South Jersey Mobile Unit Task Force

State: NJ Type: Model Practice Year: 2015

Mobile units and temporary food vendors are not easy things for health inspectors to oversee in Southern New Jersey. They don't stay in  one spot and their base of operations may be in a different county or even state. They sometimes illegally use their homes as a base of operations. When they travel through jurisdictional lines, they have often pointed out the inconsistencies amongst our departments. Health Departments in the southern part of NJ recognized that we did not have a very good handle on mobile units and temporary vendors. We all felt overwhelmed with the number of applications and lack of adequate staffing for their necessary oversight. In 2011, Cumberland County Health Department reached out to other southern health departments in neighboring counties to see if these issues were common. Realizing that we shared the same issues regarding mobile food facilities, we created the Southern NJ Mobile Force consisting of 7 health departments from Atlantic, Camden, Cape May, Cumberland, Gloucester, and Salem Counties and Vineland City. The task force addressed these common issue by developing standardized forms and processes that all agreed to use. It has saved us time and made the process more efficient and reliable. These seven counties serve 1,397,000 citizens altogether with about 863 mobile units traveling within our borders. Our goals and objectives were to: Increase efficiency and resources through collaboration in the application and inspection process Improve regulatory consistencies across jurisdictional lines through use of shared processes and standardized forms Provide for better tracking of mobile food vendors through home base health department oversight and information sharing The task force developed and implemented the following tools in 2012: Mobile retail food establishment application Instructions for application completion Amendment form Event Coordinator Form All of our goals and objectives were met. Using the same standardized forms and processes proved beneficial for both the applicants and the agencies. In 2013, we were able to reduce our review of applications by an average of 29% through sharing applications for mobile vendors operating in multiple jurisdictions. Applicants provided positive feedback to all participating departments regarding the ease of the application process, specifically in eliminating the redundancy of multiple applications and inconsistencies across jurisdictional lines. Through our processes, including pre-inspections by the home base health department AT the servicing area of the mobile operator, application sharing and communication between our departments, we now have better tracking and regulatory oversight of mobile food vendors. Other agreed upon requirements within the task force such as prohibiting the use of unprotected sternos for hot holding at outdoor food facilities has provided further consistency and improvements of food safety practices amongst mobile food vendors. Through our efforts within the Task Force, we are seeing better communications with mobile food operators and event coordinators which has also improved compliance regarding safe food sources and handling by the mobile food operators. Each task force department has the developed forms on their website for access by the community and event coordinators. An example of the forms can be seen at or
Local health departments in southern NJ realized that there were some issues regarding the oversight of mobile retail food operations. Basically, our oversight of these mobile facilities was very limited due to their transient nature, operating hours and their lack of an approved servicing area (or having a servicing area outside of our jurisdiction). We didn't have a handle on these mobile food facilities which often operated outside of our normal workday or came into our jurisdiction for a weekend event then disappeared afterwards. These operators were providing food to the public within our communities and we didn't always know! Furthermore, we didn't always know if they were employing food safety measures. This made us uncomfortable and was not acceptable. Mobile facilities, in their nature, have a potential of serving many people across many jurisdictional lines within the state and across our borders. We needed to gain better oversight of these mobile operations to ensure that approved food sources were being utilized and safe food handling was taking place. Economic issues throughout NJ increased the number of mobile food vendors and special events, as well as the complexity of the foods offered. The lack of overhead and the simplicity of this type of business encourages new entrepreneurs which increases our workload. The lack of resources prohibited the local health departments from individually improving in this area. Last minute applications and outside pressure overwhelmed our staff. We needed to approach this on a united front; if these operations were traveling across jurisdictional lines, then we needed to work together across jurisdictional lines. We needed to communicate better and work together in a united front to ensure the mobile retail food vendors within our jurisdictions were operating legally and safely. Individually, we were overwhelmed and lacked the resources to tackle the issue but through collaboration and partnerships, we could pull our resources and work together to gain better oversight of these operations. In 2011, 7 local health departments in southern New Jersey met to discuss what actions we could take that would lead to reducing our overwhelming workload and increase the protection of the publics health. Our combined population that we service is 1,397,00. We realized we could make an impact and formed the Southern NJ Mobile Task Force to address these issues together. In 2013, there were approximately 860 mobile and temporary food vendors in the jurisdiction of the South Jersey Mobile Task Force. One of the tools utilized and incorporated into our processes is an Event Coordinators Application which lists all food vendors scheduled to serve at an event with whom we reach out to ensure they are approved and inspected mobile food operators. Event coordinators have been a great asset in our success in reaching many of these food operators. Currently, our collaboration with neighboring health departments, partnerships within our communities and with other agencies has lead to: Significant reduction in staff time in review of applications Ability to handle last minute applications Improved communication with event coordinators and food vendors Ensuring adequate bases of operations are utilized for safe food production Regulatory consistencies across jurisdictional lines Encouraging legitimate businesses through required documentation such as tax certificate of authority The collaboration of the Southern NJ Mobile Unit Task Force is the first of its kind in New Jersey. To our knowledge, this may be the first of its kind in the country. Our task force was approached by our colleagues at the local, State and Federal level to speak or provide information on our practices. This practice was based on need rather than evidence.      
