To all foodservice and food retail establishments: Are you ready for your risk factor close-up? In 2008, the U.S. Food and Drug Administration (FDA) will reprise its 1999 and 2003 Voluntary National Retail Food Regulatory Program Standards benchmark surveys identifying the top risk factors that contribute to foodborne illness in U.S. retail food stores and foodservice operations. Will the top five risk factors identified in the previous surveys—poor personal hygiene and employee health, improper hot/cold holding temperatures, inadequate cooking, contaminated equipment, and food from unapproved sources—still have top billing when the 2008 survey is completed?

Since the last FDA survey was published in 2004, the nation’s restaurants, grocers and institutional foodservice operations have been busy developing their food safety programs to address these and other risk factors. In November 2006, FDA’s Center for Food Safety and Applied Nutrition (CFSAN) Office of Retail Food Protection recognized several premier food safety programs in the premiere of its two-and-a-half-hour satellite broadcast, “Reducing Risk Factors at Retail and Food Service.” Leading restaurants, food retailers and regulators from state and federal public health agencies showcased their success stories in the live broadcast, sharing ideas, tools and commentary to help reduce risk factors that contribute to foodborne illness in food stores and foodservice operations.

As noted during the broadcast by Robert E. Brackett, Director, FDA CFSAN, the tools and ideas discussed in the program aim at making foodservice and retail establishments more effective in improving food safety programs. “As many of you know, it is only a few areas that contribute to most of the foodborne illness outbreaks in retail and foodservice establishments. By focusing on these risk factors, we’ll ensure that we’re putting our efforts in the right places.”

Targeting the identified risk factors in your own operation and then communicating the how’s and why’s of risk factor reduction activities to staff is the ticket to success, according to the broadcast’s participants. Besides innovative approaches to reducing risk factors, featured success stories shared common themes, including strategies and planning, monitoring and measuring, training, behavior change, awards and incentives, and partnerships.

By reviewing the FDA satellite broadcast’s highlight reel, both foodservice and retail operators and public health and inspection professionals will learn real ways to ensure food safety at point of purchase and consumption—and assist operations in getting ready for next year’s benchmark survey close-up.

Start with a Great Script: Strategies and Planning
Big Y Foods, Inc., a family-owned and -oriented retail food company serving customers’ from nearly 30 locations in Massachusetts and Connecticut, has achieved success in reducing risk factors at its stores by focusing on the top factors of concern, says Cas Tryba, Big Y’s food safety manager. Big Y holds an annual meeting to pick the top two out-of-compliance risk factors for foodborne illness based on internal and external data sources, and designs its reduction approach accordingly. “We have an internal food safety department that audits,” says Tryba, “and we have an audit form with a point system based on risk factors. We always gauge our food safety program by scores, and each department is scored separately so we can track if the produce department is getting better, or the overall store score is getting better, and so on.”

When FDA published the first risk factor baseline survey, he continues, Big Y’s food safety team began to look at this data a little differently. “We started tracking the risk factors, out-of-compliance and in-compliance data, and coupled with the point system and looking at specific violations, we found very similar out-of-compliances as the FDA baseline survey. As a result, we targeted those areas where we thought we could make a difference.” While the company always looks at the most common risk factors, such as personal hygiene, employee health, time/temperature control and cross-contamination in food handling areas, Big Y develops strategies for use within every specific department because they often differ from section to section. Currently, cold chain management and employee health and personal hygiene are the focus of their food safety strategy. “We know that personal hygiene is primarily behavioral, so we’ve targeted training and additional fun activities for the associates to try to achieve a better compliance rate.”

Success story participants also advise that foodservice and retail establishments work closely with their county or state public health agencies and utilize the newer information systems and materials made available by these organizations to better plan the most effective risk reduction strategies for their particular operation. Many regulatory jurisdictions use the FDA baseline survey to measure the rate of foodborne risk factors observed to be out of compliance within retail food and foodservice establishments under their purview. And as a result, local agencies can collect much more specific data on risk factors, analyze trends and provide operators with more meaningful information to assist them in focusing efforts where they will do the most good.

