Standardization Job Aid Manual for Candidates

Provided by
Georgia Department of Public Health
Environmental Health Section
Food Service Program

August 2014

0
PRIOR TO STANDARDIZATION

The training and standardization process of an EHS in food service inspections is critical. Proper training
along with coaching, and constructive criticism will help evolve an EHS’s expertise in conducting risk-
based inspections. The training an EHS attains should help them develop both technical mastery, as well
as interpersonal skills such as effective communication, and dispute resolution to prepare them for
standardization. During standardization, the Candidate must demonstrate to the Standard that he/she
is able to effectively communicate findings within a food service establishment using these interpersonal
skills.

Interpersonal skills include:

o Verbal Communication - What is said and how it is said.
o Non-Verbal Communication - What we communicate without words - body language is an
example.
o Listening Skills - How we interpret both the verbal and non-verbal messages sent by others.
o Negotiation - Working with others to find a mutually agreeable outcome.
o Problem Solving - Working with operators to identify, define and solve problems.
o Decision Making – Exploring and analyzing options to make sound decisions.
o Assertiveness – Influencing change by communicating tactfully and confidently

The EH core competencies are grouped into the three primary functions of an environmental health
program which are Assessment, Management, and Communication. The illustration below depicts the
core competencies as it relates food service inspections. If you notice, all of the interpersonal skills listed
above will fall within at least one of the core competency circles (below).

1
GUIDANCE FOR STANDARDIZATION & RE-STANDARDIZATION

Prior to Standardization, your District Standard Trainer should discuss the Standardization Guidance
document with you – it is a tool to assist you in understanding the goals and expectations of the process.
It is HIGHLY recommended that Standard Trainers discuss all elements within the guidance document
with you prior to beginning the first inspection.

o Standard Trainers have been coached and encouraged to discuss each bullet of the
Standardization Guidance Document with you and provide some relevant examples to you.

For example, under the section titled Standardization Observations and Performance Assessment, in
the fourth bullet it states; Determines the compliance status for each RF/PHI (IN, OUT, N/A, N/O,
Corrected On-Site, and Repeat).

During discussions with you, the Standard-Trainer should emphasize with you ALL Risk Factor/Public
Health Intervention (RF/PHI) items will have to be thoroughly discussed/verified during all inspections
during standardization – the compliance status for RF/PHI items should NOT to be assumed.

 It will be particularly important for you to determine the compliance status for when to mark
N/O versus N/A. The needed information you must determine through questioning is whether
an activity is one that is never performed at the establishment (N/A), or is the activity
performed at some point within the establishment but was not performed during the inspection
(N/O).

A great example to explain why it is imperative to discuss/verify the compliance status for RF/PHI is
below:

FYI: in the example below, please be mindful, the facility ONLY offers the meat [chicken] on its menu

o During an inspection an EHS observes a facility that only offers menu items that contain chicken
(chicken casserole, chicken sandwiches, chicken and waffles). The chicken the facility offers is
always heated by frying the chicken in the fryer. After the chicken is heated in the fryer, the EHS
determines the chicken items are hot held on a steam table until served. After thorough
discussion with the CFSM/PIC and review of invoices, and the product’s labeling, the EHS
determines the facility never purchases/uses raw chicken and the chicken the facility always
uses is “Fully Cooked” chicken; thus, making 5-1A having a compliance status of N/A.

o In the scenario above, it states the facility does not cook the chicken from raw… the
chicken is “Fully Cooked” and the facility always uses the “Fully Cooked” chicken in the
preparation of its menu items (chicken casserole, chicken sandwiches, chicken and
waffles). Furthermore, chicken that is heated for hot holding in food products at the
establishment would be assessed under; 5-1B: REHEATING FOR HOT HOLDING.
o In the scenario above, it is important to also know that without appropriate questions
and verification being done, the EHS could NOT have thoroughly assessed 5-1A during
his/her inspection – EHS’s MUST FULLY ASSESS EACH RF/PHI
o In addition, a compliance status of Not Observed (N/O) means a great deal as well. For example,
an EHS that marks N/O for cooling should ask the PIC about their cooling process. If not, the

2
 Standard should ask the Candidate to tell he/she about the establishment’s cooling process to
ensure that they know that the establishment’s food safety management plan must be
thoroughly assessed during the inspection. A great majority of food service inspections have
N/O for processes like cooling or receiving so asking about this process is critical (how it’s
performed, when it’s performed, which foods are cooled, suppliers, etc.). This can assist the EHS
in preparing for the next inspection at the establishment and, perhaps by changing the time or
day of inspection to ensure they can properly assess cooling, receiving, or other
practices/procedures taking place at the establishment.

A COPY OF THE STANDARDIZATION & RE-STANDARDIZATION GUIDANCE DOCUMENT IS ON PAGES 4-5.

3
 Guidance Document for Standardization& Re-Standardization

The Standardization process follows the Georgia Standardization Procedures, the ratified Cooperative
Agreement, and the performance elements found within the Uniform District Inspection Program. The
following is guidance for Candidates to better prepare for Standardization & Re-Standardization.

INSPECTIONS CRITERIA
• Performs 4 “real time” risk based inspections
• Prioritizes the inspection based on risk and processes determined through menu review or
observations made at the beginning of the inspection

STANDARDIZATION OBSERVATIONS AND PERFORMANCE ASSESSMENT

• Uses a risk based inspection methodology to assess active managerial control and
implementation of regulations related to employee practices and the facility’s food safety
management system in regards to cooling, cooking, reheating for hot holding, receiving
practices and food from approved sources.
• Assesses ALL Risk Factors for Public Health Intervention (RF/PHI) through open ended
questioning of the PIC/employee to determine policies/procedures in place for instances when a
specific procedure is not observed during an inspection such as cooling or receiving.
• Obtains immediate corrective action for out of compliance employee practices and operational
procedures for RF/PHI violations.
• Determines the compliance status for each RF/PHI (IN, OUT, N/A, N/O, Corrected On-Site, and
Repeat). This is particularly important to determine the compliance status for when to mark N/O
versus N/A. The question the Candidate must determine through questioning whether an
activity is one that is never performed at the establishment (N/A) or is the activity performed at
some point within the establishment but was not performed during the inspection (N/O).

ORAL COMMUNICATION
• Asks open ended questions and engages in a dialogue with the person in charge/employees to
obtain information relevant to the inspection and processes.
• Provides the Person In Charge (PIC) and employees with accurate answers to inspection-related
questions or offers to research the question for the operator
• Uses effective communication and conflict resolution techniques to overcome inspection
barriers – offers corrective action strategies for long term compliance, and/or demonstrates
corrective actions for the operator
• Conducts an exit interview explaining the out of compliance RF/PHI observations and identifies
corrective actions.

WRITTEN COMMUNICATION
• Completes an inspection form as per the ratified Cooperative Agreement and the Uniform
Inspection Tool – documents the compliance status to include legally binding clear and concise
observations, and denotes Corrected On-Site (COS) and the action taken to correct the violation
on the addendum inspection sheet(s).
• Correctly cites all violations under the correct code provisions on the observation and corrective
action addendum sheet(s) for at least one inspection.
• Have all applicable inspection forms, a copy of the Georgia Food Code, Georgia Marking
Instructions for reference and accurate documentation.

4
PROCESS FLOW CHARTS
• Interviews the PIC/cook/other employees to identify procedures NOT observed during the
course of the inspection.
• Reviews menu ingredients and the recipe descriptions to determine operational steps, hazards,
pre-requisite programs, Critical Control Points (CCPs), and Critical Limits (CLs).
• Completes 3 flow charts using the format included in Standardization Cooperative Agreement -
one for each type of food prep process (selected by the Standard) with no more than two errors
or omissions total on all three flow charts. Exception: there should be no errors for CCPs or CLs.

