The Cutting Edge Food Safety Management Partnership Verify Results Train Staff Establish Policy MARICOPA COUNTY ENVIRONMENTAL SERVICES DEPARTMENT Maricopa County is the 6 th largest County housing 4 million Maricopa County entertains up to 4 million guests per year Maricopa Environmental Services is dedicated to provide FSIS inspections to 23,000 permitted facilities Maricopa County current business model is to inspect facilities based on Class frequency CLIMB TO IMPROVEMENT IN FOOD SAFETY Cutting Edge program introduced and initiated First county in 2011/12 Arizona to adopt FDA 2009 Code First recipient of the Innovate Food Technology Award by IAFP Introduction of new 2005 Gold-Silver-No Award program Lead the state HACCP Alliance Program utilizing 2003 Industry SOP and inspection driven on Active Managerial Control Samuel J. Crumbine 2001 Award Winning -03 Program Spearheaded statewide 2001 FDA Food Code Adoption First national program to have a web-based 2000- interactive food inspection 01 web site 2010 Initiate hand-held computer inspections 1996 Initial Risk Based Inspection Frequencies 1995 NEHA 2012 AEC June 2012 1
An increasing demand for inspections with limited resources. Increase staffing Would require 12 additional staff ($609,000) to meet inspection demand. NEHA 2012 AEC June 2012 2
Reduce the number of required inspections Public perception reduced inspections = reduced food safety Industry perception Are we getting what we re paying for? An across the board reduction may take away resources from challenged establishments. Implement Active Managerial Control assessments into current inspection program- Work with industry strengths of Active Managerial Control to create efficiencies within the current inspection program. Food Modernization Act wins approval 2009 FDA Food Code adopted NEHA 2012 AEC June 2012 3
Implement assessing degree of Active Managerial Control as the new approach in current inspection program. THE CUTTING EDGE PROGRAM Promote Active Managerial Control & Reinforce Food Establishments Food Safety Systems Create Inspection Efficiency for the Department and Industry Partners 2009 FDA FOOD CODE, ANNEX 4 Active Managerial Control Additional measures must be taken on the part of operators and regulators to better prevent or reduce foodborne illness. (Active managerial control) embodies a preventive rather than reactive approach to food safety through a continuous system of monitoring and verification. NEHA 2012 AEC June 2012 4
2009 FDA FOOD CODE, ANNEX 4 Active Managerial Control Regulatory inspections and follow-up activities must also be proactive by using an inspection process designed to assess the degree of active managerial control regulators must assist operators in developing and implementing voluntary strategies to strengthen existing industry systems to prevent the occurrence of foodborne illness risk factors. 2009 FDA FOOD CODE, ANNEX 5 Risk Based Inspections inspectors continue to have limited time in which to complete inspections. This does not negate the need to thoroughly identify and assess the control of foodborne illness risk factors during each inspection. Even with limited time, inspectors can focus their inspections on assessing the degree of active managerial control an operator has over the foodborne illness risk factors. Three key elements from industry: 1. Criteria for participation and disqualification 2. Keep it simple! 3. What s in it for us? NEHA 2012 AEC June 2012 5
QUALIFICATION CRITERIA Establishment is a permitted Class 2-5 food establishment Establishment has a Certified Foodservice Manager (CFM) on staff, where required. A CFM and/or Person In Charge (PIC) is present during operational hours. Within 30 days of being hired, all Food Service Workers must obtain a Food Service Worker card. Permit does not have any unresolved legal action. QUALIFICATION CRITERIA THREE STEPS TO ACTIVE MANAGERIAL CONTROL NEHA 2012 AEC June 2012 6
ESTABLISH POLICY General Standard Operating Procedures (SOP s) must be developed for the following foodborne illness risk factors, as applicable to the operation: Cooking Temperatures Cooling Reheating Cold Holding Hot Holding Hand Washing / Bare Hand Contact Cross Contamination Food Contact Surfaces Approved Food Source Employee Illness TRAIN STAFF Employees must be trained and demonstrate compliance with the establishment s Standard Operating Procedures, including taking corrective action when needed. VERIFY RESULTS Verification is to ensure the activities described in the food safety Standard Operating Procedures are being performed. The methods for verifying these activities are done properly should be outlined in the Standard Operating Procedures. Verification should occur at a frequency that can ensure the Standard Operating Procedure is being followed continuously. NEHA 2012 AEC June 2012 7
VERIFY RESULTS Verification activities may include Record keeping, such as maintaining log sheets. Periodic self inspections. Observing that person(s) are carrying out the critical procedures correctly. Observing monitoring is being done as planned Reviewing the monitoring records Ensuring that corrective action was taken when the critical limit was not met Confirming that all equipment, including equipment used for monitoring, was operated, maintained and calibrated properly STANDARD OPERATION PROCEDURE REVIEW Enrollment requires a review of the establishment s Standard Operating Procedures. This review can occur one of two ways: 1.The inspector can review the written procedures on site during a routine inspection 2.The operator can submit the written procedures to thecuttingedge@mail.maricopa.gov. NEHA 2012 AEC June 2012 8
STANDARD OPERATION PROCEDURE REVIEW The review will be to ensure the policies meet minimum Maricopa County Environmental Health Code requirements and contain basic procedural steps for ensuring active managerial control over the applicable foodborne illness risk factors. Written copies of the Standard Operating Procedures must be kept on site at the establishment. The Department will not keep copies of these procedures on file. VERIFICATION VISITS Verification Visits will replace the establishment s routine inspection during every other regularly scheduled visit. NEHA 2012 AEC June 2012 9