Food Safety
The goals and objectives of the South Jersey Mobile Unit Task Force were to: Increase efficiency and resources through collaboration in the application and inspection process Improve regulatory consistencies across jurisdictional lines through use of shared processes and standardized forms Provide for better tracking of mobile food vendors through home base health department oversight and information sharing To achieve these goals, representatives from seven local health departments started meeting in 2011. Immediately, we discovered that we didn't have consistency amongst our departments in our interpretations of a mobile retail food establishment.  We realized that we each viewed mobile retail food establishments differently. Additionally, we each had multiple application forms and typically separated mobile from temporary facilities. In many cases, our applications did not capture pertinent information and were not required annually. Our first step, using the state definition, was to change the mindset of inspectors and their perceived idea of mobile units. By reviewing the state code together and adapting the broader definition of a mobile food establishment, we acknowledged that a single application could encompasses all types of mobile units both with and without wheels such as tabletop, pushcarts, food preparation vehicle, refrigerated vehicles, etc. and including year round, seasonal and temporary mobile vendors. Our second step, was to research and discuss what needed to be included in the application to ensure that our focus was on food safety. During this process, we reviewed all of our forms as well as those from other states and the Association of Food and Drug Officials (AFDO). The result is a 4 page application seeking information that would ensure the food facility has the means to operate in compliance with the regulations. The application includes general information for identification and contact purposes; the type of mobile unit listing facilities and supplies for sanitation and personal hygiene; a schedule with operational locations, dates & times for inspectors ability to locate and inspect; the description of food operations including a list of menu items, food source(s), preparation location for each (vending site or servicing area), equipment utilized for cook/cool/reheat/hot and cold holding; and power sources; servicing area section to be completed by the owner of the approved establishment (servicing area) specifying what the mobile operator is permitted to utilize at their establishment and when they have access to the facility. The last page is primarily for administrative use but provides a list of documents that must be provided by the applicant as part of their application. Once the Mobile Retail Food Establishment Application form was completed, our subsequent third step was to generate an Amendment/Renewal Application for easy modification of the original approved application to reflect a change in menu, equipment, servicing area, operating location, etc.. Additionally, this application can be utilized to update an expired temporary application approval issued within the same calendar year. We also agreed to utilize an Event Coordinator Application listing all food vendors and their contact information for a given special event. This form was developed by Camden County and has proved to be a key tool in identifying and tracking food vendors. It was accepted by all without modification. Lastly, our fourth step was the development of instructions for the completion of the application in English and Spanish. This guidance not only takes the applicant through the application step-by-step, it also provides resources to further assist the applicant (ie. NJ Department of Treasury website and contact information).  Through the development of our forms and processes, we agreed upon some organizational and operational rules. One, the mobile unit's base of operation (location of servicing area) determined which health department would review the application. We agreed that we would conduct pre-operational inspections of each unit at the servicing area as part of and prior to application approval. Sometimes, this means we are reviewing and inspecting units that will not be operating in our own jurisdiction, other than use of a base of operations. However, we are the best ones to review the ability of a mobile unit to safely produce food in a commercial kitchen in our own area. Two, we agreed that we would only accept approved applications from each other to eliminate the chance of falsification of approvals. Three, we agreed to ask for driver's licenses, vehicle registrations and Certificates of Authority (Sales tax identifications) to encourage more legitimate businesses and to increase our ability to track vendors in case of a foodborne outbreak. For out of State vendors, we agreed that whoever conducts the first full application review within the year would share it with the rest of the task force. Finally, when all forms and processes were completed, one health department within the task force volunteered to run a trial on these new applications and processes before the rest of us rolled it out. As a result, we made some minor alterations. In 2012, each health department within the Task Force sent the new application forms & instructions to all of our known mobile units and event coordinators. The first year was a little more difficult as it involved new forms and a new process. As a result, we had to spend more time with the vendors in completing the applications this first year. The second year, we made a modification to the application in response to comments from the vendors to make things clearer. Since then, the process is easier on the vendors and us. No modification was made to the 2014 application. Other stakeholders included NJ Division of Taxation, the Local Fire Chief and the NJ Department of Health. The Division of Taxation provided information on Certificates of Authority and promised to help us track mobile units if we ever had an outbreak or other emergency. Bill Manley from the NJDOH reviewed the process and was very supportive. In 2014, a local Fire Chief talked to us about some fire safety issues related to temporary vendors' tents and hot equipment. Vendors had commented to us that Health inspectors and fire inspectors required very opposite placements with regards to overhead protection. We addressed this in our 2014 application reviews. The only start up cost for us was the time involved in the meetings.
