Every permitted eating establishment undergoes unscheduled inspections by trained public health departments and a bad inspection grade from one of these health officials could cost your restaurant thousands of dollars in lost sales. Corporate franchise executives understand the importance of food safety very well. They tend to view it under the umbrella of protecting their brands, and they have the layers of management and the money required to make it a priority. Similarly, smaller operations also understand its importance of protecting a reputation; however, their more limited manpower and financial means often lead them to make poor food safety choices. These entrepreneurs often become interested in food safety only after a negative event occurred— such as a poor health inspection grade or worse, an epidemic event, say a Food-borne Illness Incident (FBI).
The damaging effects of a poor health inspection grade are grossly underestimated. Their impact and reach goes beyond profit loss. It negatively affects the customer and their decision to patronize, the establishment reputation is damaged and in question, and it may affect employee morale and staff pride.
This article is meant to educate entrepreneurs on (1) how they can prepare for health department inspections through employee training and self-inspections, (2) the health inspection process and what inspectors are looking for, and (3) the health inspection grading system and how to respond to a poor grade.
The key to preparing for your health inspector is to ensure that your staff is educated and then self-inspect — Daily (Self inspection guides can be requested and obtained at f4tllc.com)
While some restaurant employees such as hostess and valet attendants do not handle food, most employees do handle food in some way or another, and they need to have some type of food handlers training (www.f4tllc.com).
Employees who handle food include the following:
- Bartenders cut fruit, make fresh juice, handle dairy, rotate stock.
- Food runners deliver food plates, prepare garnishes, clean plates off.
- Bussers deliver beverages, make hot drinks, clear dirty tables and reset clean tables.
- Servers do some or all of the above and need to understand allergens in prepared foods.
- Hosts may also help deliver food, clear dirty tables and reset clean tables.
- Chefs and cooks handle food from the back door to the plate and keep the kitchen safe.
- Dishwashers clean and sanitize glassware, dishes, pots and pans.
It is a best practice to have as many employees as possible trained in the basics of food safety via a nationally accredited food safety certification. The following is a list of basic topics covered in a food handler’s training and are the more common violations seen during a health inspection:
- How food becomes unsafe
- Good personal hygiene, including how and when to wash your hands
- How to control time and temperature when handling food
- How to measure the temperature of food
- How to purchase, receive, store, cook, cool, and hold foods
- How to label foods
- How to prevent cross-contamination
- What to do if cross-contamination occurs
- How to handle people who have food allergies
- How and when to clean and sanitize
- How to handle cleaning tools and garbage
- How to clean dishes properly
- Knowledge of the most common reportable food-borne diseases
The biggest mistake small operators make when they consider training their staff, is failing to realize that “training” actually occurs before they begin training their employees. The problem is unqualified employees fail to exhibit a functional level of food safety knowledge during the interview process (e.g., do they know when to wear gloves, how long to wash their hands, etc.). Unlearning bad food safety habits can be hard, so it is best to hire those who are already on the right track of demonstrating good retail practices and have a willingness attitude to learn the correct process of your establishment.
Immediate training — Food safety and sanitation operating procedures should be introduced as soon as an employee is hired.
Specifying responsibilities — Start with a clear job description outlining exactly what you want your employees to do when it comes to food safety. They will generally comply with signing a document stating that they fully understand what is expected from them.
Staff turnover — The restaurant business experiences a high rate of turnover for a variety of reasons: most young employees consider a restaurant position just an entry-level job, starting pay for an unskilled employee is low, and some jobs (dishwashing or building maintenance) are not very desirable. As employees move on to better things, you should be prepared to constantly train new staff members. This constant need for training does not come without some cost, and most companies will train the first or second generation of employees before the commitment wanes and employee turnover takes its toll. Entrepreneurs must keep in mind that if a food-borne illness outbreaks were to occur and be traced to their establishment; the financial fallout and bad press could be staggering compared to the effort involved in proper staff training and development.
Self-inspections are an excellent method of self evaluation. It allows an introspective look at your operation and it evaluates what practices are working and what areas need improvement. Some of the common mistakes made by small operations are twofold: 1) not performing them often enough — an issue that stems from lack of manpower/resources, and (2) not fixing problems found during these inspections — a decision that is most often financially driven. Typically, self-inspections should be performed twice a day, before the morning and evening shifts. The first inspection allows you to see if anything happened from the time the restaurant closed down until the first manager/chef arrived in the morning, and most problems (i.e. refrigeration running too hot, freezers not working, broken ice machine, etc.) can be fixed before the morning shift begins. Keep these reports on-site, use them as a teachable examples during training and use them as leverage, if necessary to demonstrate to your health inspector, your active approaches to identifying ongoing issues and your effective plan of abatement.
