Discovering Previously Unidentified Foodborne Illness Risks through Discussion

State: MN Type: Model Practice Year: 2005

The goal was to promote the active management of food borne illness risk factors by food service operators. Its objectives were to: shift the food safety program's focus from counting violations to evaluating food safety risks and "systems," use an assessment process based on discussion of foodborne illness risks with the manger/operator, and develop the ability to track assessment results toward the Healthy People 2010 goals. The practice resulted in identification of 50% more foodborne illness risk factors, improved relationships with food service operators, and improved staff productivity and morale. Attitude is an important part of replicating the practice. There needs to be a willingness to: a) see food service operators as customers and partners in preventing foodborne illness; b) see the assessment process as a food safety "movie" instead of a legal "snapshot,"; c) allow and encourage sanitarians to act as consultants; d) concentrate on behaviors known to lead to foodborne illness risk factors (from epidemiology); and e) shift enforcement criteria from lack of compliance with specific violations to a prevention strategy that includes active managerial control of foodborne illness risk factors. Also needed are good interpersonal communication skills, and knowledge of the causes of foodborne illness outbreaks.
This practice addresses the causes of foodborne illness outbreaks as shown by epidemiological data, which are primarily practices and behaviors of food workers. It fosters long-term change by recognizing that the operator is ultimately responsible for food safety by actively managing foodborne illness risk factors. This is achieved by helping operators recognize their responsibility for proactive food safety-that they cannot prevent foodborne illness by just reacting to inspection findings. Investigating foodborne illness outbreaks led Olmsted County Public Health Services (OCPHS) staff to question the value of routine inspections and became the impetus to seek improvements. Outbreak investigations are different from routine inspections-they concentrate on honest communication with the operator, food worker health and hygiene, risk assessment. There is analysis of how food is stored, prepared, and served, and advice on how to develop systems to do this safely. When restaurant owners stated that all stablishments could benefit from this approach before an outbreak happens, OCPHS staf began to wonder how this approach could be practically applied. The practice addresses the issue by asking the operator to describe critical food safety policies and practices, especially those strongly linked to outbreaks but not easily observable, such as employee illness policy. For instance, an operator is required to have a "system" for excluding employees who are ill with vomiting or diarrhea. The system would include formulating a policy, informing employees of the policy, and monitoring employee health. The practice allows the application of HACCP (hazard analysis and critical control points) principles without doing fow charts or classifying processes as control points, critical control points, good retail practices, etc. Simply, if there is a foodborne illness risk associated with the practice, there needs to be a system for doing it safely. If the operator does not have a safe system (policy, training, and monitoring) they will be expected to implement one, and will be ofered information and advice on how to do so. After the discussion, observation is used to confrm that a system exists, and that it is firmly in place. Observed "violations" are seen as symptoms of system problems, not as problems in themselves. When there are discrepancies between discussion and observation, this means the operator knows what needs to be done (policy), but is not making sure it gets done (training and/or monitoring).
Agency Community RolesThe role of OCPHS in this practice was to take suggestions and inspiration from others throughout the country and develop a practical risk-based method that could be sustained. An FDA Food Program Leadership Workshop provided the impetus for the enhancement of the practice. Initial partners included the Minnesota Department of Health and several local public health agencies in Minnesota. OCPHS initiated a pilot program to experiment with diferent strategies and techniques until the practice, including the process, forms and supporting materials was formalized. With support from an FDA Innovative Food Safety Grant, a local Food Safety Advisory Task Force (FSAT) was formed and a national conference on Active Managerial Control was sponsored. The FSAT and reports to OCPHS' Advisory Board and Olmsted County Commissioners were avenues for input and feedback throughout the practice development, and provided additional forums for community involvement.  Costs and ExpendituresThe funding source to support and sustain this practice is license and service fees (100%). An FDA Innovative Food Safety Grant for $40,000 was awarded to initiate the practice development. Also, an Olmsted County Research and Development grant for $10,000 was received to ofset costs involved in the data management system development. Approximately 3.4 FTE are budgeted to the food program, out of about 10 FTE total in Environmental Health Services.
The outcomes were:  Identification of 50% more foodborne illness risk factors Prior to implementation, conditions were identifed only by observations and illness risk factors were not a priority. During the last three years, 55% of the risk factors identified during 1142 assessments were identified by discussion. Because some of these risk factors are dificult to find by observation, such as safe cooling of food, it is fairly certain the outcome can be attributed to the practice.  Improved relationships with food service operators. Prior to implementation, surprise assessments and the citation of large numbers of low-risk conditions resulted in reports of operators who looked at the assessment process as an intrusion and of little "value. After implementation, operators were surveyed and asked to compare scheduled assessments to unannounced inspections; 83% thought the scheduled assessment resulted in better working relations with the inspector.  Improved staff morale and productivity Prior to implementation, staff members frequently expressed frustration with operators' perceived lack of concern about food safety. Sanitarians spent large amounts of time on preparing inspection reports, requesting plans for correction of low-risk conditions, and doing re-inspections-only to see the same problems at the next visit. After implementation, staff members were spending roughly the same amount of time per establishment, but all expressed increased job satisfaction.  Follow-up was less likely to be reinspections, and more likely to be continued consultation. This has been especially true of safe cooling practices. Operators who have not verifed cooling times are asked to do and send in cooling charts; sanitarians evaluate them and call operators with the results. Operators who cool food overnight can borrow an "I-button" temperature recorder from OCPHS. Because staf members still periodically state that they are completely unwilling to go back to the "old way" it is fairly certain the outcome can be attributed to the practice.
The stakeholder commitment to perpetuate the practice is partly ensured by the system itself, because operators see value in the service they receive. Also, Boards accept the underlying premise that seeing operators as partners in preventing foodbome illness is a more responsive and cost efective way to tackle the problem. This is of particular concern in Olmsted County because there are many businesses catering to a clientele susceptible to foodborne illness: patients at the Mayo Clinic and elderly who retire here because of the availability of high-quality health care. Future practice enhancements include plans to strengthen the review and outcome measures of the FDA concept of Active Managerial Control (AMC) using the "Duties of a Certified Food Manager" as given in Minnesota rule. These duties provide a framework in which AMC can be realized: policies and procedure to prevent foodborne illness are developed (policy), food workers are trained to take corrective action as needed (training), and periodic self-inspections are conducted (monitoring) to control the risk factors in the day-to-day operations.