Our primary goal was to increase efficiency and to reduce redundancy of the application review process. Our staff was overwhelmed before we implemented this practice when they had to review every application of every mobile unit and temporary vendor coming into each jurisdiction. With this practice in place, the number of applications that needed to be reviewed by our Health Departments was reduced by an average of 29% in 2013, which correlated to 254 less applications. The range of reduction was 19% to 37%. A typical application with a "pre-open" inspection takes at least 1 hour of staff time. Each task force member determined their own reduction. Our second goal was to be more consistent in our enforcement of our State regulations with an emphasis on risk factors. While we see that consistency greatly improved and hear feedback from the vendors that we are more consistent, we have not determined a way to measure that aspect yet. However, the fact that all involved health departments within the Task Force are utilizing standardized forms and adhering to established organizational and operational rules is documented proof that we are being more consistent amongst our departments and within our perspective jurisdictions. Additionally, we maintain communication frequently throughout the year and continue to meet 1-2 times per year to maintain the integrity of the program through review of continuous quality improvement factors and to discuss any issues, comments or ideas that may arise (such as coordination with fire code requirements). Our last goal, was to provide a means for better tracking of mobile vendors. As a result of this task force, we now can contact the approving Health Department for information about the vendors that they review. Communication has increased greatly between our departments, event coordinator's, other agencies (such as municipal officials and NJ Dept of Taxation) and our applicants. The sharing of information and increased communication is essential to this program and allows for the discovery and tracking of mobile food vendors in the southern region. We are very pleased with the efficiency of our review process. We have not made any modifications in this current year as a result of these findings. However, another Health Department on our northern border, Burlington County, has contacted us about joining the task force. Our meeting with them will be in November. Although this will most likely increase the number of identified mobile food vendors from an added jurisdiction of another participating County, it should provide a further reduction in the number of applications to be reviewed due to the sharing of information with yet another county health department. In addition, we are currently discussing the possibility of conducting a risk factor study with data from 2012 to data in 2015. While this was not one of our primary goals, we believe we may have reduced the incidence of risk factors along the way. Our educational efforts that are built into the application should be affecting the incidence of risk factors.
We definitely learned that sharing and collaborating can save us time and be even more effective than each of us reviewing the applications on our own. We learned to communicate with each other, something that was not very common before the task force was formed. By collaborating with our partners in this task force, we have increased our efficiency and lightened the load on our current resources. We are all very busy. This practice is quite sustainable. The interest and feedback from inspectors, support staff and applicants is positive and shows that there is buy-in amongst the people adhering to these established processes and standardized forms. The interest amongst our peers and colleagues indicates that there is a need everywhere for improved mobile retail food establishment oversight. We all want the system to work and continue to meet 1-2 times a year to review the process and resolve any issues we have. We maintain communication frequently throughout the year and continue to meet 1-2 times per year to maintain the integrity of the program through review of continuous quality improvement factors and to discuss any issues, comments or ideas that may arise (such as coordination with fire code requirements). The sharing of information and increased communication is essential to this program and allows for the discovery and tracking of mobile food vendors in the southern region. By reducing the amount of applications reviewed by 29% (254) in one year, we saved at least 254 hours of staff time total in all of the member departments.  We will add new members whenever possible and include them in all of the decisions.  
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