Webinar: Proactive vs Reactive Food Safety

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In October 2024,Bryan Armentrout, the Founder of the Food Leadership Group, and Will Eaton, the VP of Sales and Marketing at Meritech, held a webinar focused on the importance of proactive versus reactive approaches to food safety. Bryan provided information on the FDA's environmental monitoring program and how proactive approaches can result in more favorable audit results. Will spoke to proactive methods of dry footwear sanitation that can reduce the risk of outbreaks and provide the facility with significant cost savings. Check out the full webinar above!

Transcript:

 Bryan Armentrout: We appreciate you being here today. So our theme of being proactive versus reactive is very important in maintaining food safety. And when we see these major crises and food safety issues going on, it's a result of being too reactive. We need to move forward as an industry and get more into the proactivity and make sure that we understand what's going on out there in the marketplace.

So with that. We're going to dive into what we're talking about here today, which is FDA's environmental monitoring program strategy and what you need to know in your company and specifically in your facilities to manage this type of risk. So within our agenda today, we're going to look at three main areas.

We're going to look at what is FDA's regulatory approach, what's their focus, what's their methodology that they're using to this and what activity is going on in the marketplace right now that you need to be aware of. The next piece, we're going to go into an environmental monitoring case study so you can see exactly how this information is applied and importantly, it's not necessarily what you're doing, but also what you should not be doing.

I'm also going to show you a little bit on a warning letter of what you need to be looking at there to make sure that you understand what FDA is looking for. And with this information, it's always very important to take what you learn and apply it. So we're going to give you some ideas for next steps around how you can then take this case study and apply this directly into your business.

So with that, guys, let's dive in here. So FDA, what is their regulatory approach? And we've seen this very much in recent years. And the graphic that I have listed on here is an approach that FDA is taking relative to enhanced traceability. So we see guidance documents, we see information that's put out in the marketplace.

And in the case of. Enhanced traceability. FDA is really figuring out what is the correct forward path for this because as we know, very complicated process. So in a lot of times, this is a start and stop process that you need to be aware of relative to how you're being regulated in the marketplace.

So what is FDA's focus for 2024? Well, as we all know, the new era of food safety has been very high on the agenda within FDA and in this graphic that we're all very familiar with, we have four main quadrants, traceability, outbreak response, retail modernization, of course, food safety culture, and Frank Giannis, who was at FDA, was very instrumental in getting this program put in place.

But as we know, Frank is no longer there. He has been replaced with this gentleman, Jim Jones, who is the deputy commissioner of the new group of FDA human foods. So FDA is going through a very large reorganization right now and deciding the correct path forward. And they have taken a very deliberate step to focus on food and separate it from the other areas that they're responsible for regulating, such as drugs.

So what do recalls look like for this year? Keep in mind with this data that FDA ends their fiscal year at the end of October. So this data is not yet quite complete, but this is the most information that is current from FDA. Okay. So you can see for the recalls in the top graph in the green that FDA had less recalls during COVID, and then that bounced back.

And so we're settling around the 1800 mark or so. But when you look at the year so far for 2024, this is what I find interesting. Here is the level of class one. That is the serious risk to human health that FDA has instituted here. We have more data that's need to be collected for October. So this number is only going to go up.

So FDA has been focusing on class one recalls much more than they have in the past. So what type of inspectional observations, right? So you have your recalls where products being taken out of the marketplace or withdrawn. You also have then what is FDA seeing in the production facilities? What are they writing up food plants for?

When it looks at a particular production facility far and away here, you see number one is foreign supplier verification. Well, Brian, we're talking about environmental monitoring today. Where is that? In this graphic, and that's what's interesting with this FDA doesn't specifically write you up for EMPs unless they're listing at as a reason and a warning letter under the Food, Drug and Cosmetic Act for adulteration here.

It's hidden in the detail. So all these different type of programs here have something in common. And that is, these are all preventive controls and prerequisite programs, integral parts of your food safety plan. So a big chunk of what you need to keep in mind with what we're talking about here today is that.

