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WHITE PAPERImprove Plants for FSMA Compliance and SafetyWITH COSTEFFECTIVE ELECTRICAL SOLUTIONSThe Food Safety Modernization Act (FSMA) went into effect in September 2016 and is one of the most sweeping reforms of food safety regulations in decades. Under the new FSMA rules, food and beverage processing facilities must commit to tighter safety controls, greater documentation and continuous safety improvement across their entire enterprise. These new guidelines cause many facilities to implement entirely new systems for not just meeting the standards, but in hopes of exceeding them. Plant electrical wiring systems are easy to overlook, but integral to any processing facility and its safety. Stainless steel systems, watertight electrical devices and new equipment embedded with antimicrobial additives provide a range of cost-effective and easy-to-implement plant safety improvements.

OverviewEach year an estimated 48 million Americans are stricken ill as the result of one food-borne pathogen or another. Common examples include listeria, E. coli and salmonella. Up until the 1990s, most outbreaks were discovered consistently in the same geographic location. For instance, groups dining together might share a food dish and all become ill. Today, thanks to forensic technology, scientists can better track the fi ngerprints of food-borne bacteria. Cases are uploaded into a common database, enabling investigators to link disparate cases of illness by fi nding bacterial matches. And, in many instances, rather than being a case of spoiled salad at a picnic, it’s the result of contamination at a food plant. ConAgra recently agreed to pay a record–setting $11.2 million to settle allegations that the company shipped peanut butter contaminated with salmonella under its Peter Pan brand and Walmart’s Great Value label several years ago. The cost of contamination goes well beyond legal settlements. Recalls and production stoppages are disruptive and cost implications ripple throughout the food supply chain. For ConAgra, that number ended in hundreds of millions of dollars. In the case of Columbus, Ohio-based Jeni’s Splendid Ice Creams, pints of the company’s ice cream were found with listeria monocytogenes, requiring a recall of over 265 tons of ice cream. All production came to a halt. It took more than three weeks after the recall for the company’s ice cream stores across seven states to reopen. Food safety issues like those at ConAgra and Jeni’s are costly in many other ways. They also erode public confi dence. According to a recent Harris poll on food recalls and consumer confi dence, more than half of surveyed consumers say they would at least temporarily switch food product brands after hearing of a recall. Nearly 20 percent state that they won’t come back at all. These costs are far-reaching and highly impactful, severing trust between a brand and its consumers that can take years to rebuild. Stopping contamination at its source is paramount for every food and beverage processing plant. {

The enactment of the Food Safety Modernization Act (FSMA) marks a big regulatory shift: one that mandates companies take a more proactive approach to food safety rather than waiting for an outbreak to trigger a frenetic cleanup response. Rather than looking at FSMA as punitive or burdensome, the new rules should be viewed with an eye towards improving the industry: creating more effi cient plants, safer products and better profi t margins in the long run. Even small portions of the new regulations would likely have prevented some of the plant shutdowns and foodborne illness outbreaks in recent years. At a minimum, they might have allowed the companies to act more hastily in implementing a recall.FSMA will increase the requirements for food and beverage manufacturers to be positioned to prevent these events. And, if they do occur, each facility will have a plan in place for a quick response. The FSMA gives the Food and Drug Administration (FDA) broad powers to monitor safety and compliance. These powers include:• Increased inspection frequency• Expanded access to records• Ability to suspend registrations• Enhanced product tracing• Ability to monitor mandatory recalls}Overview (CONTINUED)Monitoring Safety & Compliance}

What is FSMA? The Food Safety Modernization Act (FSMA) requires that food and beverage manufacturers prove that their operations are running with proper product safety measures on an ongoing basis, rather than merely becoming compliant after a safety violation. Although signed into law in January 2011, the FDA spent the last four years writing, reviewing and fi nalizing the regulations. The general compliance period for Preventive Controls for Human Food went into effect in September 2016 and includes four key areas:FOUR KEY AREAS1PREVENTIVE CONTROLSFor the fi rst time, the FDA has a legislative mandate to require comprehensive, prevention-based controls across the food supply to prevent or signifi cantly limit the likelihood of problems. For many companies, this will require substantial investment in hazard analysis and a new or expanded food safety plan.2INSPECTION & COMPLIANCEMonitoring compliance is key to the new legislation, which intends to hold the industry accountable to its responsibility to produce food and beverage in safe environments. The FDA is committed to applying inspection resources in a risk-based manner and adopting new and innovative inspection techniques. 3IMPORTED FOOD SAFETYThe FDA has new tools to ensure that imported foods meet U.S. standards and are safe for consumers. Importers must verify that their foreign suppliers have adequate preventive controls in place to ensure safety, and the FDA will be able to accredit qualifi ed third-party auditors to certify that foreign food facilities are complying with U.S. food safety standards.4RESPONSEThe FDA has mandatory recall authority for all food products. In addition, it has expanded administrative detention of products that are potentially in violation of the law and suspension of a food facility’s registration.