RISK CONTROL PLAN

• Develops a hand written risk control plan that promotes long-term compliance for an observed
specific out-of-control risk factor. It is designed for the EHS to play the role of consultant and
work with the PIC to develop strategies to modify his/her current procedures through proper
monitoring and record keeping to achieve an overall behavior change in the facility’s
management system over time.

1. Through discussion with the CFSM/PIC/employees, the Candidate must determine the
actual “root” cause of the problem(s) causing the out of control RF violation to determine a
better practice that the operator can implement to correct the issue long term and prevent
reoccurrence.
2. Recommends specific measures to be implemented to control observed “gaps” in the
existing procedures – to assist the operator achieve long term compliance?
3. Generally, the following variables tend to be an area to focus the food safety system
intervention: equipment, people, food, processes or economics. For example, equipment
can be pre-heated before adding food, temperature lowered (cold hold) or raised (hot hold),
repaired, using shallow pans, etc. People can be trained or re-trained in proper practices.
Food can be changed such as using pasteurized eggs instead of raw shell eggs. Processes can
be modified to ensure controls for RF/PHI are in place such as using ice baths, agitating food
products, pre-chilling ingredients, batch prepare or batch cook, etc. Each food safety system
must be assessed on a case-by-case basis in the field to determine the most suitable and
plausible long-term intervention strategy to control the underlying factors observed within
the establishment.

SUPPORTING MANUALS AND REFERENCES

• These manuals and references should be used as guidance documents prior to and during
Standardization/Re-Standardization:
1. The Georgia Food Service Rules and Regulations
2. Interpretation Manual Section D – Conducting Risk Based Inspections
3. Interpretation Manual Section K-11 – Inspection Marking Instructions
4. Interpretation Manual Section L – Georgia Standardization Procedure

5
The District Standard Trainer plays an integral role in the professional development of EHS with
responsibilities in inspecting food service establishments.

All new EHS must complete at least 25 joint inspections in which he/she takes the lead during the
inspections. It is HIGHLY recommended that the District Standard-Trainer accompany a new EHS for the
25 joint inspections so that the District Standard-Trainer can coach and mentor the EHS throughout the
process to ensure a proper risk-based inspection that meets criteria in the District Uniform Inspection
Program. If the District Standard-Trainer cannot accompany an EHS during the 25 joint inspections, then
it is STRONGLY recommended that the District Standard-Trainer review ALL inspection reports
completed by the EHS during the training process. The District Standard-Trainer should verify the EHS’
inspection reports and addendum pages comply with the District Uniform Inspection Program tool, such
as but not limited to, inspection findings and code citations that comply with the Georgia Marking
Instructions, legally binding observations along with corrective actions, and Risk Factors are corrected
on-site immediately with the long-term corrective measures addressed with the operator.

o NOTE: Demonstration inspections are those in which the District-Standard Trainer takes
the lead and the new EHS observes the inspection process so that you can gain a more
practical “day-to-day” awareness of how inspections are conducted.
o NOTE: JOINT INSPECTIONS are those in which the EHS being trained takes the lead, and
demonstrates the EH competencies in conducting risk based inspections.

PREPARING FOR A RISK BASED INSPECTION

INSPECTION PREPARATION
Before conducting an inspection, it may be helpful to do some research to ensure that you have
background knowledge on the facility that you will be inspecting. The previous inspection reports,
menu, and the floor plan/kitchen layout should reviewed to become familiar with and better understand
the food service establishment’s compliance history, risk factors that may be involved with the menu,
and assist you in brainstorming inspection priorities.

When conducting risk-based food service inspections, you should enter the food service establishment
during the establishment’s hours of operation or at other reasonable times. Upon arrival, you should
show identification and let the person in charge (PIC) know the purpose of the inspection. The previous
inspection reports may give you an indication of the times (e.g. early morning, during lunch, after lunch,
etc.) that previous inspections occurred and processes that were observed or not observed during those
inspections.

When planning for inspections, timing should always be considered. As previously mentioned,
inspections may occur outside of an establishment’s hours of operation, when necessary, to observe
often missed activities such as receiving of Time/Temperature Control for Safety (TCS) foods. Several
operational steps at the food service establishment such as receiving, preparation, and cooling can be
observed only during limited time periods. As appropriate and with your management’s approval, EHS
may conduct some inspections early in the morning or late in the evening, when necessary, to evaluate
special processes.

6
DEVELOPING CLEAR PRIORITIES

At the food service establishment, it is important to develop clear priorities in order to make the most
efficient use of your time in each food service establishment. For example, certain behaviors, practices,
and procedures that happen during the cooking and cooling processes may contribute to the risk of
foodborne-related illness, and are only observable during a limited period of time. These are called
“Dynamic” activities because they likely to change during the course an inspection. Observing these
processes MUST be a priority. Other basic sanitation or general maintenance issues, such as dumpster
drain plugs and floor tiles missing, are unlikely to change during the course of the inspection and can
wait. These issues are referred to as “Static” activities. “Dynamic” activities MUST always be your top
priority over “Static” activities.

For example; cooking a hamburger is considered a “Dynamic” activity. If you arrive at an establishment
while a hamburger (without consumer advisory) is being cooked, you should prioritize the inspection to
ensure that you are able to assess the final cooking temperature of the hamburger. If you decided to
check the outside dumpster for the drain plug, which is “Static”, before checking the cook’s line, you
would miss the opportunity to verify that the hamburger was cooked to an internal temperature of
155°F for 15 seconds or above prior to being served to a consumer. This is an example of why risk MUST
always be considered when prioritizing your time during an inspection.

ACTIVITIES TO HELP EFFECTIVELY SET PRIORITIES

There are four activities that can be completed prior to or early in the inspection to ensure that
priorities are effectively set. You should 1) review previous inspection reports, 2) ask specific questions,
3) conduct a menu or food list review, and 4) conduct a quick walk-through. These activities will help
you to adequately determine and assess any processes or factors that may be occurring and are critical
to the investigation. Please note that items 2, 3, and 4 can be done simultaneously at the start of the
inspection.

On the next few pages each of the four previously mentioned activities will be discussed.

1. REVIEW PREVIOUS INSPECTION REPORTS

First, you want to review previous inspection reports. This can happen at the office prior to the
inspection or once you arrive on site. Reviewing previous inspection reports is especially important in
jurisdictions where EHS rotate from one inspection to the next. Reviewing the previous inspection
reports has two main purposes. First, if the same foodborne illness risk factors are out of compliance
during more than one inspection, it is strongly recommended that the EHS work with the operator to
develop an intervention strategy to prevent its recurrence (i.e. a risk control plan). Second, knowledge
of what has been corrected since the previous inspection allows you to provide positive feedback to the
operator, and track corrected violations in accordance with the GA Food Service Rules and Regulations.

2. ESTABLISH AN OPEN DIALOGUE WITH THE PERSON IN CHARGE BY ASKING SPECIFIC QUESTIONS

Next, you want to establish an open dialogue with the person in charge by asking specific questions
about the operation. Since the tone of the inspection is often set in the first few minutes, this activity is
critical. Your approach should be professional yet personable. Remember that showing genuine interest

7
in the establishment and the staff translates into a positive relationship that can be helpful in promoting
public health.