This is a system process, right? Going back to what FDA is saying relative to food safety culture and your programs and your operations within your facilities. So if you're not familiar with this book, you need to be, this is the investigation operators operations manual. This is FDA's Bible. This is what they use to train their investigators in the field to make sure that they're being consistent in how they're looking at their auditing and investigations within food production facilities.

Now it used to be that FDA would update this document. Oh, every five to 10 years or so, they've been updating this every year now. And what I have here is the current cover for 2024. And what we're looking at here today. It's how is FDA approaching environmental sampling. And as we're going through this information, I want you to think about what does my current environmental monitoring program look like versus what FDA's environmental monitoring program in your facility looks like.

And I'm willing to bet here that they're probably very different. So let's dive here and take a look at Chapter 4, which is where this information is located. So, under 4366, and I'm not going to read these slides to you, so don't, don't panic, but I do want to call out in here the information that's really salient for these particular topics.

So, when they're looking at collection of environmental and product samples for contamination with pathogens, they're saying here that your main objective as an FDA investigator is to is to prove, to prove that the establishment is operating in an insanitary manner. That is, they're producing a food product not fit for human consumption and getting the information and the evidence necessary that if a case moves forward, that FDA has the documentation that they can do that.

Now within here, they also reference 5873 around environmental sampling, which is the next piece of what FDA is looking at this. So under this, You're documenting these unsanitary conditions, and with that, They are working very, very closely with CFSAN, so the Center for Food Science and Applied Nutrition, to have a targeted approach relative to your facility.

So if you're in dairy, or produce, or any other FDA regulated industry, they already have a specific plan in mind of how they're going to be addressing what needs to be addressed in your facility. What are those vectors? What are the items that they're looking at? And they're once again emphasizing in here that it's very important for their field agents to be able to gather concise and accurate information relative to microbial concerns.

What we know is a swabathon intention to sample. This is very interesting here. In most cases FDA will not Will not let you know of their intention to sample until they are actually sampling So within an FDA investigation in your facility, there are two main visits that FDA has there's what's known as a GMP So FDA is coming in and looking at the basic operations of your plant.

Think of it as a routine visit. The next is for cause. And in a for cause situation, FDA is there for a specific reason. They have reports of consumer illness. You may be implicated in a wider recall, let's say with a supplier or things of this issue. They are there investigating a particular problem and they want to see how you're handling it.

Now, those are two are not mutually exclusive. You can go in and the FDA may be doing a GMP audit and they see something they don't like in your facility in sanitary conditions, for example, and they can escalate that. A new category here that you need to be aware of as well, FDA is also going into facilities and doing environmental monitoring just for that.

They are gathering data for the marketplace. So FDA may have a particular interest in, let's say, dairy again, and they want to get a better understanding of what type of flora are present in the plant, in the environment, that they can start cataloging and get a A good database of what's going on. As we know, with that database that FDA has with CFSAN, they have over a million samples that have been collected from plants.

So they're building this database for a linkage to consumer illnesses. You need to be very aware of that. So, they're not going to let you know when they sample. The other key part of this is, when they do this, they're going to be sampling, of course, by zones. And I think it's very important that we're all on the same page, because we have slightly different definitions of what zones are.

So let's kind of take a look at how FDA views zones. And the way that they're looking here in this middle section of information is showing that they're really looking at this from that vector analysis standpoint of how are these things being transferred from the environment to product. And that's what they're looking at as well.

Interesting point here, you'll notice on here as well. If during an environmental monitoring process, you as a company have a policy of taking duplicate samples as FDA is going around in your facility, should you do that or not? Well, keep in mind if you do, FDA is going to ask for copies of that information.

So let's say that FDA samples and finds no positive results. In your facility, but you do duplicate samples and you do find positives. Well, guess what FDA is going to be aware of those under this request. And now you have a positive environmental sampling. So you may want to relook at that program and decide if you really want to do environmental sampling during an FDA visit.

