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Improving Food Safety Through the Health Education Liaison Program (HELP)

State: CA Type: Model Practice Year: 2015

BRIEF DESCRIPTION OF LHD San Bernardino County is the largest county in the contiguous United States. The county covers over 20,000 square miles of land. San Bernardino County is located in southeastern California, with Inyo and Tulare Counties to the north, Kern and Los Angeles Counties to the west, and Orange and Riverside Counties to the south. San Bernardino County is bordered on the east by the states of Nevada and Arizona. San Bernardino County has the fifth largest population in California. In July 2013, San Bernardino County’s population was estimated at over two million (2,088,371). San Bernardino County is the twelfth most populous county in the nation, with more residents than 15 of the country’s states, including Idaho, West Virginia, and New Mexico. PUBLIC HEALTH ISSUE: According to the CDC, 1 in 6 people will get sick, 128,000 will be hospitalized, and 3,000 will die of foodborne illnesses each year in the United States. Furthermore, they have identified that the top five risk factors (critical risk factors) contributing to foodborne illnesses are: Poor personal hygiene Improper holding temperatures Inadequate cooking temperatures Food from unsafe sources Contaminated equipment/cross-contamination Critical violations found during inspections are significant risk factors contributing to foodborne illness outbreaks in food facilities, and pose an imminent hazard to public health and safety. Even worse are facilities that perform poorly inspection after inspection. Although many facility operators correct violations while the inspector is still on site, they are not always proactive in preventing future violations from recurring. This pattern shows that operators make immediate corrections, but do not implement long-term practices to minimize foodborne illness risk factors; thus the violations recur. This pattern of repeated low grades during routine inspections highlighted the need for an innovative approach to help facilities reduce repeat critical violations. A primary way this is achieved is through educational outreach associated with food safety practices. The County of San Bernardino Department of Public Health, Division of Environmental Health Services (DEHS) has implemented the proactive Food Safety Health Education Liaison Program (HELP). HELP consultations promote effective strategies to improve inspection grades, reduce repeat critical violations, raise food safety standards, and strengthen operators’ managerial control measures to meet long-term compliance objectives. This same service is offered to facilities that would like to improve their grade, as well as new operators wanting to understand health and safety regulations. The consultation is performed at no cost to the food facilities, and provides education and strategies for food facility operators and staff to reduce the occurrence of practices that lead to foodborne illness outbreaks. GOAL AND OBJECTIVES OF PROPOSED PRACTICE The goal and objectives of our proposed practice is to reduce the occurrence of critical violations and focus the operator’s efforts on implementing a food safety management system (Active Managerial Control). The operator can incorporate the HELP consultant’s recommendations into their daily routine to enhance safe food handling principles, improve inspection grades and reduce the risk of foodborne illness occurrences in their facilities. IMPLEMENTATION AND ACTIVITIES A HELP consultation offers food facility operator’s additional one-on-one time with an experienced Registered Environmental Health Specialist (REHS). The HELP consultant proactively contacts poor-performing food facilities, informs them about the program, and schedules their consultation. The HELP consultant assists operators in establishing a food safety management system that focuses on basic food handling regulations, acceptable workplace practices and contingency plans for potential crises such as product recalls, power outages or foodborne illness outbreaks. This provides a comprehensive framework by which an operator can effectively reduce the occurrence of foodborne illness risk factors. RESULTS/ OUTCOMES HELP consultations have had a positive and important impact on grades for the restaurants that have participated. Facilities that participated in HELP have increased their grades, decreased the potential risk of foodborne illness, and reduced critical violations within their establishments. Sixty-seven percent of poor-performing facilities scored an A grade on their next routine inspection after a HELP consultation (data is from Calendar Years 2012 and 2013; data from Calendar Year 2014 is not yet included). Critical violations associated with the top CDC risk factors decreased by 40.8% when comparing violations from routine inspections of poor-performing facilities before and after their HELP consultation. PUBLIC HEALTH IMPACT OF PRACTICE Foodborne illnesses can be costly and deadly, but are preventable. Food safety is one of the CDCs “Winnable Battles” because foodborne illness and outbreaks can be prevented through proper food handling, preparation, and storage. A foodborne illness usually arises from the consumption of contaminated food or beverages that have been improperly handled, prepared or stored. LHD WEBSITE www.sbcounty.gov/dph/dehs  