An open dialogue with the person in charge will allow you to learn important information about the
existing food safety management system. Knowing about the strengths and areas for improvement in
the existing food safety management systems will allow you to focus your inspection on areas for
improvement. Throughout the inspection, you should ask questions about practices and procedures
related to foodborne illness risk factors and the interventions such as the methods for cooling and types
of foods cooled, time frames for TCS food deliveries, etc. Asking enough questions to fully understand
the system being used in the food establishment is crucial. Early in the inspection, you should ask about
activities that are currently taking place since some activities are only observable for a limited amount of
time such as cooking, cooling, receiving, etc. Keep in mind, cooling must be assessed over a period of
time by assessing at least two measurements to assess compliance. Therefore, taking a cooling
temperature at the beginning of the inspection and again after some time will allow you to assess the
cooling curve and to determine whether the cooling method will meet the prescribed cooling
parameters. In addition, you should ask about the process for cooling foods that were cooled previously
and being held at 41 degrees Fahrenheit to determine whether proper methods for cooling are being
used. This may not warrant marking a violation but the EHS could certainly educate the operator on
proper cooling methods to ensure future cooling is performed using an appropriate method to facilitate
rapid cooling.

The person in charge of the food establishment should be encouraged to accompany you during the
inspection. Throughout the inspection, it is important to allow the operator to discuss any issues related
to food safety. One-way communication on your part is discouraged and is not conducive to a risk-based
philosophy. Maintaining two-way communication and open dialogue leads to an effective risk-based
inspection. In addition, it can save time since many violations can be pointed out and corrected by the
PIC as they are observed. It is important to note that violations that which are corrected immediately
should still be marked on the inspection form; however, a slight violation, such as one dirty utensil
among hundreds of clean utensils does not indicate that the food establishment is significantly deviating
from the Chapter requirements; therefore, discretion in marking is required. Corrective action should be
taken for the dirty utensil by placing it at the dish machine to be washed.

3. REVIEW MENU/FOOD LIST

Reviewing the food establishment’s menu or food list can also help to set priorities. This can be done in
a fairly simple manner either before arriving at the establishment, during a quick walk-through of the
operation, or at the beginning of the inspection as a discussion with management. An advantage in
assessing the menu in the food service establishment’s file at the office allows the EHS an opportunity to
take time to fully assess the menu and the EHS can readily identify if there have been changes to the
original menu when he/she arrives at the food service establishment. As previously mentioned, it is
important for EHS to review menus and the history of a food service establishment’s compliance history
prior to conducting a risk based inspection. Generally, these items are in the food service
establishment’s file and can be thoroughly reviewed in the office; however, because menus often
change a second review is required at the establishment along with questions about seasonal items
during the quick walk-through of the kitchen to discern inspection priorities before beginning the
inspection. The menu review and establishment’s previous food safety history will enable the EHS to
learn about the complexity of the food items being served, and the establishment’s food safety

8
management system. Then the EHS can develop strategies for prioritizing the inspection based on risk
factors associated with the establishment.

PROCESS APPROACH TO HACCP

The menu review will allow you to begin grouping food items into one of three broad process
categories which helps to focus the inspection on the control measures critical to each process.
This helps in setting priorities by identifying high-risk foods or high-risk food preparation
processes as well as operational steps that require further inquiry such as receiving,
preparation, cooking, and cooling.

In conducting risk-based inspections, it is necessary for EHS to be knowledgeable of food

preparation processes. Knowing how products are prepared in an establishment allows EHS to
focus their inspections on the critical procedures and steps in the preparation of these products.
The process approach to HACCP refers to the number of times a food passes through the danger
zone (between 41 degrees and 135 degrees Fahrenheit) for food safety. Process 1 foods may go
into the danger zone, but do not require a complete trip through the danger zone for food
safety. Process 2 foods make only one trip through the danger zone for food safety, and Process
3 foods make multiple trips through the danger zone.

Identifying high-risk foods or high-risk food preparation processes will allow you to focus the
inspection on those that are more likely to cause foodborne illness, if uncontrolled. The menu or
food list review may be your only opportunity to be made aware of specialized processes such
as formulating a food so that it is not potentially hazardous, or high-risk seasonal foods such as
raw oysters on the half shell. Because several operational steps may not be inspected as
vigorously during inspections due to the hours of the day that these steps occur, it is imperative
that you ask enough questions to obtain information about the operational steps that cannot be
directly observed during the current inspection in order to evaluate the establishment’s active
managerial control of foodborne illness risk factors.

HOW TO CONDUCT A MENU REVIEW

The menu is one of the most helpful tools for you to use for prioritizing your inspections. For
example, a nursing home’s menu may list roast beef with red potatoes and carrots. From
previous inspection experiences, you would be able to recognize that roast beef is a menu item
that is often offered rare, and it is often prepared in advance (cooked, cooled, and reheated)
prior to service. Therefore, you would want determine early on in the inspection whether any
foods were leftover from the day before, especially the roast beef. For example, you may ask
the operator “do you have any leftovers from last night”? The operator may reply “no” and if so,
you may say “what about the roast beef” which may jog his memory and it demonstrates that
you are familiar with his menu.

Furthermore, if the roast beef was cooked and cooled, then you should begin developing
preliminary thoughts/strategies for determining critical limits that the roast MUST meet for food
safety. For instance, is the roast beef reheated for immediate service or will the roast beef be
reheated for hot holding? You must ask the operator specific questions regarding how the
cooked and cooled roast beef is going to be prepared and served to clients. This is very critical
because if the roast beef is reheated for immediate service it can be reheated to any

9
 temperature; however, if the roast beef is going to be reheated for hot holding, then the roast
beef would have to be reheated to requirements in GA Food Service Rules and Regulations to
control for outgrowth of spore forming bacteria.

Furthermore, a thorough review of the nursing home’s menu could also allow you to determine
if further inquiries would be needed regarding the preparation of other food items – specifically,
food items such as the eggs, raw animal foods, juices, and other food items.

Lastly, a review of the nursing home’s menu will allow you to develop strategies on other special
food safety requirements that are necessary to protect individuals who are more vulnerable to
foodborne illnesses than the general population.

For instance, the GA Food Code has special requirements (see chapter .04) that relate to
facilities that serve a Highly Susceptible Population (HSP), and those provisions are additional
safeguards that are put in place to protect people who are more likely than the general
population to experience foodborne illness because they are immunocompromised, preschool
age children, or older adults, AND obtain food at a facility that provides services such as
custodial care, health care, or assisted living, such as child or adult day care center, kidney
dialysis center, hospital or nursing home, or nutritional or socialization services such as a senior
center. Keep in mind that elementary schools are ONLY classified as HSP in regards to juice.

4. CONDUCT A QUICK WALK-THROUGH

An additional activity that should take place early on in an inspection to ensure that priorities are
effectively set is a quick walk-through of the establishment. This can happen simultaneously with other
activities, such as while you are establishing open communication with the person in charge, and
reviewing/discussing the menu or food list.

Conducting a quick walk-through at the beginning of the inspection will allow you to observe what is
happening at that time and may be especially useful in determining and prioritizing dynamic activities
that may otherwise go unnoticed or unobserved if not prioritized, such as receiving PHF/TCS foods, food
preparation and handling, cooking, cooling, or reheating for hot holding.

While conducting the quick walk-through, speaking directly to the food service employees that are
performing specific tasks is another excellent way to assess the effectiveness of the PIC performing his
or her duty of food safety training.

All EHS will be THOROUGHLY assessed on their knowledge and application of Risk Factors identified in
the GA Food Service Rules and Regulations during the standardization process. During standardization,
your District Standard Trainer will routinely assess and ask you thought provoking questions to
determine if you are knowledgeable in applying the provisions of the GA Food Code. Below are some
ways the District-Standard Trainer may assess your knowledge and application in assessing Risk
Factors/Public Health Interventions (RF/PHI) for compliance during inspections.
o The Standard-Trainer could inquisitively ask you to explain how you determine foods were
received from approved/reputable sources (by review of packages for inspection stamps,
invoices, parasite destruction letters, etc.)