VERIFICATION VISITS The purpose of the verification visits is to interactively look at the outcome of the active managerial control plan for each of the 10 applicable risk factors. Where active managerial control is lacking, a root cause analysis will be conducted to determine why policy, train, and/or verify. VERIFICATION VISITS The following items will also be evaluated during the Verification Visit: A Certified Food Service Manager is on staff and a Certified Food Service Manager or Person in Charge is on duty at all times. Verify standard operating procedures are still current based on menu and/or procedural changes. Verify active managerial control (policy, training, and verification) related to the 10 risk factors, as applicable, using Assessment Form. If the establishment has a variance requiring a HACCP plan, verify the critical control points as approved by the Department. NEHA 2012 AEC June 2012 10
NON-COMPLIANCE A Verification Visit will be changed to a comprehensive routine inspection when one or more of the following are observed during a Verification Visit: Person in Charge or Certified Food Service Manager is not present at time of Verification Visit. Imminent Health Hazard. Three or more out of compliance risk factors from the Assessment Form. NEHA 2012 AEC June 2012 11
NON-COMPLIANCE A Verification Visit will be changed to a comprehensive routine inspection when one or more of the following are observed during a Verification Visit: Person in Charge or Certified Food Service Manager cannot correct out of compliance risk factor(s) at time of the Verification Visit. Non compliance with critical control points related to variance or conducting operations without a required variance (this only applies to variance processes that require a HACCP plan). NON-COMPLIANCE When an inspection is changed from a Verification Visit to a Comprehensive inspection, the usual routine comprehensive inspection will be conducted, including asking the operator if he/she would like to participate in the Grade Card system. The next visit will be scheduled as a Verification Visit (unless comprehensive inspection results in establishment being disqualified from the Cutting Edge Program). NEHA 2012 AEC June 2012 12
DISQUALIFICATION Disqualification from the Cutting Edge will result when one or more of the following situations occur: An inspection purpose is changed from a Verification Visit to a comprehensive routine inspection during two consecutive visits. An establishment is found in operation with an imminent health hazard present. An establishment has an unresolved legal action. An establishment earns a D grade during a routine comprehensive inspection. DISQUALIFICATION Disqualification from the Cutting Edge will result when one or more of the following situations occur: Lack of active managerial control is demonstrated during Environmental Related Illness investigation where compelling evidence that the point of origin of an outbreak or communicable disease was at the establishment in question. The Environmental Related Illness Program will make this determination and will notify the inspector. The inspector will be responsible for notifying establishment of disqualification. NEHA 2012 AEC June 2012 13
AWARDS AND RECOGNITION Every establishment will receive a Cutting Edge participation seal upon enrolling in the Program. AWARDS AND RECOGNITION Successful completion of a Verification Visit will result in an A under the Grade Card System. AWARDS AND RECOGNITION Participating establishments will be recognized on the Department s website. NEHA 2012 AEC June 2012 14
OUTCOME INDICATORS GOAL Increase active managerial control to decrease the occurrence of food borne risk factors in the establishment. OUTCOME INDICATOR Occurrence of top 10 food borne illness risk factors from 2008 Maricopa County Environmental Services Voluntary Standards Baseline survey compared to results of future survey (big picture view). OUTCOME INDICATORS GOAL Increase active managerial control to decrease the occurrence of food borne risk factors in the establishment. OUTCOME INDICATOR The occurrence of Priority violations observed during routine comprehensive inspections after joining program compared to occurrence of violations prior to joining. NEHA 2012 AEC June 2012 15
OUTCOME INDICATORS GOAL Create efficiency to meet inspection demands by enhancing risk based inspection approach. OUTCOME INDICATOR Overall inspection times by permit class and type. OTHER OUTCOME INDICATORS For which risk factor is a lack of active managerial control found most frequently? (of 10 FBI risk factors) What is the most common reason for lack of active managerial control over a particular risk factor? (Policy, Train, or Verify) CURRENT PROGRAM PARTICIPATION 485 class 3, 4, and 5 permit total Cutting Edge participants 10514 12000 10000 8000 6000 10514 4000 2000 0 class 3, 4, and 5 permit total 485 Cutting Edge participants NEHA 2012 AEC June 2012 16
POLICY REVIEW 477 out of 485 participants benefited by developing policies or modifying existing policies to align with the 2009 FDA Food Code. VERIFICATION VISITS RESULTS 926 Verification Visits have been conducted 99.7% received an A grade card No enforcement action or reports of foodborne illness TESTIMONIAL was very simple to implement. the greatest benefit from this program is the additional review of our policies and procedures it adds a new level of awareness receiving very positive and helpful feedback on best practices in the field for our continued improvement. (Verification) visits (are) a great opportunity to review in detail our current program and converse on any new requirements either recently implemented or in the pipeline. Cutting down on the amount of comprehensive inspections is defiantly a plus however the sharing of knowledge and education through the verification visits is a true benefit. -Paul Carter The Phoenician Resort Scottsdale, AZ NEHA 2012 AEC June 2012 17
John Kolman, R.S., MBA Director Maricopa County Environmental Services Department 1001 N. Central Avenue, Suite 401, Phoenix, AZ 85004 Desk: 602.506.4847 Fax: 602.506.5141 Jkolman@mail.maricopa.gov esd.maricopa.gov Special thanks to Susie Sid, Kathryn Garcia, Michelle Roemersberger, Rebecca Vanderplaats, Tim Hurst, David Morales, Johnny Dilone, David Ludwig, and Doug Kober. NEHA 2012 AEC June 2012 18