The development of the Elevated Risk Plan began in February 2015. The initial goal was to align with FDA's Standard 3 of the Voluntary National Retail Food Regulatory Program Standards by basing our food protection program on Hazard Analysis and Critical Control Point (HACCP) principles and the Centers for Disease Control and Prevention (CDC) risk factors. The initial objectives were to:
- Establish a process that groups food facilities into 3 categories based on potential and inherent food safety risk, and
- Assign an inspection frequency based on the risk categories to focus on food facilities that pose the greatest risk of causing a FBI.
The three categories/tiers that were established are shown below.
- Tier 1: This includes facilities that only serve prepackaged food. They receive 1 routine, scored inspection a year.
- Tier 2: This includes facilities with limited food handling or open food preparation. They receive 2 routine, scored inspections a year.
- Tier 3: This includes food facilities from Tier 1 and Tier 2 which met one or more of the following 5 criteria:
- A score letter of (C) or lower in one of the last two graded inspections,
- A score letter of (B) on two of the three last graded inspections,
- Repeated four-point violation risk factors on the last two graded inspections,
- Four or more critical violations noted during the last graded inspection, or
- A closure for cause.
Facilities that fall into this tier receive an additional scored inspection that is billed at the hourly rate. This inspection is called an elevated risk inspection.
EHS initially conducted a soft launch of the Elevated Risk Plan. Community meetings were conducted with the food industry to obtain feedback and to inform them of the upcoming changes, including, but not limited to: the frequency of inspections on food facilities, the permit fees and fee structure, and the way compliance and enforcement is handled. It was officially implemented on July 1st, 2016, and the first elevated inspection was conducted in September 21st, 2016.
The first 6 months of implementation was focused on training staff, continuing to educate food facility operators, and ensuring consistent application of this plan. Afterwards, the data that was collected during that timeframe was evaluated. We found that from January 2017 to June 2017, 216 elevated risk inspections were conducted – approximately 73% of these facilities showed improvement. Although this was a great accomplishment, EHS felt that more could be done. Therefore, it was decided to create and implement an intervention that would occur before the elevated risk inspection.
Our Division worked with the Performance and Quality Management Committee (PQMC) within the San Bernardino County's Public Health Department to develop an intervention to increase the percentage of improvement among identified high risk facilities. The PQMC consists of staff from a variety of Public Health programs including, but not limited to Nutrition, Compliance, Administration, Communicable Disease, and Emergency Preparedness. Working with the PQMC helped EHS come up with an intervention that occurs early in the Elevated Risk Plan in order to immediately address the facilities that met high risk criteria. It was decided to develop educational materials to give to all operators at food facilities that met any of the high risk criteria at the conclusion of their routine inspection. The materials that were developed and used for this intervention include a handout on the CDC risk factors and a short video called the Preliminary Education Presentation (PEP) Talk. The PEP Talk is a 5 minute video that contains information on the factors that are most commonly associated with FBIs, and how to correctly address them to prevent a FBI from occurring. This step/intervention was implemented August 2017. The goal for this new step/intervention was to have the number of elevated risk facilities that show improvement be increased from the baseline of 73% to 76% by the end of November 2017. From September 1st, 2017 to November 30th, 2017, EHS was already at 79% improvement.
In addition to PEP Talks, EHS has implemented additional sequential steps in the Elevated Risk Plan to continue to assist the high risk facilities that did not show improvement during the elevated risk inspection. If a food facility did not improve after an elevated risk inspection, the next step is to offer them an on-site consultation – a HELP consultation. This one on one consultation with food facility operators provides EHS the opportunity to teach effective strategies on how to raise food safety standards, strengthen managerial control measures, and ultimately achieve long-term compliance and improve inspection scores. It helps operators understand the underlying causes of the violations and commit to a specific correction plan. A risk review meeting is conducted on-site 1 week after this consultation to verify systems are in place to reduce the FBI contributing risk factors.
Last, but not least, one additional step was recently implemented into the Elevated Risk Plan in November 2018. It is a monthly comprehensive classroom training that focuses on regaining control of the food facility known as LEARN. It is geared towards food facilities that have been elevated after receiving an on-site consultation. However, it is open to any food operator that would like to attend. It is an interactive approach to learning Active Managerial Control (AMC) practices, and provides the operators the tools necessary to take control of their facility, their employees, and practice safe food handling. During this class, they are instructed on how to develop their own policies that will address their specific issues, and how to monitor and verify that their policies are working. We will also explain the importance of food safety and its relevance to FBIs. We hope that this final step of the Elevated Risk Plan will empower them to take ownership of their facility.
The onetime expenses incurred were from the development and implementation of PEP Talks, and the reports used to track and monitor the progression of the food facilities. This cost was approximately $5,240 in staff time. By using existing technology, such as EnvisionConnect, Microsoft Video Editor, and an iPhone, there was no additional technological operating costs. Also, no additional personnel cost were included to maintain the Elevated Risk Plan, since all the positions involved were incorporated into the annual budget. Inspectors are an integral part of the Elevated Risk Plan. All 27 district inspectors conduct the routine and elevated risk inspections, and provide the PEP Talks as needed. Currently, there is 1 inspector designated to provide the specialized phases of the Elevated Risk Plan: the HELP consultations, the risk review meetings, and the LEARN class. In addition, 1 Public Service Employee dedicates 15 hours per week to schedule the HELP consultations, and 1 EHS Supervisor spends approximately 10% of his/her time evaluating and monitoring the reports. Lastly, the Elevated Risk Plan is partially funded from the elevated risks inspections. EHS invoiced $30,210.56 at the end of June 2017, and by the end of June 2018, we invoiced approximately $35,000.