EHA Group Food Safety and Epidemiology Blog

Food Safety Audits: Worthwhile, If Done Correctly

Over the past several years, and clearly over the past several weeks, there has been increased interest, criticism, and a general sense of a conundrum in reference to the reliability, reproducibility, validity, and general worthiness of a third party audit.

Many people with varying interests have weighed in with a lot of facts, few figures, and a fair amount of speculation. We believe, and have even published, that the key to an appropriate assessment from a third party audit starts with the qualification and experience of the auditor.

As long as there are firms that are recruiting and sending out on third party audits individuals with minimum credentials, such as the one we found on one company’s website, “high school diploma, or equivalent, plus ten (10) years food processing experience (food plant experience in a responsible food safety position)”, then these audits are doomed to be a potentially harmful and indeed can be worthless.

However, if the third party auditor is properly trained, schooled, and credentialed in food safety and microbiology (a bachelor’s degree, with a minimum of thirty credits in the biological/environmental sciences), then third party audits can be an extraordinary good tool to be used by industry in assessing, to assure that the health and well being of the consumer is not going to be compromised.

When conflicts of interest arise, anywhere, there is always cause for concern. Some of these conflicts of interest are present in the auditing firm, when companies sell laboratory services, pest control services, chemicals, or other services, and the third party audit becomes a lost leader, just like a can of peas in a supermarket, selling for far under the fair market value.

We at EHA Consulting Group welcome standardization, credentialing, and educational requirements for third party auditors, as well as the continuation of a meaningful productive dialog with all stakeholders in reference to the issues.

In fact, in 2009, we blogged this, which is as true today as it was then, and we clearly welcome others to revisit it and continue this important dialog.

Let’s remember, a good working definition of public health is preventative medicine in action.

New York City Restaurant Food Safety: Time as a Control for Temperature

In our continuing effort to keep everyone informed, I would like to alert you to an interpretation of the “time as a control for temperature” principal and rule that is basically contained in the Model Food Code of the U. S. Food and Drug Administration and, in part, has been adopted widely throughout the country.

One of the latest adoptees is the New York City Health Department when they revamped their Retail Food Service Program. The changes in NYC health inspections included utilizing time as a control for temperature, as well as providing for grading with public display of the grading placards.

In the past week, we have been informed, and confirmed with the New York City Health Department, that the rules (which are somewhat more stringent) to permit time to be used as a control for temperature, which has been working rather well, has suddenly taken on a new enforcement protocol in that the New York City Health Department is considering that if a retail food service establishment offers food for take-out, then they may not utilize time as a control for temperature.

The case in point was a corporate foodservice facility in that food was being taken out of the cafeteria in appropriate containers for consumption elsewhere, most probably at the individual’s desk. There is an exemption that had not been enforced, which states, “When intended for takeout”, clearly a corporate foodservice operation is prepared for takeout, but that is not its sole mission.

To this end, I have written today for clarification to the Associate Commissioner of Health, asking for reconsideration, and a waiver for corporate foodservice facilities, since I do not believe there is a negative impact to the publics’ health, nor do I believe that there is a science-based difference between that and what is experienced on a daily basis if we went back to not utilizing time as a control for temperature.

Furthermore, I questioned whether or not a white tablecloth restaurant providing a “doggie bag” is actually providing food for takeout, a practice that I would consider far more riskier than when an employee at a corporate dining facility takes their lunch to their desk. Could there be a thermal and time abuse, absolutely. However, no one can control for human behavior.

Please be advised that if you are in the City of New York and you are utilizing appropriate time as a control for temperature, with all of the documentation required, and if food is available for takeout, you may be cited as some units have been in the past two weeks. We will keep you posted when we hear from the Associate Commissioner of Health for the New York City Health Department.

If you have any questions, please feel free to contact us at any time.  EHA is trying to get into the social network mode of communications and we invite you to follow us on Twitter at EHAConsultingGp for frequent updates, mostly concerning food.

Reducing the Risk of Salmonella in Retail Establishments

I posted this comment on Salmonella on an international listserv sponsored by the International Society for Infectious Diseases at Harvard University:

As someone who has investigated egg-associated outbreaks since the 1980s, there is a component that seems not to be transmitted either by the popular media or even through professional communication. The risk of getting an egg infected with _Salmonella_ Enteritidis (SE) is approximately 1 in 20,000.

