From Hygienic Design to Active Hygiene
Managing Microbiological Risk in Food Processing Facilities Under the New EU Listeria Requirements
For decades, food safety strategies have focused on controlling contamination through hygienic design, validated cleaning procedures, and robust quality management systems. While these principles remain essential, upcoming regulatory changes in the European Union are placing greater emphasis on a manufacturer’s ability to demonstrate continuous microbiological control throughout the entire shelf life of a product.
Commission Regulation (EU) 2024/2895, which becomes applicable on 1 July 2026, introduces stricter requirements regarding Listeria monocytogenes in ready-to-eat foods. Under the revised framework, food business operators will be expected to demonstrate, through scientific evidence and validation studies, that Listeria monocytogenes remains under control throughout the product’s shelf life. Where such evidence cannot be provided, a significantly stricter approach applies.
This development represents more than a regulatory adjustment. It signals a broader shift in expectations regarding food safety management. Regulators, certification bodies, retailers, and consumers increasingly expect manufacturers not only to react to microbiological incidents but to proactively reduce the conditions that enable them.
For food manufacturers, this raises an important question:
Are current hygiene strategies sufficient to control microbiological risks in the most critical and difficult-to-clean areas of production facilities?
The Hidden Challenge: Critical Hygiene Zones
When microbiological contamination events occur, investigations often reveal that the source was not located on primary processing equipment but within surrounding infrastructure.
Drainage systems, floor-to-equipment interfaces, structural supports, transport equipment, and other concealed areas frequently become reservoirs of microbial activity. These locations share several common characteristics:
- constant exposure to moisture,
- accumulation of organic residues,
- limited accessibility for cleaning,
- favourable conditions for biofilm formation.
Among these areas, drainage systems deserve particular attention.
In modern food production facilities, drainage acts as an interface between high-care production zones and areas with elevated contamination risk. Although drainage systems are designed to collect and remove wastewater efficiently, they also create conditions that can support microbial survival and growth if not properly designed and managed.Numerous studies and industry observations have identified floor drains and siphons as potential harborage points for microorganisms, including Listeria monocytogenes. Once established, microbial communities can develop into biofilms that exhibit increased resistance to conventional cleaning and disinfection procedures.
The challenge becomes even more significant because these areas often remain outside direct visual control while operating continuously in humid conditions.
Hygienic Design: Essential but Not Always Sufficient
The food industry has made enormous progress in applying hygienic engineering principles.
Guidelines developed by organizations such as EHEDG have transformed the design of production facilities by promoting:
- cleanability,
- inspectability,
- elimination of dead zones,
- proper drainage,
- reduction of product retention areas.
These principles remain the foundation of food-safe infrastructure.
However, practical experience demonstrates that even well-designed systems can contain areas where complete cleanability is difficult to achieve during routine operations.
This creates a gap between hygienic design and actual hygienic performance.
A drainage channel may be designed according to hygienic principles, yet its internal geometry, trap components, floor joints, or concealed structural elements can still experience continuous exposure to moisture and nutrients. Similar situations occur beneath equipment support feet, around floor anchor points, and in confined spaces that cannot be accessed during every cleaning cycle.
As food safety expectations continue to rise, manufacturers are increasingly looking for methods that complement hygienic design and provide an additional layer of microbiological protection.
agATT®: Supporting Hygiene Where It Matters Most
One example of this approach is agATT®, a technology developed by ATT in cooperation with researchers from the Faculty of Chemistry at the Jagiellonian University in Kraków.
The technology is based on silver-containing particles immobilized within a mineral calcium carbonate matrix. These particles are permanently incorporated into industrial coating systems and applied to selected infrastructure components exposed to elevated microbiological risk.
Unlike conventional antimicrobial technologies that rely on uncontrolled release of active substances, agATT® uses immobilized silver technology designed for localized and long-term surface activity.
The solution was developed to support microbiological control in areas where:
- persistent humidity occurs,
- organic residues may accumulate,
- biofilm formation risk is elevated,
- routine cleaning access is limited.
Examples include:
- drainage channels,
- drainage traps and siphons,
- floor-to-drain interfaces,
- structural support feet,
- equipment anchoring points,
- wheels in transport and handling components.
By acting directly at the surface level, the technology supports efforts to limit microbial colonization and biofilm development in critical hygiene zones.
Importantly, agATT® does not replace cleaning procedures, disinfection protocols, HACCP programs, or hygienic design principles. Instead, it provides an additional layer of protection between sanitation cycles.
From Compliance to Risk Reduction
The significance of enhanced microbiological control extends beyond regulatory compliance.
A single contamination event can trigger:
- product recalls,
- production interruptions,
- customer complaints,
- retailer penalties,
- reputational damage,
- loss of consumer trust.
In many cases, the financial consequences of contamination incidents significantly exceed the cost of preventive measures.
As a result, food manufacturers increasingly evaluate hygiene investments not only from a compliance perspective but also as part of broader risk management strategies.
Technologies that help reduce contamination risk can contribute to:
- greater operational stability,
- improved audit readiness,
- more predictable hygiene performance,
- reduced likelihood of microbiological incidents,
- protection of brand reputation.
For facility owners and business leaders, hygiene is no longer solely a quality issue. It has become a strategic business consideration directly linked to operational resilience and long-term profitability.
The Future of Food-Safe Infrastructure
The food industry is entering a new phase in which hygienic design alone may no longer be sufficient to meet growing expectations regarding microbiological safety.
Future-ready facilities will increasingly combine proven hygienic engineering principles with technologies that actively support microbiological control in the most vulnerable areas of production environments.
As regulatory requirements tighten and food safety expectations continue to evolve, the industry’s focus is shifting from simply enabling cleaning toward continuously supporting hygienic conditions throughout operation.
The transition from passive protection to active hygiene represents not a replacement of existing best practices, but their natural evolution.
For manufacturers seeking to reduce microbiological risk, strengthen compliance, and protect business continuity, active hygiene technologies may soon become an important component of the next generation of food production infrastructure.