So zone one, kind of what you would think all direct contact surfaces, slicers, mixers, conveyors, anything that isn't touching is touching the food. So, they're also talking in here, and you'll see this through these different zones. FDA has two main focuses that they're looking at, and you see the little pictures here with these guys.

Listeria and Salmonella. Those are the two things that they're looking at, and in particular here, you notice that they're calling out Listeria monocytogenes specifically, and they're looking at Salmonella as the overall genus within that. So, keep that in mind as well. Well, what does FDA think a Zone 2 is?

Any area directly adjacent to a contact surface, anything that's not a Zone 1 that's close to a Zone 1. So I got some examples here. Carts, tools, scales, things that operate in your facility are going to touch, and then they're going to touch a Zone 1. So for me, a perfect example of this, and FDA loves to sample these.

Our buttons on machines. So if you have an operator that is pushing the start and stop button on a machine and then touching the product and touching the button and touching the product, that is a zone to contact surface. And a lot of times in production facilities, those PLC panels and other sensitive electronic equipment on the production floor are covered.

During the sanitation process because you don't want to get them wet. Are you going back and re cleaning those using hand methods afterwards? In most cases, probably not. So take a look at that and make sure that those surfaces are getting sanitized and cleaned because FDA is going to be looking at those very closely.

So zones three and four. So again, right, a little bit outside of zone three. Zone two is zone three. So in these areas, think corridors, hallways, areas within a large room that are adjacent, forklifts, phones, bones, right walls. They're looking at these different things. And then of course, four is everything else.

Now, the question I put to you is, as you're seeing through these different zones, FDA, not really that interested in zones three and four, they're gonna be focusing on one and two, as you'll see in the next slides. Most of the environmental monitoring programs I see that were created a long time ago, think 10 plus years, are focusing on what?

Zones 3 and 4. So if FDA is focusing on zones 1 and 2, And you're focusing on zones three and four, got a bit of a mismatch there. You don't have really good information that you can share and look at with FDA to see if there's any type of an issues. You need to start thinking about that from that standpoint.

So there's sampling strategy. Very interesting here. Every effort should be made to conduct listeria sampling when the facility has been manufacturing for at least four hours during any wet cleaning. And with shorter runs, you should at least be looking at. mid to tail end of the production run. In a lot of plants, wind is environmental monitoring take place.

Yeah. It's after sanitation. The plant is clean. The plant is pristine. Somebody goes around from the quality department, pulls a bunch of swabs from the floors. And then you think you're okay. Well, that's not as not how FDA is approaching this. As you read through this information here, they're giving more strategies around how they're going to be sampling and what they're going to be looking for.

And of course, as we know with the swab-a-thons. If they're looking at salmonella in the environment, they want at least 100 swabs. Up to 300 is preferable for listeria 50 to 100. Let me ask you this. How many swabs are you doing on a monthly basis in your plant? Should you be increasing that number? Right?

So if you're looking at this information that's on this slide, you need to start thinking about these questions as well. If FDA is following these tactics, how will you respond during, during the inspection is too late, right? If you don't know that FDA is going to be taking this strategy and these tactics to sample doing your production run, you're going to be completely taken off guard.

They're going to be taking sampling during production. They're going to be focusing on ones, twos, and threes. You also notice in this documentation, they're taking evidence via photography. What is your company policy on the allowance of photography and recording devices on your production floor? Do you have one?

You need to. You should probably talk with your company counsel on this and decide how you want to manage this and if you are going to allow FDA to take pictures or not. So read through this and look at this and say what else in this content Concerns me today because there's quite a bit in here that you need to be thinking about.

So, a lot, a lot of information here, right? Does the environmental monitoring program that you have match what FDA is doing? What is your program? Who wrote the program? How long ago was it written? Was it written 15 years ago by a quality manager who is no longer with the company? She left and went on to a new role.

Is it the right thing that you should be doing? What is that information based on? Is it obsolete? And importantly, should I change this program?