The Maricopa County Environmental Health Division in Phoenix, AZ, offers an excellent example of how its retail and foodservice constituents have been able to significantly reduce risks with the assistance of the agency. In the last three years, public health officials have documented a 45% reduction in critical violations in facilities operating with the county. Maricopa County’s management and staff say these strides have been made since the division redirected and reinvented their program by focusing primarily on those risk factors that are attributable to foodborne illness and disease.

“The philosophy at Maricopa County is education before enforcement,” comments Jaime Viñarás, environmental health lead specialist for Maricopa County. “We want to work with industry to look at their challenges and the risk factors that contribute to foodborne illness and disease.” Two of the most successful efforts have been “training inspections” and cultural outreach initiatives that address the food safety educational needs of foodservice workers for whom English in not their native language. These two strategies are interrelated, indicates Viñarás, because they both foster better communication between the health department and operators, resulting in better compliance rates over the long-term.

Maricopa County’s training inspection approach is key to these risk factor reduction improvements, adds David Ludwig, M.P.H., R.S., Maricopa County division manager. “We do training inspections that are not weighted or tied to any potential type of enforcement action. And that’s to improve our relationship with the industry, by educating operators about what they are doing right and what they are doing wrong.” While county inspectors do look for critical violations, these onsite visits are less about enforcement and more about helping the operator identify risk factor challenges that may have emerged since the previous inspection so that they may be mitigated prior to the next official inspection.

The agency’s “cultural competency” initiative involves outreach to operators in the Hispanic and Chinese communities. “In 2000, the staff decided to look at data in regard to those facilities that were in legal actions,” says Viñarás. “We categorized these and found that while Hispanic or Chinese operations represented a small portion of those, anywhere from 10 to 15 percent of the total number of facilities, they accounted for about 30 to 40 percent of operations under probation or warning. We had a significant challenge in that area and we needed to address it.”

The county hired two bilingual public health sanitarians as liaisons to the area’s Hispanic and Chinese operators, created a wealth of visual aids and materials in the respective languages for operators, including booklets and virtual reality CD, which helps guide inspectors as to what the risk factors are for an ethnic food product or in its preparation process and suggests where to implement control measures.

Maricopa County retailer Ernesto Rascon, co-owner of El Rancho Market, says that the combination of training in between official inspections and having verbal and written education information in Spanish has helped his employees better understand and comply with food safety requirements. “The most valuable tool we get from the county is the training in between official inspections,” he says. “The training helps us gain knowledge about how to do things right, and if we don’t know how to do it, we can ask right then and [the inspectors] will tell us right away. The training in Spanish is very valuable to us because our employees don’t speak English.”

Another benefit, adds Rascon, is that increased interaction between Maricopa County officials and El Rancho employees, coupled with the removal of the language barrier, has resulted in a better repoire that translates into better performance in carrying out food safety tasks. “Employees are more comfortable when inspectors come by. Before the Spanish training program was offered, our employees were afraid of the public health department officials. Now, they feel they know [the inspectors].”

Coming Soon: Behavior Change and Training
With thousands of employees (or cast members, in Disney-speak) working in hundreds of foodservice outlets—from street vending carts and quick service restaurants to full-service dining halls serving group banquets and convention dinners—the real magic of Walt Disney World’s approach to food safety is its behavior-based food safety management system. As one of the broadcast’s featured success stories, Walt Disney World’s director of safety and health, Frank Yiannas, explained how the company’s behavior-based approach to food safety has a big impact on reducing risk. “When I think about the FDA risk factors, or the contributing factors of foodborne disease today in retail/foodservice establishments, whether they be time/temperature processes, personal hygiene or contamination, I often think of human behavior. The first step to assessing the FDA risk factors is coming to the realization that often these issues are, in some form, related to human behavior,” he says.