STATEMENT OF THE PROBLEM/PUBLIC HEALTH ISSUE Due to the high volume of food served, food facilities face hygiene and sanitation challenges every day. One lapse in food handling can potentially cause many consumers to become ill. The best line of defense against foodborne illness is prevention. According to the CDC, the risk factors that are highly associated with foodborne illness include poor personal hygiene, improper holding temperatures, inadequate cooking temperatures, food from unsafe sources, and contaminated equipment/cross contamination. In 2013, approximately 9,000 critical violations were cited during routine inspections at food facilities within San Bernardino County, and about 69% of those critical violations were associated with the CDC risk factors. Inspection reports revealed that food facility operators often correct a violation, but do not address the cause of the violation to prevent it from recurring. It became evident that DEHS needed to help operators better understand food safety and how it can be applied to their business in order to prevent foodborne illnesses and achieve long-term compliance. One of the contributing factors to foodborne illnesses is the lack of compliance with food safety regulations. Facilities that consistently receive low-performing grades, commit recurring violations, and have difficulty understanding food safety regulations are at greater risk of making their customers sick. DEHS inspectors conduct routine inspections at food facilities to evaluate food safety practices, ensure all critical violations are corrected during the inspection, and educate the operators about the importance of proper food safety practices. Additionally, inspections are conducted to investigate reported foodborne illnesses and other complaints. These inspections and investigations conducted by DEHS are the standard tools used in the prevention of foodborne illness. However, DEHS discovered that although many operators of retail food service establishments respond to inspection findings by correcting violations right away, they often fall right back into their old habits. They do not implement sustainable systems that change behavior to prevent violations from recurring. This observation revealed the need to find innovative ways to help facilities eliminate reoccurring violations, and change employee behaviors that contribute to foodborne illnesses. For retail food inspections, DEHS uses a grading system that is based on varying degrees of risk to indicate levels of compliance. Each food facility routine inspection begins with 100 points, and as violations are observed, points are deducted. The grades are based on the following scores: 100 – 90 (A), 89 – 80 (B), 79 – 70 (C), 69 – 0 (Closure). A lower score indicates a greater risk of foodborne illness and a lower level of compliance. A critical violation associated with a CDC risk factor is represented by a two or four point deduction from the facility's score, depending on the severity of the infraction. Critical violations associated with a CDC risk factor include improper cooling of food, incorrect reheating procedures, failure to wash hands correctly or when needed, improper holding temperatures, improper cooking temperatures, adulteration of food, lack of adequately supplied and accessible handwashing facilities, improper sanitization of food contact surfaces, etc. A poor-performing facility is defined as a facility that fails to score an A grade during a routine inspection (the facility scores a B, C, or is closed due to scoring a 69 or below). Many facilities show a habitual pattern of a "roller coaster" effect. They score poorly on a routine inspection but then re-score higher a few days later. Re-score inspections are billable, non-routine, scored inspections that are requested by operators. Since the operator is expecting this re-score inspection, they are typically operating at a compliant level and score higher on this inspection. However, as time elapses, the facilities lapse back into their incorrect practices, and when the time for the next routine, surprise inspection comes around, they score poorly again. Thus the "roller coaster effect" is a facility scoring poorly (B, C, or closure) during an unannounced routine inspection, re-scoring higher a few days later (usually to an A), and then several months later, on the next unannounced routine inspection, lapsing back to a B, C, or closure. TARGET POPULATION San Bernardino County is racially and ethnically diverse. Half (50%) of San Bernardino County residents are Latino. Among the remaining non-Latino residents, 32% are White, 8% are Black or African American, 7% are Asian or Pacific Islander, and 3% report two or more races. Less than one percent of residents are American Indian/Alaska Native (0.6%). Consultations are conducted in all areas of San Bernardino County. DEHS has targeted a large number of food facilities struggling during these tough economic times. It has been difficult for many food businesses to make a profit, especially if they manage or own a small family business or non-chain retail food facility. With the development of HELP, DEHS took into consideration and recognized that retail food facilities may not have the additional monetary resources to pay for a professional consultant to help them address critical violations. A professional consultant can cost thousands of dollars in addition to the cost of payroll, a health permit, a