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can be tenacious even in the presence of good handwashing. Inspectors should observe employee use of utensils and gloves during the preparation and service of ready-to-eat foods and ingredients, such as salads and sandwiches.

If ready-to-eat food is touched with bare hands, inspectors will need to address several questions in order to make the appropriate on-site correction recommendation. The answers to the following questions should provide enough information to determine the likelihood of occurrence of hazards transmitted by bare hands and should be the basis for making a recommendation for on-site correction:

  • Does the facility have an employee health policy to identify, restrict, and exclude ill employees?

  • Did the employees working with the food in question effectively wash their hands and are handwashing facilities adequate?

  • Is there an approved, alternate procedure to no bare hand contact in place and was it followed before the bare hand contact?

  • Has there been an opportunity for the employee’s hands to become contaminated?

Inspectors should examine the location of handwashing sinks in relation to where food is being prepared. Many jurisdictions use a basic distance measurement as a guideline when considering the location and number of handwashing sinks required in a food establishment during the plan review process. While this information can be used to assist with the review process, it should not be used as the sole basis for determining whether there are an adequate number of handwashing sinks or whether the handwashing sinks are conveniently located.

Special emphasis should be placed on spacing in and around fixed equipment, the expected staffing, and the flow of food throughout a food establishment. For instance, a kitchen may be 30 feet in length and 12 feet wide. Although the size of the kitchen may dictate only one handwashing sink using a basic distance measurement, if a prep table the length of the line is placed between the line and the handwashing sink, the handwashing sink may not be conveniently located. Likewise, one handwashing sink located at the end of cook line is useless to employees working at the other end if there is limited space for employees to go around one another during busy periods.


Assessing Compliance with Approved Procedures

When conducting certain specialized processes, variances and HACCP plans are required by the Code. This is because such processes carry a considerable risk if not conducted under strict controls. For food establishments conducting specialized processes, each inspection should involve a review of the written variance, if applicable,

Annex 5 – Conducting Risk-based Inspections 532

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