“In order to make improvements, we need to recognize more than just the food science,” continues Yiannis. “I believe that you won’t be successful in addressing the FDA risk factors until you realize that it’s the food science and the behavioral science—by combining these we can create a behavior-based food safety management system.” Monitoring performance, positive feedback, training and awards and incentives are all key factors in Walt Disney World’s system.

Employees need to know what you expect them to do, he says. Training has to be hands-on, showing staff exactly what it is that you want them to do and how to do it, and then overseeing what they are doing and showing them how to do it correctly. The operation’s ability to reduce food safety risk factors begins with making sure that food safety expectations are crystal clear.

But making the food safety mission personal to employeess is one powerful way that the company promotes positive behavior change to reduce risk factors and protect public health. This means making a commitment to educating personnel about the why’s of food safety rather than just addressing the what’s and how’s via on-the-job training. “When you bring employees into a classroom and you talk about food safety, such as microorganisms in foods or the time/temperature process, you are really educating them, you’re not training them,” Yiannis says. “You’re telling them why food safety is important. One of the things you might want to do is use personal testimonies, true examples of foodborne disease and how it affected an individual and their family. I think that might be very persuasive in food safety education.”

The only way you’ll know whether your strategy for behavior change is working is to measure, advises Yiannis. “We’re believers in that you can’t manage what you don’t measure. So create measurements. If you are trying to effect a certain behavior, I would ask you to go out and take a look at that behavior and actually measure it to see whether there is an increase or decrease in the behavior.” If activities are being done correctly, provide positive feedback; if not, provide coaching and feedback.

Cas Tryba also emphasizes the importance of developing training and education programs for Big Y Foods’ employees so that learning is a positive experience. Tryba has sent Glo-Germ kits to every store as a handwashing exercise, dispatched internal trainers to each location to conduct interactive demonstrations on risk-factor related strategies, and had department managers and employees form teams to brainstorm and develop fun, creative posters as visual reminders of food safety best practices. The supermarket chain is especially proud of its Learning Hub training system. Through its intranet networked to personal computers on-site and available to individual home computers, Big Y provides continuous, interactive training to its employees on a variety of topics.

Says Tryba, “On the food safety end of it, we identified six or seven topics primarily based on risk factors—personal hygiene, employee health, temperature control, which we broke down into different categories (hot holding, cooking, cold holding), etc. We did that because in every employee’s job description [we include] the frequency for taking those measurements. There is a quiz associated with each module, which is not especially difficult but you have to get 100%. Every associate has the opportunity to, either their free time or a designated time, to use the Hub.”

Top Billing: Monitoring and Measuring
Retailers and restaurant operators agreed that the greater the operation’s ability to measure and monitor any activities that aim to address risk factors, the greater the level of risk reduction achieved. After determining what risk factors are most prevalent in a particular location, determining the methods by which to measure and monitor is the next step toward reducing food safety risks.

During the airing of “Reducing Risk Factors at Retail and Food Service,” participants emphasized that whatever measurement tools the food establishment employs—from a simple digital thermometer and paper log, to mobile computers—they should provide the data specific to that establishment to be most effective in reducing risk factors. “I think the key to our program, and what I like to base my decisions on, is the data,” says Cas Tryba. “I like to see the science and the data before jumping into anything.”

When it comes to monitoring and measuring risk factors in retail and foodservice, computerized devices that are mobile and enable the user to automatically transfer critical food safety data to a centralized system are increasingly popular. In Big Y Foods’ case, handheld, or pocket, computers, have proven valuable in its efforts to combat inadequate time/temperature control, Tryba says. Custom designed for Big Y stores, the HACCP Digital Assistant allows associates to detect temperatures automatically in a user-friendly electronic format that minimizes operator error and increases efficient data collection and quality for improved trending, traceability and corrective action.

