be readily accessible and easily cleanable and have a cover. It was suggested that instructions could be included in the installation and instruction manual for cleaning these tanks. This design is uncommon and the operator might not know it needs to be cleaned. A picture of this type of unit will be distributed prior to the next meeting. M. Kohler & J. Hipp will work together to develop the language. The next teleconference will be scheduled when the action items have been completed. 5