business license, utility bills and other ongoing operating expenses these facilities already pay. With the health and safety of the residents and visitors of San Bernardino County in mind, DEHS decided to provide the HELP consultations at no additional cost to the facility. This free service offers facilities extra support and assistance to improve their food handling practices, gain knowledge of proper food safety procedures and to learn how to establish an active managerial control system for future long-term compliance. In addition, facilities that receive a grade of B or C spend extra money attempting to improve their grade. A low grade can also result in a loss of customers and revenue. Many facilities that receive a score of 89 percent or less typically request a re-score inspection in an attempt to improve their grade; billable inspections currently cost $245 per hour. Between the dates of July 1, 2012 - June 30, 2013, 431 re-score inspections were conducted with an average time of 63 minutes per inspection. Re-score inspections are requested by the operator and are usually conducted within 3 business days of the request. Operators that request re-score inspections typically prepare and successfully achieve a score higher than when an inspection is unannounced. HELP works hand in hand with these facilities to improve inspection grades and avoid the extra expense of a re-score. With proper oversight and monitoring, facility operators can learn to take these concepts and apply them to long-term food safety procedures that can help them achieve a score of 90 percent or higher on future unannounced inspections, provide a safer product to the public, and reduce their financial burden. PAST CORRECTION For retail food inspections, DEHS uses a grading system that is based on varying degrees of risk to indicate levels of compliance. Each food facility routine inspection begins with 100 points, and as violations are observed, points are deducted. The grades are based on the following scores: 100 – 90 (A), 89 – 80 (B), 79 – 70 (C), 69 – 0 (Closure). A lower score indicates a greater risk of foodborne illness and a lower level of compliance. A critical violation associated with a CDC risk factor is represented by a two or four point deduction from the facility’s score, depending on the severity of the infraction. DEHS defines a poor-performing facility as one that fails to score an A grade during a routine inspection (the facility scores a B, C, or is closed due to scoring a 69 or below). Routine inspections are conducted twice annually. Facilities which score a C are required to request a billable re-score inspection within 30 days. Although facilities which score a B are not required to request a re-score inspection, many choose to do so due to the negative public perception of having a B score. The billable re-score inspection does not guarantee an A grade, but provides a second chance for the facility to possibly improve their grade. During the billable re-score inspection, the inspector performs another new, comprehensive inspection for the food establishment. Re-score inspections requests are received by fax, and the inspector conducts the re-score inspection within three to ten business days. The advantage of the re-score inspection for food operators is that knowing they have an inspection coming; most violations have been addressed and corrected. Re-score inspection results demonstrate a common trend. Most facilities score higher, often earning an A grade. Having received an A grade, the pressure is off to continue to perform at this higher level. The disadvantage to the re-score inspection is that efforts to control critical violations are not implemented in the long term, and the incentive to reduce risk factors is removed. Some facilities have shown a habitual pattern of a "roller coaster" effect. They score poorly on a routine inspection but then re-score higher a few days later. Since the operator knows the re-score inspection will occur within ten business days, they are typically operating at a compliant level and score higher on this inspection. But as time goes on, the facility lapses back into their incorrect practices, and when the time for the next routine, surprise inspection comes around, they score poorly again. Thus the "roller coaster effect" is a facility scoring poorly (B, C, or closure) during an unannounced routine inspection, re-scoring higher a few days later (usually to an A), and then several months later, on the next unannounced routine inspection, lapsing back to a B, C, or closure. WHY THE CURRENT PRACTICE IS BETTER DEHS employed a new and innovative method to accomplish the following objectives for Food Safety HELP: Assist poor-performing facilities in reducing foodborne illness risk factors and achieve higher scores. Promote safe and sustainable employee behaviors. Promote long-term compliance by implementing active managerial control. Develop and enhance a community and business support system through education. The current practice, HELP, is better because the "roller coaster" effect (described above) is being broken for many poor-performing facilities. Sixty-nine percent of poor-performing facilities which received a HELP consultation went on to achieve an A grade on their next routine, unannounced inspection. This improvement demonstrates the effectiveness of HELP consultations. Employee behaviors and food handling practices are critical components to