10
 o The Standard-Trainer could ask you to explain in your own words the provisions of the GA
Food Code that pertain to Date Marking (date marking requirements and which food items
date marking requirements apply to, and/or to explain in your own words date marking
disposition) and you assess it during inspections.
NOTE: The overall objective is to complete the standardization process to ensure that the EHS have a
clear understanding for applying HACCP-based principles and conducting a proper risk-based inspection
that would meet all the elements in the District Uniform Inspection Program. Be prepared to explain the
rationale for decisions that you make during your standardization procedure to the District Standard-
Trainer so he or she can adequately assess your understanding and application of the Rules.

11
Helpful Strategies

12
Person in charge present, demonstrates knowledge, and performs duties - 4 items to verify

You must assess whether or not there is a Person In Charge (PIC) present and designated at the time
of inspection. Who is the PIC? Does that person have a valid CFSM certificate? If he/she has NOT
passed an accredited exam and does NOT have a CFSM certificate then you MUST see item #2 below.

1. The food code requires a designated PIC to be in the food establishment at all times
during the hours of operation. He/she is required to demonstrate knowledge of
foodborne disease prevention, application of HACCP principles, and knowledge of GA
Food Code provisions during inspections.

There are 3 options for determining Demonstration of Knowledge:

o Certification: the PIC is has certification by a professionally validated CFSM exam that
has been accredited by the Conference of Food Protection as specified in chapter .03 of
the GA Food Code;
o Compliance: compliance with the food code by having NO violations of Risk Factors/
Public Health Interventions (RF/PHI) during the current inspection;
o Knowledge: the PIC correctly responds to open-ended questions regarding food safety
processes or operational steps that pertain to their specific food operation as outlined in
Rule .03 of the Chapter. The dialogue should be sufficient enough to reveal whether or
not the PIC has a comprehensive understanding of food safety principles so that foods
produced are safe, wholesome, unadulterated, and honestly presented.

Below are some sample questions that may assist in assessing a PICs Demonstration of Knowledge (only
questions pertaining to the food service operation should be asked). EHS should question the PIC based
on what he/she observes during the inspection and keep in mind that the goal of questions should not be
to mark violations but to gain a better understanding of the food safety management system and its
ability to control foodborne illness risk factors. See the diagram on page 18 for assessing when to mark
“Demonstration of Knowledge” on Inspection Report. Note: EHS must use good judgment in determining
a sufficient number of questions to ask to assess items within the 17 food safety questions in Rule .03 to
mark demonstration of knowledge as “OUT”.

TEMPERATURE CONTROL FOR TCS FOODS

• How do you ensure TCS foods are maintained at the appropriate temperatures?
• What temperature should foods be kept during refrigeration? How is this verified?
• What temperature should foods be kept during hot holding?
• What are your hot holding procedures (steam tables, stove tops, ovens)?
• Why do TCS foods need to be kept out of the “danger zone”?
• How do you know if TCS foods are cooked to the correct temperature?
• What temperature do you cook __ (fill in the blank with a food item they cook from a raw
state)? Why?
• Do you ever serve food items raw or undercooked? If so, which ones?

13
• What do you do with foods that aren’t at the proper temperature?
• Describe your cooling procedures (time & temperature parameters as well as cooling methods)
for _____ (fill in the blank with a food item they cool)?
• Do you cool TCS foods overnight? How is this monitored overnight?
• What are your reheating procedures (microwave, range top, steam kettle, steam table)?
• What do you use the microwave for?

CROSS CONTAMINATION/HAND CONTACT/HANDWASHING

• Why should food employees prevent cross contamination?

• What steps should employees take to prevent cross contamination with hands?
• What do food workers use to handle ready-to-eat foods?
• Where and when do food workers wash their hands?
• When should the dish wash employee operating the dish washer wash his/her hands?
• Describe in detail when employee hands should be washed.
• What measures do you implement in controlling food allergens when handling foods?

EQUIPMENT – CLEANING & SANITIZING

• Why is it important to have handwash sinks located near food prep areas?
• What are the hazards associated with equipment that is not clean or in good repair?
• How do you clean & sanitize equipment & utensils (dish machine, dish sink, clean-in-place)?
• What kind of sanitizer do you use? How do you determine its strength?
• Can you explain the 3 step process for cleaning dishes/utensils in the 3 compartment sink?
• Describe your procedure on how you clean the meat slicer, the vegetable dicer, the soft serve
machine?
• How do you clean & sanitize the vegetable prep sink?
• How do you clean & sanitize the interior of the ice machine?
• How often do in-use utensils get cleaned & sanitized throughout the day (2 hours, 4 hours)?

WATER SOURCE/BACKFLOW PREVENTION

• Where do you get your water from (municipality water or well water)?
o If on a well (non-public water supply) then you should review the most recent W-33
report prior to your inspection and determine if you are going to perform one of the
four quarterly coliform tests at the inspection.
• Where do you get your ice from?
• Is the restaurant on a septic system or a public sewer system?
• What steps do you take to avoid cross connections in this facility?

CHEMICALS

14
 • How and where do you store your poisonous/toxic chemicals?
• What chemicals are used in the establishment?
• Do you use pesticides in the establishment? If so, what kind and where are they stored?

Be mindful that questions should focus on RF – the timing of questions asked will vary based on the
circumstances of the inspection. If the PIC is able to accompany you during the inspection, questions can
be asked throughout the inspection. Other times, questions may be asked during the exit conference
(the time at the end of the inspection when you explain your observations/violations and corrective
actions found during the inspection).

2. You must assess the Duties/Active Managerial Control (AMC) of the PIC during your
inspection. In other words, you must verify if the PIC has AMC and is performing duties to
control risk factors, and has implemented a food safety management system to ensure
foods are handled safely. For example, if you determine there is a pattern of non-
compliance/obvious failure by the PIC to control risk factors and ensure food safety
standards during an inspection, then the PIC may not have been performing his/her
duties, and more than likely would not have had AMC over risk factors. Determining if a
PIC has AMC and is performing duties will take a considerable amount of professional
judgment on your part – so it is important that an overall evaluation of the PICs ability to
ensure risk factors are controlled and food safety systems in place are effective should be
considered.

3. There MUST be a CFSM on staff. He/she does not have to be present at all times, but if
he/she is not present, then he/she should designate a PIC that has the same knowledge of
food safety as he/she does (see item # 2 above on how to assess a PICs knowledge). The
original copy of the CFSM certificate should be posted in public view at all times and
verified during the inspection.

** On the next few pages there are flow charts to assist you for determining the compliance status for
item 1-2 – Person in charge present, demonstrates knowledge, and performs duties on the GA Food
Service Inspection Form.

15
 Is there a designated PIC ASSESSING ITEM 1-2 ON THE
present at the time of your
inspection? INSPECTION FORM FOR FACILITIES
REQUIRED TO HAVE A CFSM

(after the 90 day time period)

Does this person have a
NO YES
CFSM certificate?
Is the PIC able to answer
the food safety questions
Item 1-2 marked OUT
in Section .03(1)(c) as it
.03(2)
relates to their
YES NO NO
PIC Present establishment?**

Is he/she
performing the
duties outlined in At the conclusion of the
.03(2)(a-n)?* inspection, did the
YES
establishment have any
RF/PHI violations?