The reason why we see restaurants now as in previous times being associated with outbreaks is they tend to pool many dozens of eggs, thermally abuse them over 41 deg F [5 deg C] increasing the number of organisms, then they either fail to cook whatever the product is to 155 deg F [68 deg C] or above, or cross-contaminate the raw egg with ready-to-eat foods.

Clearly, SE is a preventable disease if retail establishments follow the food code that is in their jurisdiction. Outbreaks of SE have been attributed in the past to hard-boiled eggs (obviously not boiled enough), raw egg products in Caesar salads, mousses, and eggnog as well as in cooked dishes such as quiches, lasagna, Monte Cristo sandwiches, and the like. The egg industry actually reduced the risk and many retail establishments eliminated utilizing raw, shell eggs and went to pasteurized eggs for both raw and fully cooked egg dishes.

-Dr. Melvin Kramer

New York City Restaurateurs ’ Dilemma – The New ABC Grading System is Effective July 1, 2010

New York City is following in the footsteps of Los Angeles County. In July 2010, The New York City Department of Health is planning on rolling out its new A, B, C Letter Grading System to score restaurants in the city on their food safety program which includes food protection, employee health and hygiene, physical cleanliness, as well as pest control.

But restaurateurs, have no fear, this is no big deal! Los Angeles has been giving letter grades to restaurants for over 12 years. The program not only increased compliance with the food safety regulations and laws within Los Angeles County restaurants, it also resulted in a decrease in the number of food-borne disease related hospitalizations drastically since the program was started (http://www.cspinet.org/dirtydining/HospitalizationsStudy.pdf).

Response to Bites

I note with interest the lead story of Monday, March 1, 2010 that “Food safety audits never enough”. There is no question that a simple food safety audit is not the ‘be all and end all’ in assuring food safety, whether at the retail, processing, manufacturing, or farm level.

However, to broad stroke the worthlessness of food safety audits is, in my opinion, a grave error. There is no question that over the past several years some high profile recalls and outbreaks, including outbreaks associated with deaths, have occurred in facilities that have had third-party audits.

The questions should be, “Who is the auditor?”, “What are the auditor’s credentials?” and “What is the motivation of the auditing firm that is conducting the audit?” Specifically, having auditors that do not have minimum credentialing of a Registered Sanitarian or Registered Environmental Health Specialist (R.S./ R.E.H.S.) is clearly the beginning of a recipe for failure.

Some of the national auditing firms that have teams of auditors who post on their websites that the minimum requirements are a high school diploma or equivalent and five to ten years of experience in a food plant clearly do not meet any credentialing standards that I would want to have as an auditor. Individuals who possess the correct credentials of the R.S./R.E.H.S. require a Bachelors Degree with 30 credits in the sciences, training, experience, and passing a state or national examination.

Cross Contamination and Hand Washing

Cross Contamination

We all know about checking foods with a thermometer or waiting for the pop up timer to tell us the turkey is done, but have we really protected ourselves and our family from disease causing germs? Not if we used the same cutting board for preparing the turkey and then the vegetables, or if we forgot to wash our hands after handling the turkey and opened the refrigerator or oven door.

Remember that bacteria are looking for that free ride to a potential victim and the best method of transport or transfer is by the hands of the person preparing the meal or not washing that utensil before it contacts the next food.

Employee Health – A Pillar of Foodborne Disease Prevention

There is no question that the three major factors contributing to foodborne diseases that are in the control of a food service operation are temperature control, prevention of cross-contamination, and employee health/hygiene. There is a significant misnomer that the lack of either an insurance program or a paid sick leave policy in any way exempts employee health requirements that are part of the Food Code and most all state regulations concerning employees who handle food.

In a retail establishment, “The PERMIT HOLDER shall require FOOD EMPLOYEES and CONDITIONAL EMPLOYEES to report to the PERSON IN CHARGE information about their health and activities as they relate to diseases that are transmissible through FOOD.” Specifically, reportable symptoms are vomiting, diarrhea, jaundice, sore throat with fever or any lesion containing puss such as a boil or infected wound that is open or draining and is on a hand, wrist, arm or other part of the body that is exposed and cannot be covered by a dry, durable, tight-fitting bandage.