the success of an operator’s retail food business. Once at the facility, the operator accompanies the HELP consultant through a mock inspection evaluation, observing these behaviors and practices. The consultant then offers additional assistance in providing solutions and instruction that will help  to obtain future long-term compliance. The consultation does not affect the facility’s current grade, but critical areas of concern and violations that are observed are immediately addressed and corrected. This program helps operators identify incorrect employee practices and/or operational procedures that can lead to a foodborne illness outbreak. CURRENT PRACTICE IS INNOVATIVE DEHS developed the Food Safety Health Education Liaison Program (HELP) to strategically bridge the gap between industry and government. This program has provided an opportunity for DEHS to take a proactive approach to provide operators with information and strategies to help improve their food handling practices. Operators are able to ask questions and receive instruction tailored to their food operation and the dynamics of their facility. Being proactive rather than reactive allows operators to incorporate sustained food safety practices as part of their business. PRACTICE ADDRESSES CDC WINNABLE BATTLES Foodborne illnesses can be costly and deadly, but are preventable. Food safety is one of the Centers for Disease Control and Prevention’s (CDC’s) “Winnable Battles” because foodborne illness and outbreaks can be prevented through proper food handling, preparation, and storage. A foodborne illness usually arises from the consumption of contaminated food or beverages that have been improperly handled, prepared or stored. According to the CDC, the top five pathogens that contributed to 91% of domestically acquired foodborne illnesses in 2011 are Norovirus, Salmonella (nontyphoidal), Clostridium perfringens, Campylobacter ssp., and Staphylococcus aureus. These pathogens can cause foodborne illnesses that may lead to hospitalization or death. Explaining this concept to operators allows them to comprehend the importance of reducing the occurrence of critical violations and to focus their efforts on implementing a food safety management system (explained below). The operator can incorporate the HELP consultant’s recommendations into their daily routine to enhance safe food handling principles and reduce the risk of foodborne illness occurrences in their facilities.
Food Safety
GOALS AND OBJECTIVES OF PRACTICE The County of San Bernardino Department of Public Health Division of Environmental Health Services (DEHS) is dedicated to improving the quality of life for all residents and visitors by protecting public health, promoting safety and preventing environmental hazards. As the agency designated by the State and the County to enforce laws and regulations, DEHS aims to “help” rather than “make” businesses comply with requirements. DEHS seeks to enhance working relationships and provide various tools to assist operators in achieving compliance with regulations. HELP has bridged the gap between food facility operators and DEHS; has enhanced customer service by providing a free consultation to food facilities; has helped participating facilities increase their grades; and, ultimately, has reduced the number of critical violations associated with CDC risk factors which can contribute to foodborne illness. By offering this free service, food facilities can take advantage without incurring any additional cost, other than their time and effort in implementing active managerial control practices that are essential to their success. Since the implementation of HELP, there are fewer facilities scoring below 90 on their unannounced routine inspections. This has not only improved public health, but also increased consumer confidence as customers at these facilities. Long-term food safety management practices have been shown to aid in the reduction of critical violations and the risk of a foodborne illness, which is the ultimate goal of HELP. STEPS TAKEN TO IMPLEMENT THE PROGRAM Prevention plays a vital role in minimizing foodborne illness, and DEHS recognized the need to provide a more flexible and non-intimidating educational approach in assisting food facility operators in achieving long-term compliance. In 2012, DEHS implemented Food Safety HELP. Managed by an experienced Registered Environmental Health Specialist (REHS), HELP provides non-scored, comprehensive, mock inspections. This format allows operators to ask questions one-on-one, provides instruction tailored to the needs of their operation, and focuses on methods to attain active managerial control in order to prevent and reduce the occurrence of foodborne illness risk factors. According to the U.S. Food and Drug Administration (FDA), to effectively reduce the occurrence of foodborne illness risk factors, food facility operators must focus their efforts to implement active managerial control. The term “active managerial control” is used to describe industry’s responsibility for developing and implementing food safety management systems to prevent, eliminate, or reduce the occurrence of foodborne illness risk factors. It embodies a preventive rather than reactive approach to food safety through a continuous system of monitoring and verification. There are many tools that can be used by operators when implementing active managerial control. The HELP consultant assists operators in