So that's the environmental monitoring piece of it. A ton of stuff going on here relative to this. And you really need to think about this in terms of change management and people. It's very important to understand the technical sides of this, but it's also the people side of it because people hate to change and.

And as Dave mentioned in the introduction here, we've had some very serious recalls that have been going on. Boar's Head is the front of mind of everybody. Ten people have died as of this recording. It's just been an absolute tragedy. And Bill Marler is at the forefront of this, and I've included a link here to this story that I'm quoting.

So, people within the company have been coming forward. The Jarrett facility has been closed permanently. Hundreds of people have lost their jobs. The sanitation individual who was working in this plant had brought in Reported back and saying, this company has no interest in fixing these things. And I'm very frustrated by this and you need to read this article.

This gentleman is very frank in these conversations. People hate change. So as you're introducing these new programs, you need to think about the people side of things, or it's probably not going to work.

So let's do a quick case study with this information and see how this can impact your company. And then as an example, we're going to use this and all of the information that you're seeing here. Was procured through research that I did on the internet. And this involves Royal ice cream company. This is a small company that was founded in 1926 in Connecticut, and they had a pretty serious recall.

And we'll take a look at this and see what you can learn from this. This is the president of the company, family owned business, third generations. James Ortefelli. And you can see him here proudly standing outside of his plant for this pose. Now as you can tell in this picture, a couple of things wrong here.

And as we're going through this, you're going to see things here. And I want you to note these in your mind as you're going through this. So here he is in his nice whites, ready to work in the plant. He has these beautiful boots on. Where is he? He's outside. He's not even in a GMP area. Okay, great. This is, this is for a photo shoot.

Well, what type of message is this sending? He did a great job on his hairnet. That looks, that looks really nice there. So with this, as I mentioned, they had a Listeria recall, a very serious Listeria recall. Fortunately, no one died, but here are a few of the screenshots of the local press that this received in the Northeast.

They supply a lot of companies, and you can see here on these slides. A lot of private label. They were manufacturing products for other companies. Now, their brands were impacted by the failures that occurred at Royal Ice Cream. A nightmare that nobody wants. So, the facility. Here's the facility. So, this is, again, in Connecticut, a relatively rural area.

And you can see from these pictures that this plant, when it was in 1926, and probably not any houses around, but you can see from these overhead views, from satellite imagery, that there's houses right next door. And you can also tell that this building was built on over the years. So as the company expanded, they would add on some new areas and all this type of fun thing.

But let's zoom in here really quickly and take a look at this. So this is the dock door and you can see the freezer there as well. You can see all the handprints on the outside from people shutting it. We're going to look at the video here in a little bit. I want you to remember the smaller door here that is next to a couple of things.

Did you see a pallet jack? With some wrap, you see a pallet laying there on the ground. You see some obvious concrete damage, and you also see a hand cart and a fan. These guys are going to show up later. So pay attention to that. You also see in the facility, a whole lot of stuff that's built up around the plant.

So obviously they're out of room here in this dry warehouse area. You see a garbage collection unit out there in the back, all kinds of areas for pests and all kinds of other things that are carrying salmonella or other type of issues. That could potentially get into the plant. You don't want this type of thing around your plant They are backed right up to the walls of the plant.

No way to inspect Now this is a video that the company posted online And with this as we're going through this I'm going to point out a few things in here. But see what else you can catch and this is always what's very important is that fresh set of eyes concept The ability to look at things that you walk by every day So as a consultant, I'll go into facilities and see things that people who are working there don't even notice because they've gotten used to it.

So what do you see in this video? So you have your ice cream coolers there, you have your rotary filler here. This guy's loading in cups. You can see his left hand, no glove. So the little dessert cups are being loaded into the tray. So this guy's loading them in. Now we have some materials that are being put on.

Everything here, handmade, right? And you can see in this room, very crowded. Lots of stuff going on in this room. So little guys come off. Okay, well he's got one glove on, and his glove, right, every single cup, his hand is going in that. So these come off again. You can see the chemicals stored in the background in the production room.

