Updating Food Safety Plan

1. Updating Food Safety Plan Julie Shelton Consultant - School Nutrition Program Wisconsin Department of Public Instruction Summer 2011

2. Section 111 – Child Nutrition & WIC Reauthorization Act of 2004 • Added requirement that school food authorities implement a food safety program at each food preparation & service facility participating in NSLP or the SBP • Implementation date was school year beginning July 1, 2005 • Program must be based on HACCP system established by USDA Secretary of Agriculture

3. USDA Guidance/Help • Two memoranda issued by USDA • Guidance for School Food Authorities: Developing a School Food Safety Program Based on the Process Approach to HACCP Principles, June 2005

4. Food Safety Plan – Advantages • “Insurance policy” for protection of customers • Compliance with food code • Continuous improvement/food quality • Saves money & time • Consultative services of environmental health specialist • Documentation to address complaints, suspected food borne illness, & legal action • Bragging rights

5. Focus of Update Class Meet “review & revise periodically” involves: • Ongoing verification of plan to determine if it is operational • Periodic validating plan to determine if the plan controls the hazards

6. Plus … • Brief review of plan components • Final regulations specific to food safety plan (January 2010) • HHFK Act of 2010/Public Law 111-296 • Considerations/Issues/Concerns • Your issues/questions • Hot topics • Allergens • Breakfast in the classroom • Farm to School • Update on available resources

7. Food Safety Plan Development Nine Item Checklist base on USDA Guidance • Develop description of site/equipment inventory • Categorize menu items as process 1, 2, 3 • Identify critical control points, control measures and critical limits for items in each process • Adapt existing/develop SOPs for operation • Specify corrective action procedures • Specify recordkeeping procedures & monitoring documentation • Determine prerequisite training programs & document training to verify employee participation • Review and revise plan periodically

8. Final Rule – School Food Safety Program • Effective January 14, 2010 • Codifies the food safety plan requirements • Addresses recordkeeping requirement • Include food safety program as part of state agency administrative reviews • Extends food safety program requirement to school breakfast program

9. Food Safety Program Based on Traditional HACCP Option • Perform a hazard analysis • Decide on critical control points • Determine the critical limits • Establish procedures to monitor critical control points • Establish corrective actions • Establish verification procedures • Establish recordkeeping system

10. Food Safety Program Based on Process Approach Option Written plan for each prep/serving site must include methods for documenting: • Menu items appropriately categorized • Critical control points and critical limits • Standard operating procedures to provide a food safety foundation • Monitoring • Corrective action procedures • Recordkeeping procedures • Program Review & revision at least annually

11. Differences Between Options • Traditional HACCP focuses on recipes • For process approach: • Menu items are grouped into a given food preparation process that have similar hazards • Actions or activities used to prevent, eliminate or reduce hazards are similar

12. How did you categorize these items?

13. Categories Process 1 - no cook step Receive Store Prepare Hold Serve Process 2 - heat and serve same day Receive Store Prepare Cook Hold Serve  Serve Process 3 - complex food preparation Receive Store Prepare Cook  Cool  Reheat  Hot Hold Serve (advance preparation or leftovers) Receive Store Prepare Cook Serve  Cool  Reheat  Hot Hold Serve

14. Categorizing • Develop composite list • Determine if the menu item potentially hazardous (time/temperature control for food safety) and designate with “*” • Follow specific control measures that apply to all potentially hazardous menu items in the category

15. Likely Hazards and Controls • Process 1 • Example: dairy products • Example: bakery products • Process 2 • Example: chicken patty • Example: heated canned vegetables • Process 3 • Example: Chili prepared in advance • Example: Leftovers

16. CoolingChili from 135°F to 41°F Note Food Code Requirement: Cool from 135°F to 70°F in 2 hours and 70°F to 41°F in 4 hours

17. Cooling Chili from 135°F to 70°F

18. Cooling Chili from 70°F to 41°F

19. Cooling Process • Improper cooling is #1 cause of food borne illness • Limit the items in process 3 to minimize the risks and efforts involved to proper cool • Invest appropriate equipment & devices

20. Cooling Documentation • Cooling study log for items (see prototype) • Cooling rates vary from item to another so separate study is needed • Use study to test/adapt procedures presently followed • Develop specific SOP outlining procedures for each item • Not necessary to monitor temperatures each time when study documents food items are properly cooled

21. Monitoring Decisions • What will be monitored? • How will it be monitored? • Who will be responsible for monitoring? (designated position with back-up) • directly associated • trained and knowledgeable • accessible to monitoring activity • responsible • Has authority to take corrective action

22. Monitoring Documentation ????? • Receiving - Logs or Invoices? Other? • Damaged/Discarded Product – Log or use invoices? • Refrigerator/Freezer Temperatures – Logs for each units? Record on daily production plan? Are recording devise for walk-ins with alarm? • Cooking Temperatures – Log or recorded on daily production plan? • Holding – How often must temperatures be taken? Ways to eliminate or minimize? • Calibration – How often?

23. Considerations for Effective Monitoring • Provide training with sequential steps • Establish specific routines or times of day for monitoring activities • Provide appropriate forms • Provide appropriate & sufficient • Thermometers • Testing devises for dishmachine & chemical sanitizers

24. New USDA RuleMonitoring Logs

25. FinalRule§ 210.15 Record Retention • Records from the food safety program for a period of six months following a month’s temperature records with § 210.13 (c). • Records from the most recent food safety inspections to demonstrate compliance with § 210.13(b).