establishing a food safety management system that focuses on basic food handling practices. During the consultation, the HELP consultant makes recommendations that are tailored to meet the needs of each food establishment by providing methods by which risk factors might be mitigated. This allows operators to take ownership in the implementation and development of their own unique safety management systems. By executing an active managerial control system, operators regain control over their operations and are prepared to take appropriate corrective actions for any identified problems, thus eliminating recurring violations. HELP allows operators to realize that a problem exists and to commit to a specific correction plan, rather than merely acknowledging each individual violation. The HELP consultant also emphasizes the importance of ongoing oversight by the operator to achieve long-lasting results and compliance. Education is the avenue in which DEHS has developed and enhanced a community and business support system for retail food facilities within the County. During their HELP consultations, various resources and educational materials are shared with food facility operators to help them and their employees increase their knowledge of current regulations and food safety principles and practices. The HELP consultant supplies operators with handwashing, cooling, reheating and proper cooking temperature handouts, which aids in the implementation of an active managerial control system. This material is also made available in Spanish for those operators and employees from other cultures and backgrounds. The ability to provide facilities not only with written materials but provide HELP consultations in Spanish as well, has allowed DEHS to effectively reach and educate a greater number of operators and employees. After the consultation, a final report is sent to the operator addressing the areas of concern that were observed and listing the consultant’s recommendations to maintain future compliance. Operators then have the tools to take a preventive approach to the management of their operation and ensure that all employees are practicing proper food handling procedures. This can help decrease recurring violations and reduce potential costs associated with foodborne illnesses. One of the objectives of this program is to educate operators and to develop long-term sustainable procedures for employees to follow. It is human nature that many food facility operators are fearful and suspicious of government. However, this program helps bridge the gap between DEHS staff and food operators in order to instill trust and promote teamwork toward a common goal of serving safe food. TIMEFRAME Development of the HELP program began in June 2010 to establish a new and innovative method to promote effective strategies to improve inspection grades, raise food safety standards, and strengthen operator’s managerial control measures to meet long-term compliance objectives. The program was implemented in April 2012 through the use of an experienced Registered Environmental Health Specialist (REHS). STAKEHOLDERS HELP is promoted to food facilities at no additional cost through district inspector referrals and referrals from the administrative hearing officer. The HELP consultant proactively contacts the referred food facilities and any identified low-scoring facilities to offer HELP’s beneficial services and schedule a date and time to conduct the consultation that is convenient for the food facility operator. Every food facility is encouraged to participate and is entitled to one free HELP consultation each year. The program is marketed to all operators through the DEHS website, Industry Roundtable announcements, the DEHS Foodwise newsletter and social media (Facebook, Twitter, and Pinterest), as well as by staff. District inspectors play a major role in encouraging operators to take advantage of this opportunity, and this encouragement has resulted in many operators calling and scheduling a consultation for their facility. START UP COST As with almost any new program, there is a cost. Funding from the San Bernardino County Food Worker Card certification program was allocated to develop and implement this program. Each facility is entitled to one HELP consultation each year at no charge. Expenses for salaries, mileage and equipment have been included in the DEHS budget over the past three years; however the initial start-up cost for brochures and request forms totaled approximately $1,700.00. By using existing database software, EnvisionConnect, DEHS is able to keep technological operating costs to a minimum. Since DEHS staff utilizes the software on a daily basis, no additional training was needed. However, one week of an employee’s time was allocated for the creation of new reports to track trends and program effectiveness. District inspectors play a major role in marketing this program. As inspectors perform their routine inspections, they encourage operators to take advantage of a free consultation. This provides a cost free marketing system for HELP. More than 75 percent of facilities participating in HELP have been referred by district inspectors. The budgeted annual expense for employing one full-time REHS is approximately $89,000 (salary and benefits). Approximately 10% of a supervisor’s time is spent providing direct supervision to the REHS at an annual cost of approximately $10,500 (salary and benefits).
