Food Protection Connection: What Happens When Something Goes Wrong?

(reprinted from Nutrition & Foodservice Edge, July 2012)

Inevitably something will go wrong at your food facility at sometime or another.

Whether it’s improper cooling, an equipment failure, or something
more significant like a fire or foodborne illness, you should have a plan to deal with various situations if they occur.

There is nothing worse than having a crisis and having to stop and research how to deal with it. Of course, you will never be able to anticipate every possible scenario that could occur, but having a
plan in place for general problems is a step in the right direction.

What should you do if a problem occurs? That depends, of course, on the nature of the problem. First and foremost, don’t panic. Various
problems deserve very different responses. Always rely on your food safety regulatory agency for guidance, answers, or assistance. Never hesitate to seek out this support.

Every food facility should have a food safety program in place. This should be a documented set of steps that aim to prevent problems with food safety before they occur, rather than having to rely on a reactive approach once a problem has already occurred. You may stop now and then to think about these things, but have you really taken the time to put pen to paper and write them down? In an emergency situation have a document to refer to so you don’t have to rely on your memory during this stressful time.

A food safety program should include all aspects of food service throughout your business—from receiving to service. It should have a procedure for each step in the process to keep food safe. What should we do if this step goes wrong? Items like pest control, staff hygiene and health, waste management, cleaning and sanitizing, recall procedures, emergency events, and similar should all be reviewed. Log sheets and records should be part of your food safety program. They are an integral part of your program and could serve as evidence that you have taken realistic measures to keep food safe.

At each step in your program, determine what kind of food safety hazard could occur. Procedures should be written to control the food safety hazards, monitor food safety, and document your actions. What should you or your staff do if a problem occurs? If there’s a problem, corrective actions taken should be documented. What happened, how was it corrected or resolved, what employee dealt with the situation, is there or was there a follow up to assure that problem does not occur again?

Your food safety program should also focus on the larger more encompassing systems in your whole business such as cleaning/sanitizing, pest control, staff training, maintenance, and similar.

I suggest a food safety plan with two sections. The first section should deal with emergency situations or natural disasters. The second section should deal with day-to-day food safety hazards that could occur.

This is by no means a complete list of items that should be in a food safety program. It’s simply a way to get you thinking proactively about your facility and how you would handle various food safety problems should they arise. Your food safety program should include at a minimum:

Emergency Situations

Your plan should address response protocols and actions to large hazards and emergency situations such as fire, flood, other natural disasters, electrical outage, or even a foodborne illness incident. Categorize food safety hazards and problems that are reasonably likely to occur. For instance, are you subject to flooding due to your facility’s proximity to a body of water?

Then have a detailed flood response document. Have similar response protocols for situations that may be even unlikely to
occur. It’s always better to be proactive.

• List important names and contact information for management personnel (or owners) trained in dealing with food safety or emergency response situations.
• List contact information for emergency response personnel and your health department.
• List general responses to various situations. Some situations will not warrant any immediate response by management or staff until the facility has been deemed safe to enter.
  • Incorporate emergency response protocols as suggested by your local health department and various federal agencies such as the CDC, FDA, or USDA. A plethora of emergency response materials is available on the Web for dealing with and recovering from floods, fire, boil water advisories, tornadoes, hurricanes, and similar natural disasters. Have them available in printed form within your food safety plan.
• Take into account various regulatory requirements that may be prescribed in your health department’s rules. You will most likely be required to contact your local food inspection agency to report any emergency situation that could affect food safety or public health. Know what you need to report and understand your food inspectors are there to protect the public’s health, but to also help your operation get up and running safely. Too many times I find operators avoid calling their food inspection authority. Not calling them will only result in a longer delay in resuming business or could even result in fines for failure to contact them. Please don’t avoid calling.
• A portion of your food safety plan, the Emergency Situations section, should document how to handle an identified foodborne outbreak or a consumer complaint of illness.
• Don’t avoid dealing with a potential foodborne outbreak. Should this ever happen, you will need a pre-thought out plan in place to maintain control of the situation.
• Identify a spokesperson for your business who will, if necessary, deal with the public. This will assure a consistent message will be heard by all.
• Identify who will manage communications with the food inspection agencies and health departments.
• Have your plan outline which illnesses, symptoms, or potential illness must be reported to your food inspection agency should you become aware of them. Have a written copy of this in your plan.
• Address what to do if the complaint of illness comes froma consumer and not the health authority. At what point will you seek the assistance of health officials?

Food Safety Concerns

This portion of your plan, although it very much mimics a HACCP plan, should specifically address problems that are
reasonably likely to occur. This is the ‘what to do when’ portion of your plan. Anything from a minor power outage, equipment breakage, food temperature problem, food recall concern, and similar could be addressed.

• Identify likely hazards that could occur in your facility.
• Detail who should be notified of the problem and provide contact information.
• Identify where within the operation each noted hazard can be controlled (and has the means to be controlled).
• Specify monitoring of the controls. What monitoring should occur and at what intervals?
• Identify corrective actions. What should happen if a concern or problem is identified? What specific action should be taken by employees?
• Spell out record-keeping tools for corrective actions taken after a problem has occurred. What did you or an employee
  do to correct the situation?
• Require regular review of the overall program by management.
• Take into account various regulatory requirements that may be prescribed in your health department rules.

A good, thorough food safety program will have great benefits such as reducing the risk of foodborne illness, having documented procedures and records to prove you have done due diligence to keep food safe, improving staff and business compliance with the food safety laws of your state, and will give you peace of mind while protecting your business reputation.

Your food safety plan should be combined with having good communication with your food regulatory agency and inspector.
Keep the lines of communication open and never hesitate to call with questions or concerns. Government or not, they are
there to help. A food safety inspector would much rather guide you on how to handle a problem situation, than be standing in your facility dealing with a much larger problem because you handled a situation inadequately. When an inspector is standing in a facility that had a crisis or emergency situation that got out of control, the operator never called for assistance and now they are knee deep in problems, the inspector will ask… “why didn’t you call us?” They often get the response that drives inspectorscrazy… “We were afraid we would be shut down, so we dealt with it ourselves.” Believe it or not, no food inspector likes to shut places down (it creates more work for them). They are obligated to protect the public health, but they are not ogres. If a situation can be handled in a way that does not disrupt business, that will always be the course of action. That said, there may be situations in which a closure or partial closure is necessary to protect the public health. When the inspector and facility work together to resolve a situation, the facility will be back and running in no time and you will have happy and healthy consumers. Look at your regulator as a partner in food safety.

The moral of the story is be proactive and have a thorough written food safety plan. And by all means, call your food inspector if you have any questions about how to handle an emergency situation or have even a simple food safety concern.

by Melissa Vaccaro, MS, CHO is a Food Program Specialist for the PA Department of Agriculture and an Executive Board
Member for the Central Atlantic States Association of Food and Drug Officials (CASA). Contact her at mvaccaro86@ gmail.com