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Assess Active Managerial Control of Foodborne Illness Risk Factors and Implementation of Food Code Interventions

Although some food establishments have formal HACCP plans, many do not. Even without a HACCP system, every food establishment needs to have active managerial control of foodborne illness risk factors. This may be achieved through several means, such as training programs, manager oversight, or standard operating procedures. For example, some food establishments incorporate control measures into individual recipes, production schedules, or employee job descriptions to achieve active managerial control.

While a person in charge may require the maintenance of in-house written records by employees to ensure that monitoring is being performed using the correct method and at the proper frequency, foodborne illness risk factors may be managed without the use of formal record keeping. Monitoring, whether through direct observations or by taking appropriate measurements, is by far the most important step in ensuring food safety. If an operator is effectively monitoring all critical activities in the food establishment and taking corrective actions when needed, safe food will result. With a few exceptions, maintaining formal records at retail is not required; therefore, records may not be in place for use during the inspection. As a result, it will be necessary to use direct observations and interviewing to determine whether a food establishment is adequately monitoring foodborne illness risk factors in their existing food safety management system.

This section provides a comprehensive discussion of how to assess the active managerial control of each of the foodborne illness risk factors and the implementation of each of the Food Code interventions. Assessment of active managerial control involves more than determining compliance with Food Code provisions. In assessing whether the operator has active managerial control, inspectors should observe whether the operator has established the appropriate control measures and critical limits and whether appropriate monitoring and corrective action procedures are in place and followed. In addition, inspectors should assess whether managers and employees are knowledgeable of food safety principles and critical practices and procedures necessary to prevent foodborne illness. If during the inspection inspectors observes that control measures are not being implemented appropriately to control risk factor occurrence, immediate corrective action must be taken.

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Demonstration of Knowledge

It is the responsibility of the person in charge to ensure compliance with the Code. Knowledge and application of Food Code provisions are vital to preventing foodborne illness and injury. Data collected by FDA suggest that having a certified food manager on-site has a positive effect on the occurrence of certain foodborne illness risk factors in the industry.

Annex 5 – Conducting Risk-based Inspections 522

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