YES NO

Item 1-2 marked OUT

.03(2)(a)-(n) NO YES

Responsibility of PIC
Item 1-2 marked OUT
.03(1)(a)-(c)

Is there a CFSM on staff? No Demo of Knowledge

*Use good judgment for an overall evaluation.

YES NO Should only be marked OUT when there is a PATTERN of
non-compliance and OBVIOUS failure by the PIC to ensure
employees are complying with the duties listed in .03(2).

Is the current CFSM Item 1-2 marked OUT

certificate posted? .03(3)(a)-(d)
**When evaluating this item, use good judgment
Certified Food Safety Manager
after asking a sufficient number of questions to
make an informed decision.

YES NO

Item 1-2 16
marked IN
 Assessment of Person in Charge Present - .03(2)

If there is a designated PIC, proceed to Assessment of

Demonstration of Knowledge

17
Assessment of Demonstration of Knowledge - .03(1)(a)-(c)

Once you have determined whether or not the PIC can demonstrate knowledge,
you must proceed to evaluate whether he or she is performing their duties by
fulfilling the Responsibility of the PIC.

18
Assessment of Responsibility of the Person In Charge - .03(2)(a)-(n)

*Use good judgment for an overall evaluation. Should only be marked OUT when there is a PATTERN of
non-compliance and OBVIOUS failure by the PIC to ensure employees are complying with the duties listed in
.03(2).

**When evaluating this item, use good judgment after asking a sufficient number of
questions to make an informed decision.

19
Assessment of Certified Food Safety Manager on Staff - .03(3)(a)-(d)

Once you have determined if the Person In Charge has met their three assigned
responsibilities, you still must determine whether or not there is an assigned
Certified Food Safety Manager to the facility before you can complete the
assessment for Item 1-2 and mark it IN or OUT of compliance.

20
Employee Health, Good Hygienic Practices, Preventing Contamination by hands

Assessing employee health and good hygienic practices of employees will require you to assess the
facility’s employee health policy/procedures – the PICs knowledge/awareness of an employee health
policy (symptoms, illnesses, reporting requirements, and restriction/exclusion), using proper
handwashing procedures, and eliminating bare hand contact with ready-to-eat foods.

You should ALWAYS discuss with the PIC their awareness of employee health policy requirements in
detail during your inspections!

• It is essential NOT to lead (by pointing to or where) the CFSM/PIC to specific information you are
attempting to ascertain from them:

 For example; if the CFSM/PIC gives you a written copy of an employee health
policy, you should not point to the 5 reportable symptoms written in the policy
and tell the CFSM/PIC to read them to you.

 In addition, you should NOT merely accept the written employee health policy
as being IN compliance without asking the PIC questions about the policy to
assess whether he or she is familiar with the policy or would know how to react
to situations (such as what to do if an employee tells you he/she has Hepatitis
A). The PIC can use the written policy to answer your questions.

** For more guidance on how to assess employee health policy requirements, please see the following
page for items that need to be specifically discussed with the PIC during the inspection.

21
 EMPLOYEE HEALTH POLICY DISCUSSION TOPICS
 The 5 illnesses must be addressed in an establishment’s employee health policy. These illnesses have a low infectious
dose, contaminate the gastrointestinal system after ingestion, and are shed in feces.
 Norovirus
 Salmonella Typhi (typhoid-like fever)
 E. coli O157:H7, Enterohemorrhagic or Shiga toxin-producing E. Coli
 Shigella spp.
 Hepatitis A virus

 The 5 symptoms of foodborne illness must be addressed in an establishment’s employee health policy
 Vomiting
 Diarrhea
 Jaundice (yellow skin or eyes)
 Sore throat with fever
 Infected cuts and burns with pus on hands and wrists

 The PIC is to make certain that food employees are trained on the subject of the:
 Cause of foodborne illness
 Relationship between the food employee’s job task, personal hygiene, and foodborne illness
 Requirement for reporting
 Specific symptoms, diagnoses, and exposures that must be reported to the PIC

 The PIC should explain to food employees the importance of reporting specific symptoms and any diagnoses or
exposures to foodborne illness. Things to be reported to the PIC include:
 Vomiting, diarrhea, jaundice, sore throat with fever, or any exposed boil or open, infected wounds or cuts on hands
or arms
 An illness diagnosed by a health practitioner that was caused by: Salmonella Typhi; Shigella spp.; Norovirus;
Hepatitis A; or E coli O157:H7 or other Enterohemorrhagic or Shiga toxin producing E. coli
 The PIC is aware that he/she should report employees who have been diagnosed with shigellosis, Norovirus,
Hepatitis A virus, E. coli O157:H7/other Enterohemorrhagic or Shiga toxin-producing E. coli, or the symptom
Jaundice to the health authority

 Exclusion and Restriction policies must adhere to those provided in Chapter .03 of the GA Food Code

Below are some sample questions that you could ask the PIC to begin a discussion with them to
determine their employee health policy requirements:

 What kind of policy do you have in place for handling sick employees?
 Is there a written policy? (Note: a written policy is not required in the food code, but having a
written policy may give an indication of the formality of the policy being discussed.)
 Describe how managers and food employees are made knowledgeable about their duties and
responsibilities under the employee health policy.
 Are food employees asked if they are experiencing certain symptoms or illnesses upon
conditional offer of employment? If so, what symptoms or illnesses are food employees asked
about? Is there a written record of this inquiry?
 What are food employees instructed to do when they are sick?

22
  What conditions or symptoms are reported?
 What may some indicators be of someone who is working while ill?
 When are employees restricted from working with exposed food or food contact surfaces?
When are they excluded from working in the food establishment?
 For employees that are sick and cannot come to work, what policy is in place for allowing them
to return and for notifying the regulatory authority?

For HANDWASHING, you should purposefully observe employees engage in food preparation
procedures and/or the handling of foods, food contact surfaces, etc. during your inspection.
Special attention should be given to the potential for hands as a vehicle of contamination. As a PRIORITY
you should ensure employee hands are washed using the proper procedure and at the appropriate
times during every inspection. You should make every attempt to observe employees using utensils and
gloves during the preparation and service of ready-to-eat foods and ingredients, such as salads and
sandwiches.

Below are some questions you could ask the PIC for determining a facility’s procedures on
HANDWASHING:

 How do employees know when to wash their hands and what method to use?
 What type of system do you have in place to ensure employees wash their hands when you
expect them to do so?
 Who is responsible for checking to see that employees practice good handwashing procedures?
 What action is taken when an employee is observed not washing their hands when you expect
them to do so?
 What type of system do you have in place to ensure that handsinks are continually stocked with
hand soap and paper towels (or hand drying devices)?
 Do you use any techniques or methods to encourage employees to wash their hands?
 Do you maintain any type of documentation that attempts to monitor employees’ handwashing
within the kitchen area?

NO BARE HAND CONTACT WITH READY-TO-EAT FOODS – throughout your inspection, you should
take the time to observe the handling/preparation of ready-to-eat foods in all areas of the
establishment such as the cook line, the vegetable prep area, the bar area, the waiter/waitress area, the
drink preparation area, and any other area where ready-to-eat foods are prepared. A diligent effort on
your part should discover the effective barriers that a facility has in place to prevent bare hand contact
with ready-to-eat foods. Be mindful, food employees can use other suitable utensils such as spatulas,
tongs, ladles, deli paper when handling ready-to-eat foods.

Below are some questions you could ask the PIC for determining a facility’s procedures on NO BARE
HAND CONTACT WITH READY-TO-EAT FOODS;

 Where do you prepare your salads?