Furthermore, if the employee has been diagnosed by a health care provider with Norovirus, Hepatitis A virus, Shigella, Enterohemorrhagic or Shiga toxin-producing Escherichia coli or Salmonella, these conditions are reportable. in addition, if the employee has been exposed to or is the suspected source of a confirmed disease outbreak where the employee or conditional employee consumed or prepared food implicated in the outbreak or consumed food at an event prepared by a person who was infected with Norovirus (within the past 48 hours of last exposure), Salmonella (past 72 hours of last exposure) , Shigella (past 3 days of last exposure), Hepatitis A (past 30 days of last exposure) or Enterohemorrhagic or Shiga toxin-producing Escherichia coli.

Any employee exhibiting these signs, symptoms or have been diagnosed with the aforementioned diseases must be excluded from work. Furthermore, the individual employee must, per the Food Code and most state health regulations, comply with the exclusion and/or any restrictions placed by the employer and/or health care provider including the Department of Health.

It is our recommendation that employees upon hiring be educated, not only to their responsibilities of their individual tasks, of their individual jobs and any cross training that management desires but also have a clearly designed statement to show that they have read and understand the aforementioned diseases and conditions that trigger the notification of management that they must be placed off duty in our opinion for at least 24 hours AFTER the cessation of vomiting, diarrhea or fever.

Some forward thinking organizations actually have employees sign a statement attesting and agreeing that they will report to the manager on duty if they are experiencing the aforementioned signs and symptoms of disease, as well as any other illnesses or conditions, that can be communicated through food. This document is witnessed and co-signed with a date by the manager.

We at EHA strongly recommend all food service facilities adopt such health education and documentation to protect the public’s health. In addition, helpful hints for good personal hygiene are also encouraged in the same type of document discussing daily bathing, clean and trim fingernails, restraining hair and clothing/uniform requirements.

Some health departments routinely and/or, if there is the allegation of foodborne disease, will ask employees about such a policy and it is clearly embarrassing and can lead to further regulatory involvement if employees have not been educated and trained in a policy that requires exclusion from work if they are sick with signs, symptoms or diseases that can be transmissible through food.

Third-Party Audits: EHA Consulting Group Releases Comments on Food Safety Consultant Auditors ' Qualifications and Competencies

February 11, 2009 -- EHA Consulting Group, which has over 25 years of experience providing food safety consulting, released comments today about the qualifications and competencies of food safety auditors.

The potential for under-qualified and lack of third party audits by many of the processors who purchased the recently recalled Salmonella contaminated peanut butter and peanut product may have had an impact on the number of cases of Salmonellosis and deaths according to EHA's President, Dr. Melvin N. Kramer.

Salmonella typhimurium has been reported in 600 cases across 44 states and Canada, and attributed to peanut butter incorporated into a plethora of food products. These cases have resulted in eight deaths. This outbreak is an embarrassment to the U.S. Food and Drug Administration (FDA), state regulators in Georgia, and industry.

Proper Utensil Storage

Food safety Perspectives by Christine Testa - Regional Food Safety Specialist Lately, during food service operation inspections, I have noticed that foodservice employees have question about where and how to store the knives and other utensils.

Many times, I find soiled knives inside sanitizer buckets with soiled sanitizer solution and food particles. Other questions come up such as “Do you really have to clean and sanitize the knife after each?” “Can we use ice water to store coffee spoons? “ What exactly is the rule? According to the 2005 FDA food code, there are 4 acceptable methods to store “in-use” utensils for ready to eat food items such as at the sandwich and salad prep stations.

Food safety training! It ’s not just for managers any more.

Perspectives on food safety by Christine Testa While I was a public health sanitarian in Michigan, as soon as I walked into a kitchen I could tell if the crew was well trained or not. One clear sign of a poorly trained staff is when they scatter away like cockroaches in a bright light, as I walked in the door.

Poorly trained employees are not confident. Food safety training is not as simple as telling the pantry employee to put gloves on or threatening to fire the cook because he continues to place the raw hamburger above the lettuce. In most cases, food safety training is conducted once as an employee orientation for a new hire.