HAZARD ANALYSIS AND RISK-BASED PREVENTIVE CONTROLS PLAN A key component of FSMA is the requirement that all food and beverage facilities implement a Hazard Analysis and Risk-Based Preventive Controls (HARPC) plan. This provision mandates that facilities have a plan in place that includes these steps:STEP ONE: IDENTIFY HAZARDS The facility must evaluate hazards that could affect food safety and identify what preventive steps or controls will be put in place to minimize or prevent the hazard.STEP TWO: RISKBASED PREVENTIVE CONTROLSFacilities need to develop and implement a series of risk-based controls at the critical points of the manufacturing process where the identifi ed hazards must be prevented or minimized to ensure safety of the food.STEP THREE: MONITOR EFFECTIVENESSHARPC requires that a facility implement a monitoring program that continually evaluates and records the facility’s control measures to determine whether the preventive controls are working.STEP FOUR: CORRECTIVE ACTIONSIf deviations occur on the control measures, they need to be identifi ed and corrected.STEP FIVE: VERIFICATIONS Facilities are required to include verifi cation that their HARPC plans are operating correctly. STEP SIX: RECORDKEEPINGIt is mandatory that facilities maintain documents and records related to their food safety/prevention control system for at least two years.STEP SEVEN: REQUIREMENT TO ANALYZEUnder HARPC, a facility must reanalyze its plan whenever a signifi cant change might increase a known hazard (or at least every three years).

Electrical Systems Present Opportunity For Improvement It’s safe to say that most facility managers and plant engineers in the food and beverage industry have had food safety at the top of their to-do lists for quite some time. The difference now is the federal government mandate requires them to commit to a standardized program per the Hazard Analysis and Risk-Based Preventive Controls (HARPC) plan.Building a new plant from the ground up with food safety in mind is in many ways a much easier task than upgrading an older plant, despite the cost. The challenge for many in the industry is that there are more old plants than there are newer ones. This is a key pressure point for plant and facility mangers the need to make ongoing improvements to food safety in their facilities, whether old or new. A good place to start when looking for areas to improve is the electrical systems. A thorough review of a facility’s electrical wir-ing systems can reveal numerous opportunities for plant managers to satisfy the HARPC pro-vision of the FSMA and implement risk-based preventive controls that improve safety and minimize hazards. Advances in electrical systems, including stainless steel cable management systems, wiring devices with embedded antimicrobial additives and watertight plugs, connectors and safety devices, provide food and beverage plant managers with a wide range of options to make cost-effective incremental improvements to their plant’s food safety plan. These improvements are not only thoughtful of the FSMA regulations, but considerate of the broader future of food and beverage processing and its safety, effi ciency and fi nancial growth. }

Antimicrobial Wiring Devices Provide Stronger Protection Many standard mandatory safety protocols, like chemical washdowns, are simply not enough to guarantee reliable, long-lasting antimicrobial protection for a facility’s electrical wiring devices and equipment. As a result, a plant could be harboring dangerous molds and bacteria that could pose a signifi cant risk. One way to reduce the risk of dangerous molds and bacteria to a production facility is using antimicrobial watertight wiring devices. HOW CAN ANTIMICROBIAL WIRING DEVICES HELP? 1INHIBITORS STORED INSIDE OF THE PRODUCTWhile many facilities simply apply antimicrobial protection to the surface of their electrical cords and components, the use of antimicrobial industrial wiring devices goes beyond this method by storing antimicrobial growth inhibitors directly inside the products themselves. 2 COMBATS CONTAMINATION ON ALL SURFACESAntimicrobial wiring devices feature antimicrobial additives embedded into all polymer components, ensuring that microbial growth is suppressed throughout the device, whether on all outside surfaces or hidden on the INSIDE surfaces. 3SLOW RELEASE FOR LONGER PROTECTION The additives are then gradually released to the surface, providing continuous, long-lasting protection against the growth of bacteria, molds, mildews and fungi.HOW EMBEDDED ANTIMICROBIAL PROTECTION WORKS Antimicrobial protection essentially requires that the growth of bacteria, molds, mildews and fungi on treated articles and components is inhibited, thus making the surface area undesirable for microbial population. When microorganisms appear on the surface of a protected wiring device, antimicrobial compounds make contact with them and disrupt the microorganisms’ attempt to live and multiply. EMBEDDED ANTIMICROBIAL ADDITIVESDANGEROUSMICROORGANISMS

