1. ICE MACHINE CONTAMINATION:
HOW TO INSPECT PROPERLY AND WHY IT IS IMPORTANT
July 13, 2017

2. About the IPIA
The IPIA represents more than 400 packaged ice manufacturers and distributors throughout the world.
The IPIA mandates as a prerequisite to association membership that member producers demonstrate compliance with Packaged Ice Quality Control Standards (PIQCS).
PIQCS was developed by our membership 15 years ago and is based on the FDA's Good Manufacturing Practices, IPIA made specific to packaged ice and includes HACCP (Hazard Analysis Critical Control Point) and finished product testing. PIQCS will be FSMA compliant
Our Mission: “To enhance the quality of the sanitation of packaged ice and all ice through improved manufacturing practices, the education of public health officials, consumers and the promotion of better surveillance of ice manufacturing facilities.”

3. The IPIA’s #1 goal: ICE is food
The industry wanted to improve safety
In 1998 PIQCS (Packaged Ice Quality Control Standards) program first created
In 2002 the Association adopted standards as requirement for membership. Annual inspections begun
In 2004 NSF partnered to update standards and conduct audits
Initially HACCP was voluntary
In 2011 HACCP became mandatory
Inspections are conducted annually of manufacturing plants
FSMA compliant including supply chain control
The bar has risen dramatically over past decade! 3

4. Why you should be concerned about packaged ice
Contaminated ice has the potential to cause a large Food Safety Problem, endangering the welfare of the consumer.
The US Food Code lacks specific ice sanitation standards (unlIke botted water) and oversight at the provincial or federal level.
Beyond food safety, packaging and labeling issues widely exist.
Independent Studies show major issues exist for packaged ice.
Consumers are not focused on differentiating brands of packaged ice and many believe Freezing kills bacteria.
As you will hear, we are advocating for federal public health professionals to be proactive so we can prevent what happened to the spinach, tomato and peanut butter industries, from happening to the packaged ice industry 4

5. Bacteria may sleep but usually don’t die
2010 IPIA © NSF 2010
Version 1.0 – Nov 2, 2010
Bacteria may sleep but usually don’t die
Freezing water only slows down the rate of bacterial growth!
Freezing may kill some bacteria, yeasts
and molds but most survive.
At 41ºF growth usually slows down
Below 32ºF they go into “hibernation”
or form resistant cells (spores)
Listeria keeps multiplying down to 28ºF
Freezing does not affect the toxins produced by some bacteria (staphylococcal enterotoxin and botulinum toxins).
Salmonella & E.Coli can survive, repair themselves and multiply after thawing.
Freezing water only slows down bacteria!
Bacteria, yeasts and molds do not die!
At 41ºF bacteria slow down
Below 32ºF they go into hibernation
Listeria keeps growing down to 28ºF
0ºF for several weeks still leaves >10% bacteria alive
Salmonella & e.coli will survive, repair themselves and multiply after thawing
It goes to sleep, it doesn’t die! 5

6. Recent Ice Contamination incident
A BBC investigation recently found fecal bacteria contamination at coffee chains in England.
43% of Samples from Costa Coffee, Starbucks, and Caffe Nero contained “concerning” levels of fecal coliforms.
Tony Lewis of the Chartered institute of environmental Health said: “The bacteria found are opportunistic pathogens - the source of human disease. These should not be present at any level - never mind the significant numbers found.”

7. Ice related outbreaks Earliest to most recent:
1983; 90 persons ill, 14 hospitalized in Iowa
Salmonellosis, alteration of plumbing during restaurant renovation
1985; 17 ill residents St. Louis nursing home
E. coli O157:H7, ice machine considered source
1987; 5,000 persons ill in Pennsylvania from commercial ice plant’s well water contaminated by flooding of the conestoga creek
Norwalk-like viral gastroenteritis
1991; Salmonella enteritis
infected food handler at a fast food restaurant handling ice bare handed
1994; unknown number ill in Florida
Campylobacter outbreak in Tampa

8. Ice related outbreaks, part 2
2005; Ice contaminated after production, feces found on floors of facility
CNN 2005: Anderson Cooper report shows locations in 4 of 5 cities are selling contaminated ice.
2006; Tampa science Fair project. Fast Food Ice dirtier than the toilet water
2012; Canadian study by CBC Marketplace found traces of coliform bacteria on ice machines in each of the six hotel chains tested. One test found a non-deadly strain of E. coli bacteria.
Other revealing reports were also included:
Cites 59 drillers sick with e. coli from contaminated ice in 1999
Half of ice in London bars and pubs in London was contaminated

