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granted that if there are no violations marked, the foodborne illness risk factors are being controlled. This is not necessarily true since the observation of code violations is subject to many variables such as the time of day, day of the week, or duration of the inspection. An inspection system that records only observed violations rather than the actual status of all foodborne illness risk factors, such as whether the risk factor was in compliance, not observed, or not applicable to the operation, may be unable to detect some foodborne illness risk factors that are continually or cyclically out of control.

Another misconception is that training alone will result in foodborne illness risk factors being controlled. While training may help, there is no guarantee that knowledge acquired will equate to knowledge applied in the workplace. In order for knowledge to translate into changed behavior, it must be reinforced and the behavior must be repeated for a period of time sufficient for the behavior to become an ingrained pattern. Another assumption is that regulatory enforcement actions such as citations or administrative hearings or on-site corrections alone will automatically result in future management control. Unfortunately, there is no assurance that any of these actions will result in the long-term control of foodborne illness risk factors.

Long-term compliance may best be achieved through voluntary actions by the operator. If an operator supports the concept that a food safety management system is needed, there is a better chance that long-term compliance will be achieved. The following are ways operators can better ensure long-term active managerial control of foodborne illness risk factors.


Change Equipment and Layout

Critical limits are difficult to achieve when equipment does not work properly. Proper calibration of equipment is vital to achieving food safety. When calibration is unsuccessful or is not feasible, equipment should be replaced. In addition to equipment malfunctioning, poor equipment layout can present opportunities for cross contamination and must be considered. For example:

  • Hamburgers with uniform thickness and weight are not all reaching a safe cooking temperature in a given time. Upon examination, it is determined that the grill is distributing heat unevenly. A new element is installed to correct the problem.

  • Splash from a nearby handwashing sink is seen on a prep table. A splash guard is installed to prevent cross contamination from the handwashing sink to the prep table.


Establish Buyer Specifications

Written specifications for the goods and services purchased by a food establishment prevent many problems. For example:

Annex 5 – Conducting Risk-based Inspections 537

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