By Hal King, Ph.D.
If you search the Internet via Google using the search terms “food poisoning”, “foodborne illness”, “diarrhea”, “vomiting”, along with any restaurant brand name in the United States (just use the word “AND” between the words), you will see that foodborne illnesses and disease outbreaks in the foodservice industry are common – many (including myself) consider foodborne disease outbreaks in the United States to be epidemic. Now during this new COVID19 Pandemic Era where we all may feel like we are in a ship fighting to stay afloat in this huge storm, it’s even more important to ensure consumers are protected from all public health threats including foodborne diseases – which can be the final thing that “sinks the ship”.
According to the recently published data by The U.S. Centers for Disease Control and Prevention (CDC), restaurants continue to be the leading cause of foodborne disease outbreaks in the United States, causing 64% or more of outbreaks each year from 1998–to 2017 (CDC 2019). How can you know if your restaurant business is at risk of causing (or has already caused) a foodborne illness in your customers? Well, one way you can tell is to look at what your key stakeholders (your customers and regulatory experts) outside of your restaurant business are saying about you (just three of the many other pre-assessment questions that should be asked):
- Has your business had two or more customer complaints about the same product during the same week (many being posted on social media) that might include illness (e.g., “made me sick” or “tasted spoiled/old”), allergy (e.g., “didn’t know your product had sesame seeds in it”) or injury (e.g., “bit into the sandwich and found a piece of metal” )?
- Do your health department inspection reports continue to cite critical violations (called Foodborne Illness Risk Factors) which by the very definition directly indicate a risk – and likely sporadic foodborne illnesses are already occurring?
- Do your employees know when they should not work in the restaurant if they are sick, and are you confident that you are properly screening and excluding sick employees, and not allowing them to return to work until they are no longer sick (i.e., not scheduled to work before they are non-infectious)?
If you answered yes to any of these questions (and remember this is not a comprehensive list of the recommended full operational risk assessment questions), you are at risk of causing sporadic foodborne illnesses in your customers and also foodborne disease outbreaks.
The good news is that you can begin to establish the proper controls to prevent all of the risk of foodborne illnesses in your restaurant (many of which you are now using to prevent the respiratory virus COVID19 from infecting employees and customers) that include wellness checks, personal hygiene requirements, environmental mitigation SOP’s, and engineering controls (see: King, 2020). The most important means to actively manage food safety risk (and COVID19 transmission) in a restaurant or any foodservice establishment for that matter is to achieve Active Managerial Control (AMC) of all of these risks by developing and executing a Food Safety Management System (FSMS) deployed by managers at each shift (King, 2016, and King, 2020). A FSMS includes:
- A hazard analysis of your menu processes and operations using what the FDA calls Process HACCP. The use of Process HACCP in retail foodservice establishments is based on HACCP principles (to enable HACCP applications in non-food manufacturing environments like restaurants), where identified biological (e.g. Salmonella or norovirus), chemical (e.g., a pesticide or allergen), and physical (e.g., a bone in a chicken nugget or piece of metal in a soup) hazards are placed under controls with daily management by a certified manager (the FDA calls these a Certified Food Protection Manager- CFPM) to eliminate these hazards in food preparation processes that include receiving, storing, preparing, cooking, cooling, reheating, hot holding, and servings foods (FDA 2017),
- Identification of where and how the hazard will be controlled during operations (or before the ingredients or products are received by the restaurant from its suppliers), and what to do when the control is not in compliance (what corrective action is needed),
- A tool to monitor these controls for the managers during each shift -I recommend digital HACCP mobile technology rather than trying to do this with a paper check list.
It is critical that both managers and food handlers are trained in food safety requirements via an ASNI certified program (which has a foundation from the FDA Food Code, and especially ensure a CFPM is at each shift) so they understand how foodborne illnesses are caused and how to control them. For example, it is critically important that a manager knows when to exclude food handlers from work when they have certain signs and symptoms of illness (and knows how to properly screen employees for them), and food handlers also know when not to come to work with the same. Continuous training and evaluation of all staff to ensure each can demonstrate knowledge of all the food safety hazards associated with the menu being prepared and served is also important (as the menu may change due to Limited Time Offers (LTO’s) or change in supplier ingredients, etc.). It is helpful to ensure managers are also prepared to execute emergency procedures during food safety emergencies.
An example of the processes and actions a manager would perform using a FSMS can be observed using the free mobile app EmergiProtect (see EmergiProtect.com- sponsored by our friends at GOJO inc.). This mobile app isn’t a complete FSMS necessary to apply Process HACCP to your restaurant for all the hazards in your business. However the Emergency Operating Procedures (EOP’s) for the restaurant manager (that include how to screen and exclude employees properly for symptoms of COVID19 and foodborne illnesses including how to use a sick log, see: https://www.emergiprotect.com/sicklog) is a good demonstration of what is needed in a FSMS to ensure controls are established and monitored (in this example, controlling for working sick employees). The app also provides other EOP’s useful to restaurant operators due to unexpected events common to a foodservice business including how to ensure food safety during power outages and boil water alerts (and remain open), and how to prepare for and mitigate the impact of natural disasters.
In this new Era of Pandemic COVID19, the restaurant owner (and the corporate enterprise helping franchised restaurant owners) must ensure the public health not just for foodborne illnesses but also for respiratory diseases in order to remain and thrive in business. Especially now that we are also entering both the norovirus (a stomach flu) and the Flu seasons (another respiratory disease), and we are in the hurricane season where food safety emergencies are likely, ensuring each restaurant is executing a FSMS to prevent these risk is paramount.
Author information: Hal King, Ph.D. is the CEO and managing partner of Active Food Safety (www.activefoodsafety.com ), an advisory services and mobile products company whose partners have developed the new Enterprise Mastery of food safety risk for the food industry. Hal can be reached at firstname.lastname@example.org.
Centers for Disease Control and Prevention (2019) Surveillance for Foodborne Disease Outbreaks, United States, 2017, Annual Report. Atlanta, Georgia: US Department of Health and Human Services, CDC.
Food and Drug Administration (2017) Annex 4. Management of food safety practices- achieving active managerial control of foodborne illness risk factors. FDA Food Code.
King, H. (2016) Implementing active managerial control principles in a retail food business. Food Safety Magazine, FEB/MAR, http://www.foodsafetymagazine.com/magazine-archive1/februarymarch-2016/implementing-active-managerial-control-principles-in-a-retail-food-business/
King, H. (2020) Food Safety Management Systems: Achieving active managerial control of foodborne illness risk factors in a retail foodservice business (Springer). https://www.amazon.com/gp/product/3030447340/ref=pe_41006280_491026320_pe_re_csr_ea_lm?pldnSite=1
King, H. (2020) Breaking the chain of infectious disease transmission in a retail foodservice business. Food Safety Magazine, AUG/SEP, https://www.foodsafetymagazine.com/magazine-archive1/augustseptember-2020/breaking-the-chain-of-infectious-disease-transmission-in-a-retail-foodservice-business/