To ensure sanitary conditions, washdowns are required in food processing environments. The washdown process, while scrubbing surfaces of bacteria, also exposes electrical equipment to high- pressure water streams, condensation and harsh chemicals. This rough, corrosive environment can shorten the life of the electrical products and may compromise the entire electrical system by creating safety issues, unreliable connections and the potential for lost productivity. New product advances in watertight, rugged plugs, connectors and receptacles that are high-pressure rated ensure more reliable power delivery in these highly sensitive areas. And, many of the newer devices currently available use multipoint sealing systems to protection connections from water and contaminants.Safety switches, which are now available in Type 316 stainless steel to further withstand exposure to harsh environments, mechanical interlocks and pin and sleeve devices are all product categories that have seen signifi cant improvements in recent years. The use of non-conductive, watertight, corrosion- and heat-resistant enclosures provide greater protection for the work environment and food safety. }Watertight Connections }

ABOUT LEGRANDLegrand is a global specialist in electrical and network infrastructure solutions. Legrand transforms spaces where people live and work and delivers access to power, light and data to millions of spaces around the world.LET US KNOW HOW WE CAN HELP YOU:legrand.us/project-helpFIND A DISTRIBUTOR OR REP:legrand.us/where-to-buyStainless Steel Cable Management Systems Offer Signifi cant Advantages To Food Safety An Open Design is Easier to Clean When it comes to preventing contamination, conduit can cause a host of problems for a food or beverage plant. Conduit systems draw in moist air, where it’s trapped and condenses. Moisture can also build up in the system and drain into electrical enclosures, causing equipment deterioration or failure. The moisture collected in the conduit or enclosures can also lead to bacteria growth, which can’t be removed or cleaned. Worse yet, the bacteria trapped in the conduit can also leak into the physical plant through electrical enclosures each time the enclosure is opened for maintenance. An open cable tray wiring system provides highly desirable safety features not offered by conduit. The cable tray is not an enclosed system – the wire is completely exposed, yet safely secured in the tray -- so problems due to moisture condensation and accumulation are not a factor. The open, wire mesh design of a cable tray system addresses three main concerns of every food or beverage processor: food contamination, personnel safety and equipment/facility cleanliness.A stainless steel cable tray offers good corrosion resistance against water and food products. The stainless steel also makes it particularly suitable for the chemical and food industries and environments containing halogen (fl uorine and chlorine).The open design of a wire mesh tray is easier to inspect for dirt and contamination than conduit. And it can be installed with the tray opening up or to the side. Side mounting the cable pathway reduces the surface area where dust and debris can settle. In either case, the open design makes it easy to inspect and clean with simple wash down procedures. In addition, a wire mesh tray with a passivated stainless steel fi nish meets the industry’s demanding needs for non-corrosion and cleanliness in accordance with National Sanitation Foundation (NSF) directives.Replacing conduit with cable trays represents a signifi cant opportunity for plant managers, as they are required by provisions of the FSMA to continually seek and document new ways to further improve food safety at their facilities. NSF-approved cable trays are quick and easy to install and modify, making them a simple and cost-effective retrofi t in most food and beverage plant environments. A review of a plant’s electrical wiring systems can uncover many opportunities to advance food safety, enhance workplace safety and improve plant productivity. And perhaps most importantly, at least in the context of the new FSMA requirements, a review of a plant’s electrical wiring systems will provide plant managers and engineers with cost-effective ways to promote ongoing food safety improvement and compliance. {{