 At what times of day do you prepare salads, slice fruits, or prepare cold-cut lunch meat
sandwiches?
 Who is responsible for expediting the bread rolls and salads to the customer? Where does this
process take place?
 What procedures are employees expected to follow when working with ready-to-eat foods?

23
 Can you describe the system you have in place to ensure employees that work with ready-to-eat
foods follow your operational procedures?
 What action would be taken if you observed one of your food employees handling ready-to-eat
foods with their bare hands?
 Do you slice, wash, or prepare any ready-to-eat foods (lemons, onions, tomatoes, lettuce,
parsley, cheese) that will be subsequently added as an ingredient to a food product that will be
cooked?

24
 Highly Susceptible Populations (HSP)

A highly susceptible population (HSP) is defined as persons who are more likely than others in the
general population to experience foodborne illness because they are:

 Immunocompromised,
 Preschool age children, or
 Older adults
 Obtaining food at a facility that provides the following services:

 Custodial care
 Health care
 Assisted living (child care center, adult day care center)
 Kidney dialysis center
 Hospital
 Nursing home
 Nutritional or socialization services such as a senior center

NOTE: Establishments that serve food in highly susceptible populations have additional restrictions and
requirements that are necessary in preventing the spread of infectious pathogens and viruses to their
respective vulnerable group(s) of people.

Raw Egg Tips at HSP facilities

Food safety rules for serving eggs in a HSP facility are more stringent because of the increased risk of
foodborne illness.

 Time as a Public Health Control (TPHC) MAY NOT be used for raw shell eggs
 Consumer advisories CANNOT be used. ALL raw eggs MUST be fully cooked before service
 Raw eggs may be combined (pooled) for use in baked goods such as cake, muffins, or bread.
 EXCEPT for baked foods, NO more than one raw egg may be used in a menu item unless the raw
combined eggs are combined immediately before cooking one consumer’s meal, properly
cooked to at least 145°F for 15 seconds, and served immediately.
 Pasteurized eggs or egg products MUST be used when:
o Preparing foods items that contain partially cooked/uncooked eggs that will not be fully
cooked prior to service such as;
 Eggs served sunny side up, soft poached, or soft scrambled
 Hollandaise sauce
 Eggnog
 Ice cream
 Tiramisu
 Meringue
 Drinks containing eggs (egg fortified drinks, alcoholic drinks)

25
 Highly Susceptible Populations (continued)

You should ALWAYS fully assess the operator through discussion or observations of all 8 elements
included in Chapter .04 of the GA Food Code. You should discuss/verify all 8 elements with the operator
and verify each of the 8 elements listed below:

1. Juices?
o Only pasteurized juices being used?
o Unpackaged juices are not being prepared on-site without a HACCP plan – this includes
squeezing the juice from fresh lemons/oranges/etc. into pasteurized juice products to
enhance their flavor or to add juice pulp.
2. Pasteurized eggs or egg products being substituted for raw eggs?
o Such as mayo, ice cream, eggnog, Caesar salad, hollandaise or béarnaise sauces,
meringue, dressings, mixed alcoholic drinks
3. If the following foods are NOT being offered in ready to eat form?
o Raw animal foods (raw fish such as salmon, raw shellfish, steak tartare, raw egg)
o Partially cooked animal foods (fish such as salmon, various meats, eggs, meringue, and
raw seed sprouts)
4. Food employees are not using bare hands to contact exposed ready to eat foods?
o This includes nurses or nurse aides feeding patients with dexterity problems in the
dining area.
5. Time as a public health control (TPHC) is NOT used for raw eggs (if applicable).
6. If raw eggs are being used and how they are being used and if raw eggs are being used
appropriately as indicated in chapter .04 of the GA Food Code (if applicable).
o NOTE: some HSPs do not use raw eggs and only use pasteurized eggs. If raw eggs are
being used then item numbers 2, 3, 5, and 6 above MUST be verified.
7. If the re-service of foods that are dispensed is allowed (determine which foods and
procedures from the operator).
o NOTE: the re-service of a container of food potentially hazardous food such as milk,
butter, creams, ice cream, etc. cannot be re-served once served to the customer – see
chapter .04 of the GA Food Code.
8. If the HSP establishment serves patients or clients who are under contact precautions in
medical isolation or quarantine, or protective environmental isolation and that foods are NOT
re-served ever.

Below are some other items to assess while conducting inspections at HSP facilities:

You should discuss and verify with the operator if there is an emergency supply of food and water on-
site stored in a different location other than the kitchen.

o Many HSP’s are required to keep a 3 day supply of food and water (typically canned/bottled) for
emergencies and in many instances both have been observed stored in closets, rooms, outdoor
storage buildings that are on the property. You should verify the overall storage practices and
package integrity/condition of the food/water during the inspection.

26
 Highly Susceptible Populations (continued)

You should discuss and verify with the operator if there are “satellite” kitchen/serving/food storage
areas at the facility.

o Many HSP’s often transport foods (on/in mobile carts) to other dining/serving areas at the
facility. The dining/serving areas can either be on different floors, wings, in resident activity
areas, or other sections of the building.

You should also discuss and verify with the operator if there are other coolers/refrigerators on-site –
such as a nurses station, or in closets that are used to store/hold potentially hazardous foods (milk,
butter, ice cream, creams, etc.) during the day or overnight when the kitchen is closed or unstaffed.

o If so, then you would need to assess if the food items are being stored correctly and maintained
at appropriate temperatures

27
Risk Control Plan (RCP)

As part of the standardization process your standard trainer will select and instruct you to develop a RCP
by selecting a critical control point that was determined to be NOT in compliance during the inspection.
The purpose of the RCP exercise is for you to demonstrate a clear understanding of the observation,
process used, associated hazards, critical limits, “Gap Analysis”, and corrective actions that should be
targeted for a RCP.
A RCP is a concisely written management plan developed by the retail or food service operator with
input from you, which describes a management system for controlling specific out-of-control foodborne
illness risk factors. A RCP is intended to be a voluntary strategy that you and the person in charge jointly
develop to promote long-term compliance for specific out-of-control foodborne illness risk factors. For
example, if food is improperly cooled in the establishment, a system of monitoring and record keeping
outlined in a RCP can ensure that new procedures are established to adequately cool the food in the
future. A RCP should require that the basic control systems in the plan be implemented for a designated
period of time (e.g., 60 - 90 days) and allow inspector oversight. The longer the plan is implemented, the
more likely it is that the new controls will become "habits" that continue to be used in the food
establishment after inspector oversight ends.

A RCP should stress simple control measures that can be integrated into the daily routine. It should be
brief, no more than one page for each risk factor, and address the following points in very specific terms:

 What is the risk factor to be controlled?

 How is the risk factor controlled (with “GAP Analysis” in mind)?
 Who is responsible for the control?
 What monitoring and record keeping is required?
 Who is responsible for monitoring and completing records?
 What corrective actions should be taken when deviations are noted?
 How long is the plan to continue?
 How are the results of the RCP communicated back to you?

By implementing a RCP, the foodservice operator will have the opportunity to determine the
appropriate corrective action for the identified problem and design an implementation strategy to best
suit the establishment and operation. Since the RCP is tailored to meet the needs of the food
establishment, the operator takes complete ownership of the plan and is ultimately responsible for its
development and implementation. Your role is to consult with the operator by suggesting ways that the
risk factor(s) might be controlled.
By creating a RCP, the operator realizes that a problem exists in the established food safety
management system and commits to a specific correction plan rather than merely acknowledging a
single violation. Follow up by telephone or in person indicates to the operator that you are interested in
seeing the plan succeed. This also gives you an opportunity to answer any questions and offer feedback
to the operator to make the RCP more useful.