OUTCOME / ACHIEVEMENT OF OBJECTIVES Our overall goals and objectives are to decrease the potential risk of foodborne illnesses, reduce critical violations within food facilities, and provide food facilities with the resources to be able to score an A grade on their routine, unannounced inspections. Our goal is to help businesses in our county be successful, while also protecting public health. Since there is a negative public perception of restaurants that have B and C grades, it is the goal of both DEHS and the food facility operators for them to achieve an A grade on routine inspections, avoiding the “roller-coaster effect” of scoring poorly on routine inspections and then re-scoring again a few days later. A poor-performing facility is defined as a facility that fails to score an A grade during a routine inspection (the facility scores a B, C, or is closed due to scoring a 69 or below). Sixty-seven percent of poor-performing facilities which received a HELP consultation went on to achieve an A grade on their next routine, unannounced inspection. [Data is from Calendar Years 2012 and 2013; data from Calendar Year 2014 is not yet included]. This improvement demonstrates the effectiveness of HELP consultations. For the majority of poor-performing facilities which receive a HELP consultation, the "roller-coaster effect" is broken. Data analysis for facilities that participated in HELP has showed an inverse correlation between scores and critical violations; with average scores increasing and critical violations decreasing after their HELP consultation. Critical violations associated with CDC risk factors decreased by 40.8% on average when comparing the number of critical violations (observed during the routine inspection before HELP), to the number of critical violations observed during the next routine inspection after their HELP consultation, for poor-performing facilities. This in turn reduces the potential risk which can contribute to a foodborne illness outbreak. An example of the effectiveness of this program is represented by a facility that went from a score of 70 (C grade) on a routine inspection before HELP and increased to a score of 91 (A grade) on their next unannounced routine inspection six months later. Facilities that improve their scores and maintain long-term food safety management practices due to their participation in HELP can take pride in their contributions to reducing foodborne illness risk factors. EVALUATION OF PRACTICE Primary data sources were the facilities’ grades and scores during routine inspections before and after HELP consultations. District inspectors conduct an inspection, and generate the official inspection report (including letter grade and numerical score) at the end of the inspection. All report data is uploaded to the EnvisionConnect database when the district inspectors return to the office. Therefore, the district inspectors collect the data (from routine inspections) out in the field as they are conducting their normal work activities. When the HELP consultant conducts a consultation, that date is recorded in both EnvisionConnect and Microsoft Excel, so that pre- and post- intervention data analysis can be performed. Our performance measures included facilities’ numerical score, letter grade, and number of critical violations cited during routine inspections. A poor-performing facility is defined as a facility that fails to score an A grade during a routine inspection (the facility scores a B, C, or is closed due to scoring a 69 or below). As discussed previously, there is a negative public perception of food facilities that have B or C grades. For business owners of food facilities, their goal is to achieve an A grade so that customers will continue to come to their facility. Therefore, one of our outcomes measures is whether or not a poor-performing facility achieved an A grade on their next unannounced routine inspection after a HELP consultation. Results were analyzed using EnvisionConnect and Microsoft Excel. Long-term food safety management practices have been shown to aid in the reduction of critical violations and the risk of a foodborne illness, which is the ultimate goal of HELP. As a result of the data findings, we are planning to implement some modifications to HELP. One proposed change is to have the HELP consultant conduct re-inspections every six months for facilities that have participated in HELP.
LESSONS LEARNED Continued efforts to enhance collaboration with industry, DEHS staff, and the public, in addressing environmental health concerns countywide, will help meet the public health needs of county residents. Working together will help guide food facility operators in meeting food safety standards, along with incorporating innovative ways to make their businesses successful. PARTNER COLLABORATION As the program moves forward, DEHS will continue to collaborate with food facility operators to sustain long-term compliance rather than take a reactive approach to food safety. Our focus as a program is not only to educate operators on how to correct violations, but also to provide an innovative approach so operators can actively monitor and control their operations on a daily basis to control the CDC risk factors that contribute to foodborne illnesses. BENEFIT ANALYSIS: N/A STAKEHOLDER COMMITMENT TO SUSTAIN THE PRACTICE The benefit of implementing long-term intervention strategies for each facility will be monitored as HELP progresses. Data tracking and monitoring for trends will continue in efforts to continue to alleviate the "roller coaster" scoring effect, while encouraging operators to implement long-term intervention strategies by taking action in active managerial control. DEHS will continue to educate operators in various intervention strategies to control foodborne illness risk factors and educate better food safety management system for operators.
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