9. Why the IPIA is different: PIQCS Program
PIQCS Good Manufacturing Practices based on US federal GMP’s made specific to ice manufacturing. Includes Personnel, Plants/Grounds, Equipment/Utensils, Processes/Controls; Storage/Distribution
Sanitation SSOP’s
Adherence to FDA and EPA Drinking Water Standards
Recall Plan
Data/records Management Program
Pest Control Program
Date/lot coding for traceability
Finished Product Testing
Coliform - Using Membrane Filtration Method
Less Than 1 Organism Per 100 ml
Fecal coliform tolerance zero
Total Plate Count - Less Than 500 Colonies /ml
HACCP

10. Where are consumers buying Non-PiQCS Compliant ice?
Wholesale manufacturers – selling to retail
Not operating under PIQCS
Retail establishments producing and packaging ice
Retailers NOT SUBJECT TO FSMA, just generic food code
Retail includes convenience stores, gas stations, fast-food services, liquor stores, and self-service vending machines
Poor labeling – High recall risk factors.

11. Problems associated with retail-produced packaged ice
2010 Joint MABWA & SEBWA © NSF 2010
Version 1.0 – March 3, 2010
Problems associated with retail-produced packaged ice
Packaged ice coming from retail sites lack the food safety programs of manufacturing plants.
No HACCP
No GMPs or SSOPs
Employee turnover is high
Food Safety Training is minimal
Packaging is ad hoc and imported ice bags especially Not necessarily food grade
May use draw strings; not sealed
Ice makers are typically appliances; not designed and maintained as food manufacturing equipment

12. Regulations ARE not clear
Ice has no 21CFR “Standard of Identity”; no separate GMP requirements.
FDA treats packaged ice as food on the basis that it is engaged in interstate commerce. It is inspected and monitored as a food manufacturing plant.
FDA regulates other businesses that bag ice on their premises or use stand-alone vending machines differently; categorizing them under the food service code, leaving regulation and enforcement to the states.
Thus, packaged ice made in c-stores, gas stations and restaurants are not currently accountable to federal GMP requirements for food manufacturing much less FSMA.

13. 2010 Joint MABWA & SEBWA © NSF 2010
Version 1.0 – March 3, 2010
Why labeling matters…
Studies show how closures impact quality of packaged ice (see forthcoming slides)
Bags should be sealed in a way that precludes post-production contamination.
Should an outbreak occur, how do you handle a recall?
The manufacturer’s name, location and contact information should be on each bag.
Every bag should have a production code traceable to ingredients and distribution
… no drawstring closures
… name & contact information for manufacturer missing 13

14. Lack of proper regulations lead to insufficient inspections and a compromised food product
Due to packaged ice being labeled “low risk” inspectors rarely pay the attention to packaged ice manufacturers that is deserved.
Lack of proper regulations give consumers a false sense of security.
Improved regulations would renew the inspector’s focus on packaged ice.
Inspectors can be advised on what to look for when inspecting a wholesale and retail ice machine. 14

15. The SCIENCE BEHIND ICE IS FOOD
INDEPENDENT STUDIES CONFIRM THE REASON FOR CONCERN
2014 University of Georgia Study
2016 University of Cal-POLY Study

16. UGA Study – by the numbers
13.6% contained one of the two potent contaminants E. Coli* and enterococci.
71% contained heterotrophs – indicators of bacterial growth
38% fell outside the acceptable range for PH in the chemical analysis
37.2% contained an unsatisfactory level of coliforms – significant enough to indicate sanitation problems.
1 sample (out of 250) contained Salmonella – a deadly bacteria seen recently in many food-borne outbreaks. 16

17. UGA Study - Overview 17

18. 2016 Cal Poly Study Published in Journal for Food Protection
56% of on-site packaged ice samples were shown to be positive for yeasts/mold growth
19% of packaged ice samples produced on-site did not meet the IPIA/PIQCS TPC microbiological standard of less than 500 total plate counts per ml and an absence of coliform/E. coli
34% of non-IpiA ice samples identified staphylococci (the source of staph infections), implying contamination from packaging workers
100% of bags manufactured by ipia showed consistently acceptable rates 18

19. More Bad News for Consumers
Over 70% had coliforms present and 36% were unsatisfactory

20. Study Conclusions
“Overall, the on-site packaged ice samples showed poorer microbiological quality than the manufactured ice which may be attributed to contamination from the environment and food handlers, as well as lack of quality controls using the PIQCS or other processing standards”
California State Polytechnic University, Pomona, CA

