BIZTRACKS
Cornell Advancing Dry Sanitation Forum: Executive Summary

The Cornell Advancing Dry Sanitation forum, which took place October 26–27 at Kerry's North American headquarters in Beloit, Wisconsin, brought together 200 participants from food manufacturing, research, regulatory agencies, and solution providers to examine how sanitation practices can better support food safety in low-moisture food facilities.
Organized through Cornell's Dry Sanitation Research Advisory Council and hosted by Kerry, the forum combined research presentations, industry experience, and interactive discussions across six themes: moisture management, emerging technologies, allergen control, hygienic design, sanitation validation, and priorities for future collaboration.
Theme 1: Moisture Management is Foundational to Dry Sanitation
- Discussions highlighted the potential for water introduced during sanitation to remain in crevices for extended periods of time.
- Relative humidity strongly impacts dry-out time.
- Regular environmental cleaning between major breakdown sanitation events can help maintain sanitary conditions and reduce downtime during major breakdown sanitation events.
- Dry cleaning may take longer than wet sanitation, but the additional time can be justified by the food safety benefits of keeping the environment dry. Sanitation decisions should be guided by risk, with production efficiency considered alongside, but not overriding, food safety.
- The time required to perform dry sanitation decreases as staff learn how to do it and get the right tools. Providing the right tools and training can greatly reduce the time to perform dry sanitation.
- Selection of sanitation methods should consider overall food safety risk (including transfer and pathogen regrowth) and not just maximizing pathogen reduction.
Theme 2: Technology Selection Requires Evidence Under Actual-Use Conditions
- Emerging low-moisture antimicrobials and advances in cleaning equipment can expand the options available to manufacturers. Their value depends on how effectively they address a defined problem within a facility.
- Evaluation of novel approaches should account for equipment construction, food residues, application methods, and practical constraints.
- Strong sanitation fundamentals remain essential to successful implementation.
Theme 3: Allergen and Microbial Risks Need to be Considered Together
- Wet cleaning for the sole purpose of allergen changeovers can increase microbial food safety risk when it introduces moisture into an otherwise dry system.
- An exclusive focus on "chasing zero" or non-detection for allergens on product-contact surfaces can backfire and potentially enhance overall food safety risk. Once allergen residues have been reduced to levels supported by data and sound risk assessment, further removal may offer little additional protection. If achieving that marginal reduction requires introducing water into a dry facility, the resulting increase in microbial risk could outweigh the additional allergen risk reduction. This is a case for evaluating allergen and microbial risks together, with the goal of reducing overall food safety risk.
- Presentations explored how allergen thresholds, reference doses, and risk assessment can inform effective management strategies. These strategies may be useful in evaluating the use of dry sanitation techniques for allergen changeovers.
- The broader priority is to establish science-based approaches that control allergen cross-contact while accounting for the microbial risks associated with the selected sanitation method.
Theme 4: Hygienic Design Should Support Effective Dry Cleaning
- Hygienic design flaws in low-moisture food production environments are often better managed using dry sanitation than wet sanitation.
- Equipment design and materials of construction influence where material accumulates and how readily it and moisture can be removed. The forum examined both opportunities to improve new designs and practical approaches for existing facilities.
- Hygienic design gaps strengthen the need to understand equipment-specific risks and select suitable dry cleaning practices.
- Identifying niches and evaluating targeted design changes can support more effective cleaning and flushing.
- Incorporating feedback from sanitation teams into equipment design and modification can greatly improve the hygienic status of equipment.
Theme 5: A Credible Sanitation Break Requires Supporting Evidence
- FDA's January 2025 draft guidance recommended cleaning and sanitizing all food-contact surfaces during a sanitation break.
- The session explored what evidence could support alternative approaches in dry facilities, including those without sanitizer application to all food-contact surfaces.
- Discussion emphasized elements necessary to support validation of a sanitation break using dry physical cleaning methods: an environment in control that supports validation, knowledge of equipment hang-up points, and evidence that sanitation effectively addresses those locations.
- A proposed qualitative, five-step assessment framework—also discussed in similar terms at the recent Reagan-Udall roundtable on dry dairy sanitation validation—provided a structure for gathering facility-specific evidence. After defining the equipment, products, and sanitation practices within scope, the steps are:
- Determine whether the environment supports validation of a sanitation break.
- Identify the hardest-to-clean food contact surfaces and material hang-up points.
- Define sanitation steps that effectively treat those locations.
- Gather evidence that all food-contact surfaces were treated and prior-campaign material was removed, including accumulated residues in hard-to-clean areas.
- Reassess when equipment, products, procedures, or environmental conditions change.
- The framework focuses on documented, facility-specific evidence rather than a universal sanitation method. Visual inspection, tracers, surrogate studies, and other appropriate analytical methods can generate useful evidence. Finished product testing alone cannot establish an effective break.
- FDA anticipates the release of a revised draft of its low-moisture RTE draft guidance.
Theme 6: Future Collaboration
The organizers thank Kerry, the sponsors, speakers, moderators, panelists, and participants for their contributions and openness. Ways to stay engaged include:
- Connect with the dry sanitation community. Join the Cornell Dry Sanitation Research Advisory Council LinkedIn group for research updates, technical discussions, resources, and opportunities for continued engagement.
- Help guide future work. Share research questions, facility challenges, case studies, and training needs with Dr. Abby Snyder at abs276@cornell.edu. Contact Cornell Food Science Extension to discuss education and collaboration opportunities for your team.
For more information about dry sanitation for low-moisture foods, check out the ongoing series of articles in Food Safety Magazine authored by Dr. Abby Snyder and industry experts. Read the articles here.
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