So they go over to this station. We're going to throw some, ooh, cocoa in a unapproved container. What is that, an ice cream container? So they throw this over the top. We have some clumps, so obviously that's being reused quite a bit. Maraschino cherries going on top. All right, some get on there, some don't.

They have gloves on, but as we know, just because you have gloves on doesn't mean that you're not sharing things and contaminating areas. So this guy then takes this, puts it in this cooler. Again, anytime you have a transition from cold to hot, like this, you're going to have condensation. So they're then freezing these guys in this room.

Very nice looking, right? Out comes Kurt. Alright, so far so good. There you go, so now he's going to box these up. So he takes them out, brings them over here, uses his gloved hands, To fold the box and then that's just the product, which is then broken up, goes in the boxes.

Okay. Going off to a customer in Brooklyn. All right. And we're now loading up the pallet and use that shrink wrap that we saw outside. Again, you can see all of the material in the background. Here comes our hand cart. Where was the hand cart? outside, right? So that just now came into the plant. So he's going through a side note, OSHA violation on the pallets there.

You can't have those standing up like that. And the product is sent outside, right? So within the head example, I'm just kind of hitting the high notes, right? I'm sure as you look at that video, there's other things in that video that you're going to see as well. So out of this recall, Royal Ice Cream received a warning letter and in this warning letter, you'll notice who's it addressed to.

It's addressed to him. It's addressed to Mr. Ortofelli, the president and owner of the company. Always, within warning letters, are always addressed to the senior most responsible person in the company. And this is due to the Park Doctrine. If you don't know the Park Doctrine, this is a requirement that went all the way to Supreme Court that says, The senior person in the company does not have the ability to delegate food safety responsibilities to senior, to subordinate personnel, that he maintains that responsibility.

They can't say, well, that's not my fault. The food safety person didn't do it. They are ultimately responsible and they're ultimately held in judgment according to that. So he is on the hook for this. And as you look at these videos, there's something else I want you to keep in mind. we hear a lot of times that food safety is a cost.

The average cost of a recall is 30 million dollars. Ask Mr. Ortofelli how much food safety costs. He was looking to sell his company. Would you buy this company? I wouldn't. Would you buy Boar's Head? I know lots of people that I spoke with who said I'm never going to buy a Boar's Head product again after this recall.

How much damage has been done to the consumers and the trust and the brand? Huge impact. In the industry. Ooh. All right. So lots of stuff here. What does all this mean? What should you be taking away from this? And this is the important part is with this case study, summary, food safety. We assume it, but it cannot be ignored.

Food safety doesn't cost money. It saves money and it saves lives, but don't forget the people side of things in this. Change is hard. You have to approach this in a sensible way and work with people in your company and educate them on the why. Okay. Just not the how. It's very important, and this of course then translates into food safety culture.

Put together your action plan. Apply what you have learned. Teach others what you know now, and take baby steps. You don't need to reinvent your entire program overnight. Take these different steps and look at it and say, how can I revamp my environmental monitoring program? What else can I learn from other experts in the industry to help me with this?

Prepare for FDA. They're coming. And now you have a good idea of what they're going to be doing when they come to your facility in regards to environmental monitoring. Look at case studies. I can guarantee you the people involved in these case studies didn't think it was going to happen to them. And then it did.

So what can you learn from their mistakes? Put the script on your program, completely rewrite your environmental monitoring program and look at it from the standpoint of FDA. Look at how you can mirror those programs and how you can look at that. And of course, keep up to date on developments as we had referenced earlier in, in our talk here today, FDA is constantly revising how they're looking at things are constantly changing their developments.

And they are looking at this from a proactive standpoint, not a reactive standpoint. They're going in those facilities, looking for. Environmental pathogens and linkages to products before there's a recall. And that's the correct approach. Having a recall, it's the last resort. You don't want to get to that step.

