Regulatory Credentialing in Food Safety
By Robert W. Powitz, Ph.D., MPH
Unlike any other regulatory credentials, those in food safety are decidedly different in scope and development, training and measures of competency. Whether a license, registration or certification, credentialing is defined as an individual process, usually in written form, that provides a basis of confidence and indicates evidence of authority in a given field. In effect, a credential is a document attesting to the truth of certain stated facts. In the case of the sanitarian, credentialing takes on certain urgency. From a regulatory perspective, regulatory credentialing is a necessity; it defines our profession and provides credibility. For our clients, credentialing evens the playing field. From the retail side, having a credentialed individual on site provides some assurances that food protection is integral to that foodservice operation.
If I am correct in my assumptions, there is a two- and sometimes three-credential approach to food safety. On the regulatory side, the credential begins with either licensure or registration as a professional sanitarian: the Registered Sanitarian (RS) or Registered Environmental Health Specialist (REHS), or some permutation thereof. This credential attests to the individual’s knowledge in a wide variety of environmental health sciences, including microbiology, toxicology, epidemiology, contamination control, response to environmental health emergencies and regulations.
In some instances, sanitarians and other industry professionals working within the retail food industry obtain an additional credential relating to their specific competency in food safety by integrating food microbiology, Hazard Analysis and Critical Control Points (HACCP) principles and regulatory requirements into questions that test problem solving skills and their ability to properly interpret the Food Code. My only wish is that “Plan Review” and housekeeping would be added to this mix. This credential is known as the Certified Food Safety Professional (CFSP). The CFSP is available through the National Environmental Health Association (www.neha.org)
On the retail side of regulatory credentialing, we have the Certified Food Manager—also known by such other names as Qualified Food Operator or Certified Kitchen Manager—which is provided through a number of approved sources. A quick search of the Internet yields a wide selection. The credential attests to the manager’s knowledge of the principles of food protection within a foodservice operation.
We know that when these three regulatory credentials are applied at the same time; within the scope of a comprehensive regulatory food safety program, there may be a significant reduction of risk of foodborne hazards. For example, those health departments that vie for the Crumbine Award sponsored by the Foodservice and Packaging Institute (FPI) and embrace the concept of risk-based inspections conducted by properly credentialed sanitarians, and where the presence of a Certified Food Manager is mandated for all retail food establishments, a significant reduction of foodborne misadventures can and have been documented.
In addition, as recently as November of last year, Dr. Craig W. Hedberg authored an article that appeared in the Journal of Food Protection, in which he stated that well-trained and certified kitchen managers may significantly reduce risk of foodborne hazards. The implication is that the reduction of risk may even be independent of regulatory oversight. In summation, regulatory credentialing in food safety really works and can work well.
So, if regulatory credentialing in food safety really works, what piques my curiosity is how these credentials are fashioned. I, and many of my colleagues, wonder if strengthening the credentialing process at all levels would have even a greater effect on food safety.
The Apprentice, Sanitarian-Style
The most important fact to realize is that credentialing for regulatory inspectors and foodservice managers is not mandated everywhere. Unlike the universal licensing for barbers and beauticians (and plumbers and electricians, physicians and nurses, or lawyers), not all governments place a value on food safety by requiring credentials. To my best estimate, only about 80% of our nation’s regulatory agencies, including the federal government, require certification of inspectors and managers engaged in the food safety business.
When I get my hair cut, regardless of where I am at the time, the person doing the cutting is licensed. They obtain their license through a well-defined process by attending a school to learn their craft and familiarity with the regulations covering their vocation. Barbers serve an apprenticeship, not only to master the skill of cutting hair but also to understand the diseases of the scalp and how to prevent them from spreading from customer to customer. They learn how to protect themselves and their clients against exposure to bloodborne illnesses and they know how to apply the various disinfectants and antiseptics used in their trade. Every barber takes a written examination, and in some cases, the applicants have to demonstrate their skill to a professional examiner, who in turn, is a licensed barber. On the contrary, some food establishment inspectors do not get formal training or mentoring before working in foodservice enforcement. We don’t have enough colleges teaching young professionals the art and science of food protection and we don’t have enough young professional to meet the regulatory and societal demands.
Unlike barbers, physicians, plumbers and electricians who are trained by co-professionals, sanitarians may or may not receive their formal training from another practicing sanitarian, or for that matter, anyone who has worked in the field of environmental health. Unlike barbers, physicians, plumbers and electricians who have to demonstrate both their knowledge and skills of their profession, for the most part the sanitarian credential only measures knowledge—not the level of skill. Unlike other professions that have apprenticeships, many health departments have none. The sanitarians’ attributes, or ability to use their knowledge and skills, only get evaluated as part of their on-the-job performance. Competency is often more a function of the individual’s professional pride than formal training.
When you think about it, the picture is equally as nebulous with foodservice operators. Not many cooks and restaurateurs are graduates from culinary schools or received formal training in food safety and protection. In most instances, the prerequisite for Certified Food Manager credentialing consists of the ability to read and about six to eight hours of didactic training, followed by an exam. In addition, there are few requirements for continuing education between recertification. Even stranger, is the fact that those doing the training are not required to be credentialed or even to have worked in the retail food or regulatory industry. I hate to say it, but if this credential is not mandated by regulation or corporate responsibility, its primary motivating force is the fear of lawsuits.
Room for Improvement
The barber is trained to cut hair; likewise, the food safety inspector should be trained to inspect and the foodservice manager should be trained to maintain the highest standard of food protection. If I get a bad haircut, the barber will no longer have my business. This is not the case of the regulator. We have little recourse to poorly conducted inspections and hardly any form of redress from them. Poor food practices at the retail level lead to mighty inconveniences, which are indeed difficult to undo. In short, food safety credentialing and competency go hand-in-hand. I am thankful that barbers are licensed, and that part of their licensing criteria is the prevention of disease. However as of last count, foodborne E. coli O157:H7, Salmonella, Campylobacter, Clostridium and Listeria, along with norovirus and a host of other microorganisms of public health concern, far outweigh ringworm of the scalp in sheer numbers and severity. Am I missing something? Are our priorities a bit skewed? As you can readily see, there’s huge room for improvement. And, it is up to us all to demand universal competency in food safety.
I charge everyone reading this column to get involved in the regulatory credentialing process and take an active political role advancing the credentialing process either in government or with your trade association. To learn more about understanding the concepts of credentialing, including the purpose, definitions and descriptions of types of credentials; processes used in conducting or choosing a psychometrically sound, legally defensible credentialing program; and the differences between end-of-course tests and professional credentialing examinations, I refer you to the National Organization for Competency Assurance (NOCA) website (www.noca.org) and visit to their publications page.
Forensic sanitarian Robert W. Powitz, Ph.D., MPH, RS, CFSP, is principal consultant and technical director of Old Saybrook, CT-based R.W. Powitz & Associates, a professional corporation of forensic sanitarians who specialize in environmental and public health litigation support services to law firms, insurance companies, governmental agencies and industry. For more than 12 years, he was the Director of Environmental Health and Safety for Wayne State University in Detroit, MI, where he continues to hold the academic rank of adjunct professor in the College of Engineering. He is the first to hold the title of Diplomate Laureate in the American Academy of Sanitarians, and also is a Diplomate in the American Academy of Certified Consultants and Experts and with the American Board of Forensic Engineering and Technology. Contact Dr. Powitz directly at firstname.lastname@example.org or through his website at www.sanitarian.com.