Icons that appear on the unit’s touchscreen represent separate locations, says Tryba, “so if you are doing any cooking item out of a rotisserie or any kind of oven, all the items listed under that icon are foods that we cook. You press the icon for rotisserie chicken and it automatically has a predefined minimum temperature and maximum temperature. The nice part about this system is that it automatically prompts you to a corrective action, such as recooking of that rotisserie chicken, and will automatically store that data.”

The system is wireless, so after taking the measurement, the user just presses the “Sync” button and the data is automatically transmitted to the corporate headquarters, where Tryba can see every cooked and hot holding temperature in real time throughout the chain.

“At Disney, we’re believers in using new technology to advance food safety,” Yiannis adds, particularly innovative information tools that enhance the efficacy of its HACCP checks, internal inspection processes, and food safety training activities. Holding up a video iPod whose screen was playing a training film, he promoted the use of these types of hand-held devices as visual training aids. “Historically, the food safety professionals have to require employees to come into a central location so they can do training with the visual training support that they need. But these types of tools and technologies allow you to make training very mobile and take it to the people. These tools are very effective because they allow you to visually display what you are trying to communicate, which is particularly beneficial in the foodservice industry where we are seeing an ever-increasing number of employees who don’t speak English as their primary language.”

Your Talent Deserves Red Carpet Treatment: Awards and Incentives
Eight years ago, Clyde’s Restaurant Group, which owns and operates more than a dozen restaurants throughout greater Washington, DC, had no quality assurance program, So when an employee contracted hepatitis A, they recognized the need to focus on reducing risk from ill employees and poor handwashing practices—two of the top five risk factors identified by FDA in its benchmark surveys. But how to effectively communicate the importance of food safety practices to frontline workers, the critical role they play in reducing risk factors, and get them to commit to practicing what they learned every day and on every shift?

What Clyde’s came up with is well-known throughout the industry as the Handwashing Olympics, an unique annual incentive and award event that rewards good food safety practices and reinforces critical food handling training messages in a positive way. The handwashing competition, which focuses on the basics of good handwashing and food safety knowledge, brings together Clyde’s hourly employees, managers and regulators (as judges) in a fun environment with prize money and medals for the top teams. The contest runs throughout September, National Food Safety Education Month each year, and is a highly anticipated event throughout the company.

Victoria Decker Griffith, CFSP, Clyde’s Restaurant Group’s director of quality assurance, says that the competition has fostered an increased awareness of employee health, hand hygiene and food safety, which helps reduce the risk factors of highest concern to the company. “We know that handwashing and personal hygiene are common challenges for the restaurant industry,” she says. “This business is driven by people, so when employees come to work it is essential for them to understand their role in the foodservice operation. The employees really do have a better sense of some of the things that we’re worried about, particularly those who are scheduled to work but who aren’t going to tell us about symptoms of illness. We feel confident that we are impacting our staff through the handwashing competition and by making handwashing so prevalent as a subject matter in our training programs.”

Training servers and cooks in all of its restaurants to serve and prepare food safely starts with handwashing, adds Tom Meyer, Clyde’s executive vice president, which is worth the investment made to fund the contest. “In the big scheme of things nothing is more costly than a foodborne illness outbreak in one of our restaurants. What this event costs is below the radar; financially it’s the best money we can spend.”

Investing in creating positive recognition or positive consequences for food safety through award and incentive programs is definitely effective in promoting long-term behavioral change, agrees Disney’s Frank Yiannas. “Many years ago the Walt Disney World food safety team developed a whole host of strategies aimed at creating positive consequences for food safety. One of these is the Walt Disney World Food Safety Partner Award. We’ve been doing it for seven years as an annual celebration where we recognize those locations that have been doing an outstanding job in food safety performance.”