So work on everything that you can to make these activities proactive. So with that, this is. FDA's environmental monitoring strategy. And this is what you need to know to be successful within your company. Thank you very much, Brian. That was extremely informative and I think really highlights the importance of being proactive versus reactive, especially when looking at, you know, what the FDA is doing.

Will Eaton: So we're going to talk about being extremely proactive and how Meritech can help with that. So does your current plan, does your current hygiene, you know, protocols focus on preventing harmful pathogens from entering, you know, zone one, two, three, and four, just like Brian talked where the FDA is going to be monitoring.

So the equipment from Meritech can play a crucial role in enhancing your food safety and really with that proactive approach, with standardizing your hygiene protocols. So during this quick presentation, I'm going to talk about our most popular product, that's used in a dry environment. It is called the soul clean enhancement for one of our clean tech Evo hand washing stations.

this will work on sanitizing the bottom of your footwear. So it does attach. To the CleanTech^® fully automated handwashing station, which you can see in those pictures on the right, that is the white system. So the cleantech handwashing station provides the perfect handwash in 12 seconds and removes more than 99.9 percent of harmful pathogens. So when you're thinking about being proactive, there's, here's a few things that, you know, help validate not only your whole hygiene program, but your footwear program. Number one. efficacy. Does the product or solution you're selecting have efficacy that can be validated? Is it consistent?

Like, you know, for everybody going in, is it standardized between individual shift in all the facilities and locations, right? Super important to make sure whatever you're going to use is in the right location. Is it in your GMP zone? That's going to help prevent any pathogens from entering production.

What do you have in key transition areas, raw to RTE or RTE to raw? What do you have in those? And the biggest one, is it simple and is it easy to use? We're going to show a quick virtual demo of how easy it is to use SoulClean on a cleantech station. So I'm going to go through some of the popular methods that are out there for dry footwear sanitation one by one.

First is shoe covers. you know, personally,  I do see them a lot. We see them a lot in dry environments. One of the challenges I see with shoe covers If you don't have the automatic, machine that applies the shoe cover to footwear, you're asking your employees to put their hands to their feet. And feet are usually, shoes, footwear are, are, are carrying all kinds of pathogens.

So it's, it's a scary thing of putting your hands down by your feet. expensive. That's the one thing we learn a lot about shoe covers. And I'm going to show a quick case study, in a few minutes on the cost that we see with a lot of our customers who are using shoe covers. If you have a sustainability program, shoe covers, a lot of waste.

I don't think it's going to be a positive thing for your sustainability program. Tacky mats. We see those more in clean room applications, but occasionally we do see them in dry footwear areas. A benefit of a tacky mat, you know, can be used with all shoes, but is it getting inside the treads? It's not, right?

And it's only going to remove small particles, and they need to be replaced, which is also very, very, very expensive. UV sanitation systems. I personally have not seen one in a plant. I've heard of them. I haven't seen a lot of clinical validations with them. so can't speak to them a lot. Dry quad, outside of shoe covers.

This is what we see a lot in facilities. this picture in the bottom left, kind of similar to the video that Brian was showing. What do you see in the background? Is that food on a conveyor that close to dry quad pellets? It's a challenge for food safety without a shadow of a doubt because those pellets can travel with it.

They can travel onto that, you know, food contact surface right there. one of the things we see with dry quad as well as contact time, what type of contact time does the footwear need in that dry quad for it to be effective? Efficacy. Another thing with dry quat, A lot of the efficacy you see with dry quat, it does say it requires moisture to activate, which most dry facilities are trying to get away from any type of moisture. So we don't see moisture being introduced into dry quad in order for it to be effective. So what is the efficacy around that?

Here is the system that I mentioned, you know, a few minutes ago, the CleanTech^® EVO with Sole Clean. Easy to use effective contact time. What I was just talking about with dry quad, you are going to get 12 seconds of contact time at the bottom of the footwear while you're washing your hands. So now you're achieving two paramount hygiene events in that 12 seconds, clinically validated hand wash that is standardized across every employee.

