Nutrition & Foodservice Edge Magazine - September/October 2022 - 25

MAKE YOUR
FOODSERVICE
OPERATION
INSPECTION
dy
rea
BY KATHLEEN BRADY, CDM, CFPP, CP-FS, PCQI
IN THE MAY-JUNE 2022 NUTRITION
& FOODSERVICE EDGE, I read two
articles touting the benefits of using
reduced oxygen packaging (ROP) for
sous vide cooking. Although it's a
good way to prep food ahead of time
or preserve food for future use, it's
important to note that ROP, sous vide,
and cook-chill are considered Special
Processes. Therefore, according to the
FDA Food Code (FDA.gov) and most
likely your state's code, they require a
Hazard Analysis Critical Control Point
(HACCP) plan or a Variance, meaning
local regulatory or Health Department
approval. This is due to the risks
involved with pathogens growing
inside the packaging-risks like
Clostridium botulinum, a dangerous
bacteria that can thrive in reduced
oxygen conditions. " You cannot see,
smell, or taste the toxin that causes
botulism, but taking even a small
taste of food containing the toxin can
be deadly. " (CDC.gov) Since fish are
carriers of C. botulinum, fish can only
be packaged if frozen before, during,
and after packing.
The regulation is tricky to decipher.
If you read the Food Code starting on
page 101, Section 5-502.12 it states
that you do not need a HACCP plan if
you are only going to leave the food
in the package for 48 hours, or if you
have a HACCP plan, that you do not
need a Variance. Remember you're
going to need one or the other or
both! Check with your local regulatory
authority before incorporating any
new processes.
As a Health Inspector and a CDM, CFPP,
I'm always concerned about clarity
and didn't want anyone getting sick or
tagged for violations. After reaching
out, I was invited to write an article on
tips of my trade-inside information
on how to help you " get a good
inspection. "
In one way or another, I have been in
different facilities for the last 20 years
as a Foodservice Director, Training
Manager, Consulting CDM, and a
Regulator. I've received and given
marks that could have easily been
avoided. Below are some real-world
tips that I hope will help your facility
be inspection-ready.
INSPECTION TIPS
One way to not get a good inspection
is to store a freshly-caught 6 foot long
eel on top of the frozen items in your
chest freezer, and don't take a bath in
the three-compartment sink or thaw
your food and store dirty dishes in the
same sink. In addition, don't answer
your phone while on the line and then
proceed to debone a piece of chicken
for someone's dinner, and don't sit
on the floor while cleaning a pile of
shrimp. And for Pete's sake, do not
drain your steam kettle full of pasta
into a colander set on top of the floor
drain. Yes, I've seen it all!
NUTRITION & F OOD SER VICE EDGE | SEPTEMBER-OCTOBER 2022 25
http://www.FDA.gov http://www.CDC.gov
Nutrition & Foodservice Edge Magazine - September/October 2022

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