We all read the headlines about foodborne illness outbreaks at top national chain restaurants. Naturally, these big stories attract both the public and the press. But have you ever wondered if the violations that cause these infamous outbreaks are relatively rare events or more common among all restaurants, large and small? That’s a question the FDA tries to answer every fiscal year.
From October through September, the agency’s Office of Regulatory Affairs, which is responsible for all restaurant and commercial kitchen inspections and enforcement, publishes a compilation of their food safety violations, referred to as the annual Inspection Observations. This database lists citations that FDA agents have handed out during routine food facility visits across the country.
Perhaps most interesting about the FDA findings is that the same five categories of violations occur most frequently, year after year: inadequate pest control, unintended contamination, lack of hand washing, poor sanitization, and improper temperature.
Pest infestation is the violation that the public finds especially objectionable, if only that bugs and rodents seem like they should be relatively easy to prevent as compared to say, microscopic organisms, which are invisible. Certainly, the idea of rats leaving droppings in food storage bins or roaches scuttling along kitchen counters is distasteful. But pests can pose a real threat of food contamination as well.
Violations usually take one of two forms: either a lack of adequate screening for pests in general or lack of effective exclusion of pests from specific food processing areas. If a kitchen becomes infested, citations require that the kitchen closes until effective measures are taken to remedy the pest problem.
Contamination citations are hardly limited to pests. Indeed, cross-contamination of produce by bacteria from raw animal products is far more common. Additional sources of foodborne illness are contaminated surfaces, utensils, and processing equipment that are improperly cleaned between uses, allowing harmful pathogens to breed. Other typical sources of contamination include wipe cloths and packaging materials that carry living microorganisms. Citations require that the sources of contamination be sanitized or quarantined from the processing areas.
Contamination and sanitization are closely linked, but restaurants and commercial kitchens can be cited for sanitation violations even if no contamination has yet to occur. For instance, refrigerated units in which raw meats are improperly stored in proximity to raw fruits and vegetables from other foods can be cited. So can dirty mops used to clean floors, soda dispensers that have never been flushed out, or cutting boards used for both raw meat and vegetables. Perhaps the costliest citations are for facilities that fail to maintain cleanliness not only because of neglect, but because of problems with their construction. For example, lack of adequate restrooms is a common issue that requires costly capital investments to rectify.
Although you might think that hand washing would fall under sanitization, the violations are so common that hand washing gets its own category. In fact, the CDC reports that food handlers’ unwashed, exposed bare hands are the most common means of transmitting gastrointestinal viruses and bacteria to foods. All employees who handle food, whether sick or healthy, carry Staphylococcus bacteria on their skin, which they can easily transfer to food products without proper precautions in place.
Hand washing citations can usually be traced to one of three causes: lack of employee mindfulness, inadequate hand washing facilities, or sick employees coming to work. Too frequently, because of poor training or the fast-pace of the environment, employees forget to wash their hands after processing raw meat, handling soiled tableware, taking out the garbage, or using the restroom. Employees required (by law) to wear gloves while processing foods often forget to change them after handling pathogen-prone ingredients, such as raw meat, poultry, and seafood.
In other cases, the fault lies more with management than with the employees. For instance, hand washing facilities often lack hot water, soap, sanitized towels, or air dryers. Sinks must be reserved for hand washing only, rather than shared with dish washing or food prep. There should be enough sinks available so that staff don’t have to wait in line to use them.
Finally, even though management may need every employee to fill a shift due to worker shortages, it’s essential to restrict employees with a certified diagnosis or showing symptoms of cold or flu. Coughing and sneezing are difficult to control and can easily contaminate safety gloves.
Temperature Control for Safety (TSS) foods (formerly called Potentially Hazardous Foods) require temperature monitoring to keep microorganisms at safe levels. If foods are in the Temperature Danger Zone (41 to 135°F) for too long, pathogens can grow to harmful levels and cause foodborne illness. To prevent a temperature excursion, hot foods should be kept hot, and cold foods should be kept cold.
This precaution is imperative during the holding stage. Not only should temperatures of foods in holding trays be continuously monitored, but reheating foods too slowly should be avoided. Most holding equipment, such as a steam table, is not designed to bring up temperatures of foods fast enough to kill pathogens. And leaving containers of hot food, such as stock, at room temperature too long can be hazardous.
The same precaution is essential for refrigeration. Kitchens can be cited for thawing frozen foods outside of the refrigerator, as they can warm up if left unattended. Putting hot foods directly into a refrigeration unit has two dangers: the food may not reach 40 degrees fast enough, or it may increase the overall temperature of the unit above 41 degrees and put all of the stored food in jeopardy.
Given that these five category violations are both common and perennial, every commercial kitchen should keep them in mind and prevent them proactively, in advance of an FDA inspection. If there’s one overarching reason for these violations and citations to keep recurring, it’s failure on the part of management to implement an effective HACCP plan at critical control points.
HACCP is the most recognized best practice of large-scale food service operations and restaurant chains. In fact, the FDA strongly recommends that all commercial kitchens voluntarily create their own HACCP plans, even if not required. A good HACCP plan strictly monitors each point of the food service process: from production, procurement, and handling to manufacture, distribution, and consumption. If a deviation occurs, stringent controls take the appropriate steps to prevent hazardous products from reaching consumers.
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