And then a footwear sanitizing event that is also clinically validated. That is also standardized, across every employee who steps in there for 12 seconds. So when we talk about the clinical validation, Meritech did invest money to have a third party clinical validation done on SoulClean. We've also done it with our hand washing stations.

but we did it with footwear. Why did we invest money in this third party validation? And the biggest reason why is if you look online or if you look at any of those other methods of dry footwear sanitation that I threw out there, try to find clinical validation. it is a few far between and borderline doesn't even exist.

especially clinical validation that is done online. Real world. So we applied Listeria and Salmonella to the bottom of footwear, street shoes and rubber boots, and those contaminated footwear, you know, that we tested were then placed in the sole clean pan for 12 seconds for us to see what the efficacy was.

All right, we're going to talk about the efficacy. This is the real world efficacy. We had a four log reduction with both salmonella and listeria in that 12 seconds of contact time Now, like I said, this is a real world. This was done on the bottom of footwear street shoes and rubber boots Plenty of time if you are if you are able to find clinical validation, it's going to be in vitro We did this in in a test tube.

We didn't, we did it on footwear. So now that you see what the product looks like, now that you see the clinical validation, most people at this point say, we can't afford it. This looks very, very expensive. And believe it or not, Most facilities can't afford it when you're comparing it against the other methods that are out there quick case study here This is just comparing cleantech evo just hand washing no footwear sanitation But this customer had about 75 employees.

They were using a hassap e2 soap in their gmp zone They were spending about 7, 500 a year On that soap after consultation with meritech. We upgraded them to two evo walls You After the initial investment, this customer was saving 3, 400 a year comparing the Cleantech to the soap they were using. The next quick case study is with shoe covers.

And like I mentioned before, they are super, super expensive. So this customer had six sinks that were being used for manual hand washing. They were spending about 11, 000 a year on their hand soap. they had about a hundred employees per shift. I believe it was two shifts. Third shift was a cleaning shift, but they were spending about 11, 000 a year on hand soap.

Shoe covers, anyone entering production was required to put shoe covers on. This customer was spending 75, 000 a year in shoe covers. Like we mentioned, they are extremely, extremely wasteful and extremely expensive. The, this customer, that top picture, they installed two Evo threes with soul clean, and this customer was able to save around 62, 000 a year by going with Meritech last, but not least dry quad.

The other picture I showed the dry quad really close to a food contact surface here, the mats, this customer was using, they were. Filling these three mats with about three pounds per day of dry quad, which shook out to about 43, 000 a year and dry quad. And when you add that to the 5, 600, they were spending on hand soap for their 50.

So employees, it was expensive, very expensive for them to have in their facility. And this customer saved 36, 000 a year by switching to Meritech. So it is a, An option, right? Here's some installation pictures. It is not as, as expensive as most people think to automate their hygiene protocols. you'll see people upgrade and all of these, you'll see people upgrading from sinks to footwear, having that footwear sanitizing enhancement on the clean tech Evo.

So the next thing we're going to show in the most important, now that I've talked about standardizing, efficacy. The important of having those is critical to being proactive. So investing in the automated hygiene equipment can save you money, but it also is going to protect your brand. Don't be a royal ice cream.

Don't be a boar's head without a shadow of a doubt. take that step to be proactive. so standardized efficacy. Now I'm going to quickly show the ease of use, and how easy it is to teach and train an employee. To use a clean tech station. All your employees need to do is step into the pad, place their hands into the evo Now the hand wash is starting remember.

It's only 12 seconds to get that clinically validated hand wash Now i'm getting 12 seconds of contact time on the bottom of my shoes And that's getting me that four log reduction of salmonella and listeria And it's as easy as that. Any questions myself and Brian will make ourselves available. Here's our contact info.

We'd love to hear from you. We'd love to answer your questions. And we more importantly, would love to establish a partnership for people who are looking to be proactive versus reactive!