by Wyman Philbrook
It will depend on what you do and where you are located.
As a food service operator you need to determine what skills and knowledge are required by you and/or your staff members to meet regulatory & company expectations and regulations. These can be broken out into basic and advanced bodies of knowledge based on what your food operation is providing to the public and who your customers are.
Food Safety – A general requirement is that the Person-in-Charge (PIC) has the knowledge and understanding to apply the regulatory requirements in their food establishment. The FDA’s Food Code is a recognized standard that is used in most states.
It is a recommended model from the Food & Drug Administration that is based on input from the Conference for Food Protection (CFP).
The biennial CFP meeting is made up of regulatory, academia and industry representatives who identify problems, formulate recommendations, and develop and implement practices that ensure food safety based on the most current science and generally recognized risks.
The states have the authority to use or adapt the current or past versions of the Food Code as their food safety regulation and add additional amendments to it. Local regional regulatory agencies can add their own supplements, which can be stricter but cannot conflict with the overriding state regulations.
A manager/operator must understand what the town, city, county and state regulations are based on the location of their food establishment. So as an example one state may require a hot holding temperature of 1350 F and another may mandate a temperature of 1400 F based on which version or supplement of the food code they are following or using as a reference.
There are some states that develop their own regulations but the majority use one of the dated versions+ of the Food Code because the research into risk and preventive action have been accomplished.
The CFP currently recognizes 3 food safety training programs that have been accredited by the American National Standards Institute (ANSI) as meeting the requirements of the body of knowledge the PIC should know. (ServSafe, National Registry of Food Safety Professionals (NRFSP) and Prometic) Taking the course and successfully passing the exam will result in a certificate, which has an expiration date.
States have the authority to recognize these certificates, add requirements of retraining & recertification earlier than the expiration or having their own in-state course & certification exam.
Your local regulatory inspector will be verifying the validity of training and certification based on the state & local requirements. Validating is accomplished by checking the certificate, asking the PIC questions and observing the operation on the day of the visit.
The inspector is gauging the knowledge, understanding and the APPLICATION of that knowledge to the food operation. The local requirement may be that there is always a trained manager on site whenever the food establishment is open, so based on the operating schedule there may be a need for more than one individual to be trained and certified in an establishment. Inspectors will also be verifying the knowledge and understanding of line employees as they conduct their tasks. Typical questions an inspector will ask are:
- What personal health symptoms should you report to your manager/supervisor?
- What temperature are you cooking this product to?
- What should the temperature be for the food items in the steam table or salad bar?
- How are you going to cool down this batch of chili?
- When should you wash your hands?
- What should the final rinse temperature be on this dishwasher?
- What should the strength be on this sanitizer?
As a manager part of your responsibility is insuring that your employee understands the requirements for the task that they are responsible for. Some regulations want to see documented food safety training for all the staff.
Advanced Subject Knowledge & Skills
HACCP- Regulatory offices will require that high-risk establishments, high-risk procedures or variances from the state & local requirements need a HACCP plan. An understanding of the HACCP principles and their application in an operation will assist in the development of a plan that addresses the specific risks in a food establishment. There are several organizations, and individuals who are recognized as trainers/instructors of HACCP by the International HACCP Alliance (IHA) and the Association of Food & Drug Officials (AFDO) for Seafood HACCP. Curriculums have been reviewed and approved as meeting the Body of Knowledge required for this specialized system of food safety. Individuals who take the courses will receive certificates with either the IHA seal or from AFDO.
Special Processes- Certain procedures are recognized as carrying unique food safety risks and will require both the HACCP plan previously addressed and specialized training and knowledge. Some of these processes and the required training & knowledge that would be required/expected by the regulatory agency prior to approval are:
Reduced Oxygen Packaging (ROP) – this category includes Sous-Vide, Cook-Chill, Vacuum Packaging and has the risks of Clostridium Botulinum and Listeria Monocytogenes that need to be addressed. Knowledge & training in the process, the equipment, the food product risks and the control measures for the bacterial pathogens would need to be validated & verified. Specific employees that will use the equipment and processes need to be identified.
Smoking- for preservation not for flavor would need to have knowledge verified. Cold smoking of seafood has additional risks.
Curing & Fermenting- require knowledge and understanding of water activity, temperature, pH and the specific food products & seasonings that will be used in these processes.
When using specialized skills and knowledge in your operation you will need to consider having alternates on your staff that can step into the role when a designated individual is not on-site or leaves your establishment. Cross-training and developing replacements for employees have been mentioned in previous columns but are critical when it comes to specific skills and knowledge. Keep your records on training and designated individuals up to date in your establishment and with the regulatory agency. Document all updated training and plan to annually retrain and verify the skills & knowledge of your designated staff. Updates in the Food Code and the industry should always be addressed to insure all risks.
As stated every state and local regulatory law are different and the PIC needs to understand their compliance needs.
There are other functions that have laws & regulations such as human Resource & Employment and Workplace Safety. This column addresses those requirements in Food Safety. In the coming months we will be addressing Cross-Contamination, Cross Contact, Cleaning & Sanitizing.