Definition of “Gap Analysis”: An evaluation of the difference between what is expected and what is
observed in a food safety management system.

Example: PHF/TCS food is required to be held at 41ᵒF or lower. During an evaluation of a salad bar, it is
observed that tuna salad is being held at 50ᵒF.

28
Risk Control Plan (continued)

A “Gap Analysis” determines why there is a difference between what is expected (PHF/TCS food held at
41ᵒF or lower) versus what is actually observed (PHF/TCS food held at 50ᵒF). The “Gap Analysis” could
consist of asking questions and/or making observations about preparation of that food product and the
equipment used. Additional temperature measurements of other food products on the salad bar may
yield additional info about why there is a “Gap” in the system.

USING “GAP ANALYSIS” TO DETERMINE AN APPROPRIATE LONG-TERM INTERVENTION STRATEGY

The results of the “Gap Analysis” may indicate that new (or existing) procedures, training, and/or
monitoring need to be implemented (or modified). It is important to develop an intervention strategy
that meets the objectives (i.e. fills the “Gap”) in the food safety management system, based on the
outcome of the “Gap Analysis”. If not, the intervention strategy might focus on the wrong thing. For
example, if the problem is with the food preparation procedure, then an intervention strategy that
requires monitoring temperatures at the salad bar would not fully address the problem. It would
continue until the procedure is modified, the employees are trained to use it, and monitoring is
conducted on the modified procedure to ensure its effectiveness.

A more relatable example of “GAP Analysis” is to think about a baby crying in its crib. Why would the
baby be crying?

Some possible reasons (“Gaps”) of why the baby would be crying could be;

o The baby may need to be fed (it may be hungry)

o The baby may need to have its diaper changed
o The baby may have a fever
o The baby may be cutting teeth and be in some pain

As you can see there are several things to consider (“Gaps”) on why the baby is crying and each “Gap” as
to why the baby is crying would have its own respective control measure to solve the problem of caring
for the baby’s needs. For instance, the baby’s last meal could have been 5 hours ago, so the “Gap”
would be to feed the baby - give it a warm bottle of milk – that may solve the problem. Or, if the baby is
cutting teeth, then maybe some children’s Orajel for teething pain relief can be given to relieve the pain
the baby may be experiencing. Furthermore, the reason(s) the baby would be crying could be a
combination of all examples listed above; therefore, all “Gaps” listed above would have to be
considered in keeping the baby from crying.

29
Process Flow Charts

Another aspect of the standardization process is for you to complete 3 process flow charts. Your standard trainer will
select a total of three food preparation processes for you to describe on a flow chart. The food preparation processes
are to include:

 Process 1 – “No Cook Step” food item

 Process 2 – “Same Day Service” food item
 Process 3 – “Complex Food Preparation” food item

Your development of each flow chart will use information you gained through actual observations of operational steps
during an inspection. Information gained through discussions with the Person In Charge (PIC) and/or food employees
should be used to substitute for a lack of actual observations, i.e. when operational steps in the process do not occur
during the inspection.

All Process Flow Charts must have the following sections included: recipe, hazards, prerequisite programs, and the flow
diagram of the food based on the recipe (refer to an example of a flow chart on the next page).

There must be a recipe for each process and recipes must completely reflect the flow of the process that it represents.
You will have to communicate with the PIC and document the operational steps (food flow), the ingredients used and
steps in preparation, and the manner in which ingredients are received (fresh, frozen, dry goods, etc.). For example, if
whole muscle, intact beef steak is used, then you must document the method that was used to verify the product was
whole muscle intact beef in the prerequisite programs (information from box or letter from supplier).

NOTE: ingredients in recipes used for flow charts (process 1, 2, and 3) must include potentially hazardous foods
(time/temperature control for safety foods).

** On the next page there is an example flow chart and how they should be formatted when developing them.

30
Process Flow Chart - example
Hazards
• List only the most common
biological, viral, chemical,
and physical hazards
associated for each
ingredient and/or operational
steps.
• List the Genus + Species
name for biological hazards
or the disease caused from
the hazard (for example
Salmonella Enteritidis or
Salmonellosis may be
identified with raw shell
eggs).
• Any hazard identified must
have a corresponding CCP
and vice versa any CCP would
have a hazard that is being
controlled listed.
Cool/Hold
Prerequisite Programs
• List the procedures that
address the basic operational
and sanitation conditions
(Standard Operating
Procedures) to control
hazards listed above for each
ingredient and operational
step that are not covered by
a CCP such as proper date
marking for Listeria
monocytogenes or no bare
hand contact with ready to
eat foods, employee policy,
and effective hand washing
would control fecal oral route
contamination during
preparation steps.
Receive Recipe & Preparation Description
• List ALL of the ingredients and
steps to prepare the menu item
(note whether the items are
received fresh/frozen or
Store raw/pre-cooked, etc. This will be
key in determining process flow
steps and critical control points.
For example, raw chicken would
need cooking step (CCP);
whereas ready to eat chicken
Prep would possibly require reheating
either for immediate service or
for hot holding. Also, pre-
washed bagged lettuce would
not need a prerequisite step for
Cook CCP washing whereas whole, raw
CL: 155°F for 15 sec. lettuce would need to be
washed in a dedicated sink to
or prevent cross-contamination.
{ Cool CCP
CL: 135°F – 70°F w/in 2 hrs., 135°F -41°F w/in 6 hrs.
Hold *CCP
CL: 41°F or below
* Cold Hold CCP followed cooling
Reheat Note: Reheat was for immediate service.
Note: Operational steps are not the same for each flow
chart, even within the same process type; they will vary
Serve with each recipe and require critical thinking skills in
order for you to assign CCPs and prerequisite programs.
31
 Verification of a HACCP Plan

During standardization, at least one food establishment will be inspected/visited that has a mandatory or
voluntary HACCP Plan. You will have to demonstrate to the standard trainer your abilities to verify that the
HACCP Plan is properly implemented by reviewing the food establishment’s monitoring procedures and record
keeping, verifying that the critical limits are met, and substantiating that corrective actions were taken when the
critical limits were not met. The standard trainer will select at least one critical limit for you to verify.

Your task will be to review the records for the selected critical control point(s) for three specific 24 hour periods,
which shall include records for the current day, if possible, and two additional days selected at random. Based
on this review, you will have to make the following determinations regarding monitoring, record keeping, and
the performance of corrective action for a total of nine HACCP Plan record answers:

 Required monitoring was performed on the three selected dates;

 Accurate and consistent records appear for the three selected dates; and
 Corrective action was documented in accordance with the plan when critical limits were not met on each of
the three selected dates.

You and the standard trainer will use HACCP verification forms for this exercise. The verification form for the
standard trainer is distinctly different from yours. The verification forms can be distinguished by the title of the
form. To demonstrate proficiency in the HACCP Verification exercise, you and the standard trainer must have ≤ 2
disagreements between them. You and the standard trainer must circle “Yes” or “No” on the individual HACCP
Verification forms (N/A for not applicable is not acceptable for this exercise). If the establishment's HACCP plan
identifies what is to be done in regards to corrective actions and the log has a provision for corrective actions to
be recorded, it is suitable to use and should be marked "Yes" if all temperatures logged are within the critical
limits or if not within the critical limits but the appropriate corrective action was taken. A "No" should be
marked if the temperature logged is not within the critical limits and an appropriate critical limit was not taken.

At times the standard trainer may have you explain sections of the HACCP plan to him/her with regards to
Critical Control Points (CCPs) and Critical Limits (CLs).