During the year, the food safety team measures the performance of every food and beverage location and staff operating on Walt Disney World property. Locations are measured and scored on: 1) how well each location is doing under state regulatory inspections, which address the FDA risk factors; 2) how each location is doing in their own internal food safety evaluations; 3) how well each location is doing with regard to HACCP checks, such as meeting requirements that food products be checked for HACCP temperatures and parameters on a consistent basis throughout the day; and 4) how well each location is doing in its degree of compliance with required food safety training. Based on these four objective measurements, an overall score is given for each location and the top rated location is recognized at a celebration where the winning group is presented with the prestigious Food Safety Partner Award glass sculpture.

“I think positive recognition brings out the best in people,” he explains. “We measure food safety performance for a variety of reasons, one of which is obviously to provide coaching and feedback in areas that aren’t as effective as they should be. But certainly one of the reasons we measure is to catch people when they are doing things right. And I believe that when you catch people doing things right and give them positive reinforcement it will lead to better behaviors.”

The Ticket to Reduced Risk: Industry-Regulator Partnerships
Fostering partnerships between local, state and federal public health inspection agencies and food establishments is another common theme in the FDA’s satellite broadcast. County and state food safety inspection agencies who participated, including—including DeKalb County’s Food Protection Program located near Atlanta, GA, the County of San Diego Department of Environmental Health, and the Maricopa County Environmental Health Division in Phoenix, AZ—all mentioned this as a critical factor in successful foodborne illness risk reduction in this sector.

By using FDA’s risk factor benchmarking surveys to focus efforts on the most common and critical food safety issues and create risk assessment-based rather than enforcement-oriented inspection strategies and programs, environmental health inspection agencies are better able to focus their efforts on the issues that have the greatest public health impact and communicate those to industry as a partner in achieving long-term compliance and risk factor reduction.

Jennifer Kirby, an environmental health specialist with DeKalb County’s Food Protection Program, says that her agency’s data analysis system allowed them to track the performance of all establishments and trend the data to get an overall picture of where the greatest problems were within the county with regard to specific violations. The county was then able to develop an early intervention risk assessment program geared towards assisting smaller, independent operators with free consultations by DeKalb County inspectors to help them develop their own risk control plans and teach them how to prevent bad habits from a food safety perspective. The early intervention consultation is done within the first four months of a particular establishment beginning to serve food to the public, whether it’s a new operator or a change of ownership, she adds.

“Our risk assessor will go in and dialogue with the operator about those menu items, take a look at all of the operations as far as the employees, their detailed functions, who is in charge of dishwashing, who is in charge of handling the food, and so on,” says Kirby. “The assessor will basically outline or put a plan of action together for the operator to ensure that they understand the importance behind [risk factors] such as time and temperature, the significance of handwashing at the critical steps in the food handling process, and the importance of sanitation of cutting boards.”

And these partnerships really do pay off in terms of reducing risk factors, agrees Kirby’s colleague, Julayne Gath, REHS. As an example, she says, “We changed our inspection forms to focus on the risk factors, and since it is scannable, we are actually able to track a reduction in risk factors over time and how the risk factors are being reduced.” By partnering with industry to get a handle on risk factors, Gath notes, foodborne illness has been reduced in San Diego County by more than 50% for specific organisms.

Lights, Camera, Risk Reduction Action
“It is not my job to create a bigger and better food safety program,” says Walt Disney World’s Frank Yiannas, “it is really to create a food safety culture. When you create a food safety culture, you actually change the thoughts, behaviors and beliefs of individuals within a group.”

As the success stories featured in the “Reducing Risk Factors at Retail and Food Service” broadcast attest, foodservice and retail operators and public health and inspection professionals are doing just that. This paradigm shift in stakeholder communication and partnering is creating a food safety culture that should have a positive impact on reducing risk factors, an impact that many project will show in the 2008 benchmark surveys. Will your operation have a starring role as a contributor?

Julie Larson Bricher is Editorial Director, Food Safety Magazine.