Cleaning and maintenance schedules
To be in a position to pass your self-inspections (and the health inspector’s inspection), every restaurant should follow Daily, Weekly, Monthly, and Quarterly cleaning schedules. The cleanings should be thorough and cover all areas, including both the front and back of the house and areas outside of the establishment. The list below provides an idea of how often you should be cleaning different areas/items.
• Daily — Sweep and mop all floors; clean all counters, under-counter shelving and refrigeration shelving, small equipment, floor drains, and dishwasher surfaces.
• Weekly — Clean all internal fan guards, refrigeration door gaskets, oven gaskets, underneath fryer wells, the grill vents above grills, inside ice machines, all garbage cans, and the walls around equipment; defrost the small ice cream freezer.
• Monthly — Deep-clean floor drains, ceiling vents, rolling carts, floor mats, and employee lockers.
• Quarterly — Clean outside ventilation filters, internal and external dumpsters, staircases, and storage units.
Maintain all service contracts and ensure that preventative maintenance work is performed according to schedule. They should list maintenance/renewal schedules for various items. Creating a “Food Safety Binder” is preferred, information retained should include, but not be limited to health department inspection reports, self-inspection reports, maintenance and temperature logs from the past three months, fire extinguisher repair reports, exterminator’s reports, etc. Ensure all managers and shift leaders know what is in the binder, where it is located, so should a health inspector want to see proof of maintenance, you can provide some history.
Health Department Inspections
Most operators view a visit from the health inspector as an inconvenience. In fact, many operators hate the health department. This is the wrong attitude to take, but it does explain why restaurants seem to dread health inspections. Inspections are unannounced, but if you are prepared with an educated staff and a history of routine self-inspections, you won’t have any reason to fear the inspector’s visit.
When the health inspector arrives, greet the inspector warmly and ask for identification, this may be an opportunity for someone, without being obvious to make known to the back of the house (BOH) that the inspector is on-site. The person in charge (PIC), should accompany the inspector and take note of any observations. Each health inspector is different and there is no norm when it comes to an inspector’s style. However, there are a few observations most inspectors like to focus on:
- No tiles cracked or missing, lights protected with plastic shields or plastic tubes, air-curtains working at delivery doors, doorways use air pumps for closure. Floors, floor drains, walls, and ceilings clean and in good repair.
- Containers covered and labeled. Gaskets, fan guards, shelving, and all types of door handles clean.
- Thermometers present in all refrigeration units containing proteins. Taking random temperatures of hot and cold foods at all stations to make sure temperatures are maintained at the proper levels for cold holding and hot holding.
- Dining room furnishings in good condition, restrooms properly stocked and in working condition, garbage and trash areas have proper receptacles that are covered and rodent proof, basements are rodent proof and with proper lighting.
- Storeroom door closed, everything stored six inches off the floor and away from walls, cans inverted, boxes sealed closed, no flies or insects in dry ingredients.
- Single-service items wrapped in original sleeve, to-go boxes inverted, cases sealed closed.
- Can opener and blade clean, containers inverted, utensils stored handles up, clean equipment.
- Hair covered, uniforms clean, aprons on, condition of hands (looking for cuts, open wounds, rashes), gloves on, gloves available in a variety of sizes.
- Hand sinks clean, hot water 100ºF +, soap and paper towels available, trash can available with no obstacles in its way.
- Stoves, grills, fryers, vents, hoods, and filters present and clean; kettles working.
- No cell phones in work or food areas, and no beverages, food, or tobacco in back of house.
The most common violations
The following violations seem to be the most common. You can develop your own self-inspection form from these very common violations.
|(A) Top good retail practices violations
Good retail practices violations are low-risk violations that do not require immediate action.
|(B) Top Minor Violations
A minor violation does not pose an imminent health hazard, but it does warrant an immediate correction.
|(C) Top Major Violations
A major violation poses an imminent health hazard that warrants immediate correction and may require closure of the food facility.
|Nonfood-contact surfaces clean and in good repair — This violation refers to items that do not come into direct contact with food and include gaskets, fans, garbage cans, mop buckets, floor mats, shelving, etc.
|| Food in good condition, safe and unadulterated — This violation occurs when food is left out or stored in unsafe areas (e.g., near cleaning supplies or in a restroom), and when ice crystals are forming on food due to improper defrosting and refreezing procedures.
||Proper hot and cold holding temperatures — This violation can occur in reach-in refrigeration lowboys, top-cold holding units, walk-in refrigerators, and on stovetops. Have thermometers present. The only way you can control the rapid growth of bacteria is to make sure food is held outside of the temperature danger zone, which is between 41ºF and 135ºF or 140ºF (the required level depends on your local health department guidelines).
|Equipment/utensils approved, installed, clean, in good repair, and in the proper capacity — This violation refers to household utensils and equipment that are being used in the restaurant. Examples of this violation include aging equipment and cooking utensils, and appliances that are dirty and perhaps not large enough in capacity to handle the demands of the business.
