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Food Protection - Not Just Inspection By Richard J. Robbins

Many people, when they think of the Health Department's food protection program, first think of an Inspector searching in the dark corners of restaurant kitchens for dust, dirt, and signs of dreaded cockroaches. Unless they have seen our trained staff of professional Sanitarians in action, this may be as far as their thought goes.

In reality, the food protection program consists of much more than inspection. The other elements are Hazard Analysis and Critical Control Point Review, Food Worker Training, Food Borne Illness Investigation, and Enforcement.

Even the inspection part is different from the common perception. While cleaning is important, the emphasis is on food and people. Some of the catch phrases are: "Hot foods hot," "Cold foods cold," "No handling of ready-to-eat foods without gloves, tongs, deli paper, etc.," and "Don't work when you are sick." Sanitarians view the activities in the kitchen as part of a process where all the food has a past, a present, and a future. The inspection is not just a snapshot. Many problems are only elucidated by careful interview.

Hazard Analysis and Critical Control Point Review (HACCP) is a procedure for studying the preparation of a food product from the delivery of the raw ingredients through to the service of the final leftovers. Full HACCPs can take several hours, so most are done as mini-HACCPs where interview skills play a large part. Once the process is documented, control points are injected which prevent or control the growth of pathogenic micro-organisms. The control points may be cooling portion sizes, cook temperatures, or re-heat temperatures. When the HACCP is completed, it can be used as a safe recipe for the preparation of the particular food product.

Food Worker Training has become a useful means of gaining compliance with the requirements of the food code. Most people are law abiding citizens who take pride in their jobs. Appropriate training in food handling skills provides the information and the tools food workers need to do their jobs in a way that promotes public health and conforms with the code. The Department currently provides training on request in English and Spanish. The programs are tailored to the needs of the facility.

Foodborne Illness Investigation is a means to gain direct insight into the causes and effects of foodborne illness. Typically, a report is received that one or more individuals consumed a meal and then experienced gastrointestinal symptoms. Through interview, information regarding dates, times, symptoms, duration of illness and foods consumed are gathered. This information is then compared to that resulting from various pathogenic agents and an initial hypothesis (a guess) is formed. An inspection, interview, and most likely one or more mini-HACCPs are conducted at the suspect facility. Possibly, samples of food or stool may be collected for laboratory analysis. When all the data is in, a conclusion may be made as to the cause of the outbreak and appropriate controls instituted at the facility. However, in too many cases, a long time has gone by before the initial report or the data is incomplete and no causative agent can be determined.

Enforcement is another useful tool to gain long term compliance with the Sanitary Code. It may be as simple as a directive letter, and informal hearing conducted on the district level, or a formal hearing at the central office with attorneys and a stenographer. Typically, enforcement efforts are used following a pattern of noncompliance or an especially onerous violation of the Code. Directive letters and informal hearings do not result in penalties. Formal hearings can result in significant penalties up to $1000.00 per violation per day and public notification through the newspaper.

To accomplish all of the above, a Sanitarian has to wear at least three hats: Teacher, Scientist, and Law Enforcer. The balancing act is to know under what circumstances to wear the appropriate hat.