26. Final Rule § 210.18 Administrative Reviews State agency must examine records to confirm that each school food authority under its jurisdiction meets food safety requirements of §210.13.

27. Final Rule§ 220.7 SBPRequirement for Participation Implementation of a food safety program at each of the food preparation and service facilities under its jurisdiction serving reimbursable breakfasts

28. Prerequisites for HACCP • Working relationship with vendor • Vendor HACCP certification • Allergen management • Pest control • Standardized recipe with detailed instructions • Integrated controls (designated cutting boards, fully cooked products) • First-in-first-out inventory system & date marking

29. USDA Guidance Success of plan implementation is dependent on: • Facilities • Equipment • People

30. Facilities & Equipment • Selected/designed to promote safe food preparation and handling practices • Attention given to correction of barriers to safe food preparation • Faulty, outdated plumbing • Air gaps & cross connections • Delivery schedules for food deliveries & transported food based on mail delivery

31. Facilities & Equipment • Appropriate thermometers/properly calibrated • Heating and holding equipment with accurate gauges • Sufficient cold storage facilities

32. “People” • Knowledgeable • Understand his/her role • Committed • Overcome Obstacles • Time commitment • High employee turnover • Communication barriers

33. Employee Training • Basic food safety competencies • Specific competencies for Food Safety Plan: • Thermometer usage and calibration • Receiving procedures • Storage temperatures • Hot & cold holding temperatures • Cleaning/sanitizing • Cooking and documenting temperatures • Cooling procedures • Reheating procedures and temperatures • Maintaining necessary logs

34. USDA Practices for Success • On-going safety training • Review of food safety principles including SOP guidelines on annual basis • Documenting training • Holding site supervisors responsible for maintaining standards

35. Employee • Employee Health Reporting Program • Procedure/Process • Signed Agreement with plan & copy provided to employee • Orientation for new employees, subs, and volunteers • Documentation of SOPs

36. Job Aids • Posted Process 1, 2, 3 charts • Customized temperature charts • Laminated signs in kitchen • Standardized recipes with: • Food safety procedures • critical control points • Others

37. Job Aids also include: USDA Quantity Recipes Posted at: http://www.nfsmi.org/Information/school_recipe_index_alpha.html Use as: • Source for recipes to standardize • Guide for written recipe format: • Ingredients and detailed instructions • Contribution serving makes towards food based menu planning system • CCPs and food safety procedures

38. Other Success Elements Attention to: • Simplicity • Specific to each food service operation • Involvement of employees in plan development, implementation, plan review • Support from administration

39. Support from Administration • Recognition that food safety is important issue throughout entire school agency • Develop food safety & food safety policy for school agency addressing: • School food service program • Food brought from home or other sources • Food in the classroom • Vending • Concessions • Use of facilities by outside groups • Access to the school kitchen

40. Support from Administration, cont. • Involve key constituents on a team to develop food safety & security policy • Support food safety and food security training for school food service staff • Support food safety education for students

41. Recommendations for Food Service Directors/Managers • Work with administration to develop strong school district food safety & security policy • Require food safety certification for all management & supervisor personnel • Provide continuing food safety education • Evaluation the school food service program to determine that all prerequisite programs are in place to support food safety & security programs • Purchase tools required/make readily available • Develop self-inspection programs • Stay informed about current food safety rules and inspection processes

42. Organization/Accessibility

43. Organization/What to include • Required components • Table of contents/Index • Any food safety policy/kitchen use policy & forms • Prerequisite programs • Additional SOPs • USDA guidance pertaining to food safety • Signed employee health reporting agreements • Blank copy of each monitoring logs • Completed monitoring logs for six months/more • Employee training records • Food safety inspection reports • Annual review/revision documentation • Others?

44. Ongoing Verification & Periodic Validation • Ongoing Verification – Implementation of the food safety plan Is the plan being followed? • Periodic Validation – design of food safety plan Does the plan control the hazards?

45. When Conducted • Ongoing Verification • Conduct frequently (daily, weekly, monthly) by designated employee for multi prep/serving site operations and/or part of 2nd food safety inspection • Periodic Validation • Done less frequently, but at least annually, and is intended to confirm that the plan controls the hazards in operation and may be completed during 2nd inspection

46. Ongoing Verification Ensures… • Monitoring is being done, per plan • Monitoring records are completed accurately at predetermined frequency • Planned corrective actions are taken • Thermometers are calibrated

47. Ongoing Verification Activities • Observing employees • Checking monitoring records • Checking corrective action records • Reviewing calibration records • Checking accuracy of thermometers • Reviewing past inspection reports • Reviewing training protocols & agendas

48. Ongoing Verification Activities Includes: • Observing employees • Checking monitoring records • Checking corrective action records • Reviewing calibration records • Checking accuracy of thermometers • Reviewing past inspection reports • Reviewing training protocols & agendas

49. Ongoing Verification Activity Completion of Checklist for Review of Food Safety Plan (see prototype) • Adapt prototype to fit site • Adapt as the “look fors” for multi school sites and/or • Person in charge acts as “inspector” • Complete at least annually as part of routine monitoring of sites and on “as need basis”

50. Ongoing Verification • During observations: Determine if employees follow plan/Ask open ended questions to find out if employees understand what to do • For record review: May need to randomly choose a few days if responsible for multi-school sites • Focus on CCPs • Look for patterns