||Adequate hand-washing facilities supplied and accessible — This could also be a major violation depending on how many violations occur. Examples: Lack of hot water, soap, and/or paper towels; a transit cabinet placed in front of the sink, inhibiting access to the sink; missing hand sinks; and not enough sinks in a work space
||Hands clean and properly washed, gloves used properly — This violation occurs mainly when hands are not washed long enough, soap is not used, or gloves are not worn when handling ready-to-eat foods (e.g., when dicing cooked chicken for buffets, etc.).
|Equipment, utensils, and linens: storage and use — This violation refers to equipment, utensils, and linens that are improperly used or stored such that they may become contaminated and need to be replaced.
||Toxic substances properly used, identified, and stored — Examples: When caps fall off chemical containers, when cleaning supplies are transferred out of their original containers into spray bottles and are not relabeled, and when chemicals are stored near food products such as vegetable oil spray.
| Food contact surfaces clean and sanitized — This violation can occur when surfaces that come into contact with food are not washed, rinsed, and sanitized, when sanitation buckets are missing from active food preparation stations, when the supply of sanitizing solution is too low, and when mold and yeast are found on the inside rim/ice chute of an ice machine (ice is a food). Note that all surfaces of an ice machine must be clean, including the scoop and its holding container.
|Floors, walls, and ceiling: properly built, maintained in good repair, and clean — This violation is concerned with the condition and the maintenance of these surfaces and whether or not proper finishes (e.g., durable, skid resistant, nonabsorbent) are used. Violations include holes in wall tiles, wooden walls in the kitchen or at the bar sink, and rugs used on the kitchen floor.
||No rodents, insects, birds, or animals — It is a minor violation when you see filth flies or one live roach, but this violation can close a restaurant down if there is an infestation. Keeping your floors, drains, and corners clean helps to prevent pests, and keeping your doors shut prevents them from flying in
||Communicable diseases: reporting, restrictions and exclusions — This violation can occur when employees show up for work sick (and note that sick employees are often the reason behind the spread of foodborne illness). Create good relationships with your staff so they will self-disclose medical conditions.
|Plumbing, fixtures, back-flow devices, drainage — This violation covers all issues regarding water flow from sinks, drains, toilets, and refrigeration. Violations include missing back-flow devices on utility sinks, sinks not being attached to the wall, refrigeration lines draining onto the floor, and no floor drain being present.
||Proper eating, drinking, tobacco, and cell phone use — Employees can eat, drink, and smoke only in designated areas, and they cannot perform these actions as they prepare or serve food. Cell phones are hard to sanitize and not welcome in most kitchens, as they are generally sitting on top of cutting boards or counter surfaces (and contaminating those areas).
|Proper reheating procedures for hot holding — After food has been cooked and then cooled down and chilled, during the reheating process food must reach 165ºF for 15 seconds in order to kill any bacteria that have been growing. An inspector can test for this violation by asking an employee to what temperature they reheated the food and for how long.
In most cases, correcting issues on site will help raise your score, and the reason for not receiving a top score could be a few easily correctable issues.
How to Respond to a Low Score/Grade
When the inspection is complete, the inspector may choose a quiet area to write the inspection report and review it in depth with the person in charge, and then both parties sign the report. The report is left on site or emailed to the person in charge, and in most cases it will also be posted to the Health Department’s website and become part of the public record. During the exit summary, this is the best time to gather a better understanding of the inspector’s findings. If there is a violation that you do not agree with or understand, the best approach is to ask the inspector what the health implications are regarding that violation. Whatever the outcome, the first thing you should do with the inspection results is to take them seriously. You want to convey to the inspector your sincere concern to have those issues addressed and abated in an appropriate time frame. Retrain everyone in the areas identified in the report and make sure that you fix and repair for the long haul. This correction process starts with a prioritized list, and because repair and maintenance issues take time and cost money, it is best to start with the big things like cracked or missing floor tiles and grout, dirty fan guards, torn gaskets, and repairing broken equipment. Provide realistic time lines and sincere expectations. If you are still unsatisfied with the results of your health inspection, you can always contest or appeal to a higher authority for resolution. In some jurisdictions, a fine and/or re-inspection may be warranted and it might be worth the trouble of pursuing that route. If your establishment is involved with a Foodborne Illness (FBI) incident, then getting a lawyer might be a good idea.
In closing, health inspection scores do matter and it will affect facets of your bottom line. The results can be financially crippling to a small operation, with regards to fines, damaged reputation, pending closure, fleeing personnel and in this age of social media, bad news travels fast!. Stay on top of your food safety management program. Hire 3rd party consultants to give your establishment fresh ideas, observations from unbiased viewpoints and diagnostic checkups to see whether your system is working!
Note: The information of this article is inspired by years of working with clients who have experienced the joys and pain of health inspections. Information provided is in accordance to the recommendations of the FDA and the specifics of this article may not be accurate for every city and town.