21. Conference of Food Protection – Ice Maker Cleaning and Sanitizing
Served on CFP Ice maker Cleaning and Sanitizing committee and currently serving on CFP CIP (Clean in place) committee. Final report highlights:
many OEMs offer limited cleaning instructions and in some cases they do not indicate that the cleaning methods described must be followed by a sanitizing step. no test data or field studies to support the recommended cleaning and sanitizing procedures, frequencies and chemicals utilized were provided.
The Ice Machine Cleaning and Sanitizing committee uncovered a significant discrepancy relating to cleanability of food contact surfaces. The FDA Food Code requires FOOD EQUIPMENT with inaccessible food contact surfaces that depend upon CIP processes for effective cleaning and sanitation to be designed to enable inspection access points for verification purposes, so it cannot be readily determined when cleaning is required.
Current ice machine designs which passed the existing ANSI standards are not always accessible for cleaning and inspection and may require tools that are not commonly available to the cleaning personnel or inspectors.

22. CFP - Ice Maker Cleaning and Sanitizing
FIVE jurisdictions provided inspection records for 2014 associated with ice machines:
A. 3,763 violations were identified related to mold or soil accumulation in the ice bin, bin walls, ice chute, door, and/or gaskets.
b. 1,427 violations were identified related to the ice scoop, personal items being stored in the ice bin, and chemicals being stored over ice.
c. There were no violations regarding the internal components of the ice maker thus indicating they are not inspected…the dirtiest part of the Ice machine
2013 FDA Food Code states that Equipment should be cleaned at a frequency specified by the manufacturer. Based upon the number of cleaning violations noted in our survey and the lack of guidance provided by manufacturers regarding cleaning frequencies we propose that simply cleaning ice machines based on a manufacturer’s recommendations may be inadequate

23. CFP - Ice maker Cleaning and Sanitizing
The committee could find no information on line from Ice Vending Machine Manufacturers on recommended cleaning frequency, procedures or chemicals used.
OEM’s cleaning frequency recommendations ranged from cleaning annually to quarterly, to “when dirty”.
State health environmentalists serving on the committee acknowledged dirty ice machines are more common than you think and a concern.

24. Inspection Issue #1: License and Locations
An establishment where ice is packaged for human consumption should be permitted or licensed by the state or local regulatory agency.
Ice makers must be located in an area that can be easily and frequently cleaned, has low traffic, and is free of airborne contamination
Ice bins must be securely closed at all times except when packaging or removing ice. Access is to be limited.

25. Inspection Issue #2: Source Water
Ice must be made from source water that meets EPA drinking water regulations. If municipally treated water is not available, the private water supply permit must be on file and annual chemical/physical testing to EPA regulations of the source water conducted.
Ice machine water supply must be separate from operations water, i.e. toilet facilities. If not separate, then the ice machine water supply must be protected against potential back flow by a suitable back flow prevention device.

26. Inspection Issue #3: Personnel
Employees must be trained in the sanitary procedures for making and packaging ice. Procedures should be posted.
Employees must follow proper hand washing followed by the use of sterile, non latex gloves when manually packaging the ice. Hair and beard restraints should be worn.
Employees with disease in communicable form must not package or handle ice.
Inspect for insect or rodent infestation under and around ice maker. Pest control chemicals are to be properly labeled and stored in a separate area from the ice manufacturing operation.

27. Inspection Issue #4: Sanitation
Food-contact surfaces (i.e., ice machine, ice bin, scoops) must be maintained in a sanitary condition and must be cleaned and sanitized on a schedule and frequency that prevents accumulation of mold, slime, fungus, and bacteria.
Ice must be processed and packaged using methods that preclude contamination of the product and the packaging
Packaging, closures, non-nested transfer buckets, and the packaged product must be stored at least 5 inches off the floor and protected from splash, overhead dripping and other contaminants.
Food Contact utensils, i.e. ice scoops are to be sanitized before each use and stored sufficiently when not in use to preclude contamination.

28. HOW YOU CAN HELP
Attention to the issue will improve the food safety of packaged ice and all ice
Holding retailers accountable with documented cleaning and sanitizing performance and frequency would help significantly.
Periodic coliform and TPC testing of the Ice.
Training of inspectors to disassemble the machine to view the internal components. 28

29. Thank you! Safeice.org Packagedice.com Chris@packagedice.com