Norm Faiola

Consider how many operating systems are within your property: engineering, accounting, point-of-sale, phone, human resources, and, hopefully, a food safety system, to name a few. All must function in concert to produce desired outputs and maintain a stable hospitality environment.

QUESTIONS TO CONSIDER
How do we establish the systems’ initial parameters? How do we determine if they are functioning properly? How do we know if we consistently meet our expectations? What do we use as benchmarks? When do we need to make modifications to meet changing demands and conditions? How do we know when changes are needed?

Let’s look at a food safety system (FSS) and some of the questions posed above.

What is the goal of the FSS? One perspective is for the system to consistently produce safe food & beverage. We must be able to produce food & beverage in the required volumes over a set time period to be delivered and served to needed locations and guests. Quality comes into play, but it is secondary to safety. Our FSS must be a dynamic enterprise. The hazards we face daily are not static, and the FSS we develop and maintain must be constantly modified and improved to meet new challenges and conditions. Core to meeting our overall goal is creating and maintaining a HACCP-based FSS.

A QUICK REVIEW
Hazard Analysis and Critical Control Points (HACCP) is a system- based approach to food & beverage. Hazards are identified (biological, chemical, or physical) in our system (operations), and we determine what controls (critical control points and critical limits) are needed to prevent, reduce, or eliminate hazards. Our system must be designed and maintained in a way that lets us be confident the operation (management and employees) has taken all reasonable precautions to minimize the risk of foodborne illness.

SAFETY INSPECTION VS. SAFETY AUDIT
How do we know if our systems are working? Inspections and audits are critical to answering this. I want to make a distinction between a food safety inspection and a comprehensive food safety audit. Inspections are commonplace in our operations, with audits being less frequent. Building inspections, fire inspections, accounting audits, and occasional state tax and IRS audits are examples.

In many cases, we label the review (rating or grading) of our food & beverage operations by the county health department representatives an “inspection.” Some of us old timers remember inspections from years ago and called them “sticks and bricks” inspections because the inspector reviewed what was most visible. If we looked clean and tidy, we usually passed. There was little proactive HACCP oversight with this type of inspection.

Inspections from the regulatory side have changed in many locations and, in keeping with HACCP principles, have gone far beyond “sticks and bricks.” Many now experience this more stringent level of review where the operator is asked to show how the system is designed to work and prove that production specifications and policies are maintained. The inspector may ask you to “show us how you make beef stew,” and question what volumes are made and how the product travels through the production system. Records are reviewed, production is observed, and management and employees are asked questions to determine appropriate levels of knowledge and consistency of application.

Audits go well beyond inspections. Comprehensive audits review a system in great detail and as a part of the process conduct inspections. An auditor reviews the food safety system—its design and functionality—and then provides extensive feedback and recommendations. A review of policy and operational manuals, training plans and records, HACCP-based recipes and processing models, and actual processes and related records during peak operational times and across shifts, plus interviews with management and line employees are conducted. A good auditor compares the operation’s stated practice with actual practice over an extended time period.

For example, a one-day review of an operation’s production is not sufficient to determine if the policies and practices as stated in the HACCPbased system documentation are consistently practiced. We want to “see the movie, not just one photo.” It is through observation and by sampling products using established laboratory techniques that an auditor can determine if processing protocols are controlling the hazards identified in the HACCP plan.

I am not suggesting all operations must have audits conducted by outside companies. Internal inspections conducted by staff and, in some cases, audits conducted by corporate personnel, are valuable components of an overall system review. There is value, however, in having a knowledgeable outside entity conduct a comprehensive audit. This new set of eyes and ears can find flaws that may have gone unnoticed. Further, a good auditor with experience (in both food safety auditing and handson operations) can provide the organization with suggestions that may reduce the risk of systems failure and also be cost effective.

Here are some items I would look for, ask for, and allocate time to observe/review if invited into your operation for several days. This list is an abbreviated version of the one I have developed for clients.

• Initial meeting with management to review overall organization and areas of responsibility related to FSSs.
• Information on overall operation including layout, volume of food & beverage produced, number of operations and types of units, guest counts, hours of operation, shift assignments, and menus.
• Comprehensive written policies and procedures review including HACCP plansand HACCP-based recipes and production protocols.
• Training and development program review related to food safety including training program content and records of training conducted. Types of, frequency of, and evaluation methods used.
• Attend in-house food safety training sessions as well as new employee orientation. I would look for the extent and timing of all food safety-related messages and specific knowledge and skills training. What is the organization’s food safety message? How and when is it first delivered, and is a “team approach to food safety” message conveyed at orientation and reinforced at the unit level?
• Review the operation’s standards and requirements for its suppliers’ HACCP program.
• Review inspection reports, both internally and from the local regulatory agency.
• Review time and temperature logs, corrective action reports, calibration logs, and related automated systems reports if utilized.
• Review system failure protocols. Review fact-finding procedures when dealing with guests and product isolation and control in the event of an alleged outbreak.
• Compare stated production processes with observed [processes].
• Walk the property and review flow of goods from receiving to service.
• Observe management behaviors when inside food production areas.
• Observe employee behaviors during all production phases, over several shifts, and at varied times. This includes “graveyard” shifts and offpremise production introduced into the system.
• Conduct comprehensive inspections of all units within the operation, noting positive activities and conditions as well as areas needing improvement based on the operation’s stated policies and procedures and generally accepted practices. Here I look for appropriate and specific HACCP-based procedures as well as standard operating procedures.
• Sample products and send out for laboratory analysis if authorized by management.
• Debrief management of findings after developing a written report providing an overall review as well as a ranked order list of suggested systems modifications or additions.

Inspections and audits are integral parts of a comprehensive HACCP-based food safety system. In-house personnel should be trained on how to conduct them and be given the responsibility to do so.

Auditors from outside firms can provide an unbiased review of an operation and valuable feedback. Select firms carefully. Get references, and be sure they are prepared (and take the time) to understand your operation fully before providing feedback. You should get a “movie for your investment, not just a photo.”

Norm Faiola, Ph.D., associate dean and associate professor, Department of Nutrition and Hospitality Management, Syracuse University. Email Dr. Faiola with questions or comments: nafaiola@syr.edu.