Health Inspections

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If someone asks you what health department inspectors look for first when they show up at your foodservice operation, you might say cleanliness, employee hygiene, proper temperatures, or even good record-keeping.

But another less-obvious area, often overlooked by operators, is client attitude, according to industry insiders. "The first thing is your attitude, the attitude you project to the inspector," insists Carl LaFrate, pres. of ProCheck Food Safety Consultants, Inc. in Baldwinsville, NY. "It's the most critical thing you do. If the inspector identifies you as someone who doesn't care, or someone who thinks this isn't a priority in your total operation, then you are labeled as someone who's neglectful—and the rigor of the inspection is more intense."

"I think what we're seeing is a shift to a HACCP-based inspection policy by departments of health around the country," notes Mike Dunne, dir. of quality assurance and food safety Sodexho. "They're starting to come in and say, 'Show me what you do to prevent the foods from becoming bad. Show me your documentation, show me your training. Show me that you have control of the food products in reference to their time, temperature and cross contamination.'"

Be proactive: How does an operator show an inspector he's concerned and interested? "That's simple," says LaFrate. "Your number one objective is to identify your potential risks. Indicate what the potential risks are in your operation and explain what you have in your system to control those risks."

More great advice: have an outside auditing company handle food safety and let the inspector know about it. "They really like that," LaFrate says. "They have such a small snapshot in time after they walk through your door. Plus, they're overloaded with work—90 out of 100 operators are not up to standard. Inspectors want to come in and find something that says, 'These people have a system in place. They've got outside, unannounced—this is critical—auditing being done to verify their food safety program.'" With that in place, he adds, inspectors are "much less likely to get that rigor going and really tear you up."

Looking for time: Inspectors are also looking for time—yours. "One of the biggest mistakes operators make is not accompanying the inspector while he makes his rounds," says LaFrate. "They find a reason not to spend the time one-on-one with him." Here's what LaFrate instructs his people to do when the inspector arrives: "Say, 'I'll be with you in a minute.' You can't stop him dead in his tracks because he'll think you're going to hide something. You go with him. You have a pen and a piece of blank lined paper with you. Every single thing he mentions that has a negative connotation, immediately write up and immediately correct, if possible, particularly if it's important. He'll write less notes that way."

Listen to the inspector: Your response before the inspector's eyes is crucial, he explains. "If it's a critical problem, you need to stop your operation immediately and do the correction. If you don't, then you imply to him that it's not a big priority."

He says he has heard of operators who hear an inspector tell them that the temperature reading on their food is wrong "and just continue on with their operation. It enrages the health inspectors."

Inspectors are also looking for handy, properly calibrated thermometers and authentic-looking records. "If you keep some type of cooking log, and I'm doing an audit, I'll ask you for your records. You pull them out and all I see are columns of numbers—and here's the worst-case scenario—that are all written with the same pen, the same handwriting, with basically the same number, say 160, 160, 160. And when I ask to see your thermometer, you spend 10 minutes trying to find it. Plus, when I compare it against mine, which is a lab-grade thermometer, it's 10 degrees off." Disaster has just befallen your operation, says LaFrate.

"Properly calibrated thermometers and thermometers that are readily available are things inspectors look for right away," he adds. "Temperature control is food safety today."

Lafrate says the companies that are best at food safety view it as a corporate policy. "The companies that are what I would call the 'lower-rung' companies, all they want to talk about is the health inspector. They hand me a stack of paperwork, loaded with violations, and say, 'Fix this.'"

Toward HACCP: Sodexho's Dunn, who formerly served as a corporate sanitarian for a large dairy conglomerate, says the days of what many refer to as traditional "floors, walls and ceilings" inspections are over.

At one of his accounts, the local department of health had actually rescinded a building permit for a client because they did not have a HACCP plan for each one of the food items on its menu. "I think that's where we at Sodexho have a huge advantage," he explains. "We are able to go to our menu system, which overlaps with our food safety and HACCP program, and are able to show that we have a HACCP program for each individual food item in our recipe collection. We are able to pull that together and document it very clearly."

That same "very aggressive" county health department in Maryland soon began referring operators to Dunn because of Sodexho's detailed program.

"They actually came back to us on another time and said, 'Mike, we requested a food safety program from someone, they need your help. Can you go back and let them know what we're really looking for?' That's a nice thing to have happen," he adds. "We have to literally provide the (local) department of health with a HACCP plan before we can get a food operating license. This is a huge shift, and I think we're going to see more of it as we go forward."

Food security: Looking ahead, says Dunn, health department inspectors may well come to look not just for food safety but food security, too. "It's a separate discipline outside of food safety. I think that's what we can expect next, and I think departments of health will become involved in that."

Precisely how it will come together is tough to predict. But he says he wouldn't be surprised to see inspectors asking questions like:

How do you know who the people are who work for you?

How do you control the food from the time it leaves a distribution center to the time it comes into your place?

How do you check for evidence of tampering with the food in transport?

"I think we're going to see a huge shift," he notes. "We're starting to see security questions like this now. Our clients are asking for that. I don't think the departments of health would be much further behind," he notes."