HACCP Inspections: Active Managerial Control

The FDA’s stance on Active Managerial Control

More now than ever, the active communities of review and ranking sites have provided a clearer window into restaurants and food establishments, and needless to say, this transparency and honest feedback is invaluable to owners and consumers alike. With that said, restaurant owners and operators are also tightening their food safety management system (FSMS) to prevent spoilage and bacterial infestation. In the larger picture, these practices reflect well on the operational capability of the establishment, and also serve to prevent the stigmata of food inspection violations. 

The FDA has long published documentation on prevention and adherence to the HACCP (Hazard Analysis and Critical Control Points) preventative approach for food service. Still, many restaurant owners and operators are unaware or unfamiliar with these practices and suggestions, and to this day, health inspectors are suspending licenses and punishing these businesses for failing to comply. While reviews and consumer feedback are invaluable to the welfare of a restaurant or food establishments, these inspections are not to be overlooked or ignored. The following explication of active managerial control serves to inform you about the basics of HACCP, and what you should expect from a visit with the health inspector.

One of the primary objectives of a health inspector is to observe the level of active managerial control, or as the FDA defines “the purposeful incorporation of specific actions or procedures by industry management into the operation of their business to attain control over foodborne illness risk factors.” In short, such actions and procedures are a preventative and proactive approach to food safety, as opposed to reactive post-disaster tactics. Following this approach is critical for any food establishment or restaurant to ensure best practices in the kitchen. The above statement specifically cites foodborne illness risk factors, of which are outlined below.

• Food from Unsafe Sources (farms, meatpacking plants, etc)
• Inadequate Cooking (to subpar temperatures)
• Improper Holding Temperatures
• Contaminated Equipment (bacteria, mold, dust, etc.)
• Poor Personal Hygiene (for line cooks, chefs, and prep personnel)

The health inspector will be focusing on these five points of failure as they represent the most sensitive areas for food safety and food consumer protection. There are a number of tactics that can be used to avoid these risk factors, and while some dwell in the neighborhood of common sense, others are not so obvious. The following food safety management tips are taken directly from the Regulator’s Manual for Applying HACCP Principles to Risk-based Retail and Food Service Inspections. Consider this a quick ‘cheatsheet’ for your next inspection and be sure to employ as many of these smaller strategies to conquer the larger goal of safe food practices. These represent FDA-approved guidelines for HACCP compliance.

• Standard Operating Procedures for critical operational steps in a food preparation process. This includes cooling, heating, reheating and holding.
• Recipe Cards or ‘cheatsheets’ that contain specifics steps for individual item preparation. This should include important boundaries such as final cooking temperature, verification and directives for temporary storage.
• Monitoring procedures for preventing bacterial growth, spoilage and proper cooking/holding temperatures.
• Record keeping. These include temperature records, employee records and equipment maintenance and upkeep documentation.
• Health policy for restricting ill employees from the establishment.
• Specific goal-oriented plans, such as Risk Control Plans (RCPs) that are used to control specific and more incremental risk factors.

In the next piece, we’ll dive further into these incremental risk factors and RCPs that can easily be employed in your restaurant or food establishment. Remember that while the world of online reviews can boost your consumer reputation, the food safety management suggestions from above are equally as important for the long-term livelihood of your business.