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The Unwritten Food Code

Jim Mann's picture
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(Submitted by a former State Regulator after reading this blog series in preparation for the 2014 biennial Conference For Food Protection (CFP))

The ‘prescriptive' nature of the food code is now being understood by local health officials as: 'The health authority prescribes how a task is done and the operator is responsible to do the task as prescribed.' This interpretation, which differs from the traditional approach of Food Code which defined the minimum standard needed and operators were encouraged to innovate to complete the task at a standard that exceeded the minimum required by regulation.

The prescriptive approach discourages innovation, reduces communication that allows education, and makes regulators more feared by operators.

It gets even more onerous when the unwritten Food Code, which is the interpretation of the Code, is prescribed in a situation that has multiple solutions. Operators can no longer choose a method of compliance that works for them. I also think scheduled visits work well. Inspections take longer now. Ask any member of the Committee if he or she has 2-3 hours of time during his/her day between 9:30 AM and 2:00 PM for an unannounced person to come off the street and take their time regardless of the business demands on their time.

With dinner restaurants regulators are encouraged to come at the busiest times. Coming at the busiest times emphasizes proper use of gloves and countertop cleanliness but really does not allow for analysis of the time/temperature issues in advanced prep items/cooked and chilled items. In my experience, regulators often let operators know they are coming, and also make unannounced inspections. Quite frankly it results in unequal enforcement. You make an excellent point about water use.

I am in California, the health code encourages excessive use of water especially in its prescription that in use utensils be kept in container of running water with the stream sufficient to remove top debris even though a sanitizer solution wipe with a clean cloth is an alternative. Finally, documentation to prove you are following the prescription is excessive. In many instances health departments are requiring about 10 pages of documentation daily in terms of cooling logs, temperature logs, receiving logs, handwash logs, SOP logs, etc. For a restaurant open 365 days a year = 3,650 pages per year. Who reads it? Not the health authority which requires it to be done.

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