For instance, if the facility’s HACCP plan states that all raw poultry will be cooked to 180°F prior to service and all
final cooking temperatures of poultry will be documented on a log sheet. Then you should be able to explain
that the HACCP plan states that all raw poultry products should be cooked to 180°F which is a much greater
temperature than 165°F for 15 seconds that the GA Food Code requires. You should be able to explain necessary
CCPs/CLs of the HACCP plan to the Standard Trainer when asked to do so. Furthermore, the standard trainer will
assess you to determine if you understand that all HACCP records should be maintained & available to indicate
that (poultry is in fact being cooked to at least 180°F for 15 seconds) the required monitoring is being completed
as the HACCP plan states.

Applying the 7 Principles of HACCP

Your standard trainer will also assess your knowledge of HACCP by having you apply the 7 Principles of HACCP
during a standardization inspection. You do not need to memorize the 7 principles – you will be responsible for
demonstrating to the standard trainer on how would apply each principle to a menu item that the standard
trainer selects. The standard trainer may ask several questions to determine your understanding of HACCP as it
relates to the food item he/she selected.

** On the next page there is an overview on how the process is conducted.

32
 ASSESSING THE 7 PRINCIPLES OF HACCP

Roles Process
7 Principles
ST selects a menu item

Process Process Process Principle 1:

1 2 3 Conduct a Hazard Analysis

ST explains to the Candidate that they are going to Principle 2: Determine

S
assess their knowledge and application of the 7 Critical Control Points (CCP)
T
Principles of HACCP using the selected menu item
Standard
Trainer Principle 3:
Establish Critical Limits (CL)

Principle 4:
ST should ask the Candidate to explain Principle 1 in his/her own
Establish Critical Control Point
words
Monitoring Requirements
ST should ask the Candidate to explain Principle 2 in his/her own
words
C
Principle 5:
ST should ask the Candidate to state Principle 3 in his/her own Establish Corrective Actions
words
Candidate ST should ask the Candidate to state Principle 4 in his/her own Principle 6:
words
Establish Record Keeping
ST should ask the Candidate to state Principle 5 in his/her own Procedures
words

ST should ask the Candidate to state Principle 6 in his/her own Principle 7: Verification of the
words
HACCP plan
ST should ask the Candidate to state Principle 7 in his/her own
words

33
 APPROVED SOURCE

Foods being served should be from approved sources and protected during the production process - such as packaging,
shipping, harvesting, slaughtering, growing, watering, freezing, washing, feeding, and irrigating.

It is essential that foods received in food service establishments are handled/processed under sanitary conditions
throughout the production process and distributed under those same conditions.

Food at all stages of production is susceptible to contamination, so verifying its source is imperative.

The sources of foods are important because pathogenic microorganisms may be present in the breeding stock of
animals, feed, environment, water, soil and fertilizers.

Food sources can be verified in a variety of ways during inspections. Below are some ways sources can be evaluated;

 Labeling – product packaging will contain identifying marks of inspections.

 Invoices/Receipts – will provide a way to trace back a foods source
 Letters- such a parasite destruction letters to ensure fish products have been frozen to the appropriate
temperatures
 Packaging labeling – will provide an immediate way to verify the source of food items from commercial sources

** On the next page you will see common marks of inspection seen on food items

34
Below are various pictures of inspection stamps observed in food service establishments:
This is the Meat legend/stamp that
will be applied to beef, pork, goat,
sheep, etc.
This is the Voluntary inspection
legend/stamp that will be applied
to animal products done under a
voluntary inspection program
such as buffalo, bison, reindeer,
etc.
This is the inspection stamp/legend
that is applied from the country
that exported the meat, poultry, or
eggs to the USA
This is the GA inspection
stamp/legend that allows meat
product to move freely through the
state of GA.
This is the Import legend/stamp This is the Egg legend/stamp that is
that will be applied at a Food Safety for USDA inspected processed egg
& Inspection Service (FSIS) import products.
locations to any species product
authorized and allowed to enter the
US for commerce
This is the Poultry legend/stamp
that will be applied to chicken,
turkey, etc. products
35
You should be mindful that meats/food items in containers that do not bear inspection stamps should be investigated
further to determine approved source. For example, if you observe a stainless steel container of raw steaks, then you
should ask the operator some of the below questions:

 Do you have purchase specifications/receipts for the raw steaks for me to review?
 How frequently do you have raw steaks delivered to your facility?
 Who delivers the raw steaks?

Approved Source - FISH

There are 6 ways fish are considered from approved sources;

1. Fish from a “Licensed Commercial Fisherman” as regulated through Georgia Department of Natural
Resources (GA DNR) or other approved commercial sources;
2. Live fish from an “Aqua culturist (domestic fish farmer)” registered with and regulated by the Georgia
Department of Natural Resources Law Enforcement Section or other approved aquaculturists;
3. Live fish from a “Wholesale Fish Dealer” as permitted through the Georgia Department of Natural
Resources or other permitted fish dealers; and
4. Processed fish obtained from “Processing Plants and Distributors” as permitted through the Georgia
Department of Agriculture or other state agriculture offices.
5. Fish, other than molluscan shellfish, that are intended for consumption in their raw form must be
purchased from a supplier that meets applicable law and that freezes the fish to destroy pathogens as per
Rule -.04 of the GA Food Code
6. Fish, other than molluscan shellfish, that is properly frozen on the premises of the food service
establishment as per Rule -.04 of the GA Food Code

Approved Source – VEGETABLES

Unprocessed produce is unregulated, there is no approval process. However, there have been many foodborne illness
outbreaks involving unprocessed produce which creates a cause for concern whenever produce is brought into a food
establishment. The facility should be encouraged to follow the guidance found at;

http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ProducePlantProducts/ucm064574.htm

The link above discusses the importance of minimizing microbial contamination of produce in the field through Good
Agricultural Practices. Once the produce is harvested and brought into the restaurant it should be washed and handled
in a manner to prevent contamination according to the provisions in the GA Food Service Code.

Approved Source – WILD MUSHROOMS

Wild harvested mushrooms are extremely poisonous and it can be difficult for you to distinguish them from safe/edible
mushrooms. You should always be inquisitive of the PIC on determining where they obtain their mushrooms during your
inspection.

Determining the source of wild mushrooms can be very difficult. With the change 2013 FDA Food Code, you will have
some flexibility to apply rules/policies of minimum standards in ensuring wild harvested mushrooms are from an
approved source. There is guidance material titled “Draft Model Guidance for Wild Harvested Mushrooms” posted at
the following link: www.foodprotect.org.

36
Approved Source – EGGS

Eggs are often a contributing factor in foodborne salmonellosis outbreaks because:

 Intact eggs may be contaminated internally with Salmonella Enteritidis
 Multiple eggs are often combined (“pooled”), allowing one contaminated egg to contaminate the mixture
 The cooking of eggs such as scrambling, frying, poaching, and making omelets does not always fully cook the
eggs and final cooking temperature assessment can be difficult.

Eggs shall be received clean and sound and may not exceed the restricted egg tolerances for U.S. Consumer GRADE B as
specified in the GA Food Code.

If you observe eggs stored in a walkin cooler without identifiable information (see the picture below) or stored in a
flat without identifiable inspection stamps (see above inspection stamps) then you should inquire with the PIC of
where the eggs were received from – ask for invoices/receipts, etc.

Approved Source - EGG PRODUCTS AND MILK PRODUCTS

Liquid egg, fluid milk, and milk products are especially good growth media for many types of bacteria and MUST be
pasteurized.

 Fluid and dry milk products shall be:

o Obtained pasteurized (you should review product specification sheets or product labels to determine
pasteurization), and
o Comply with GRADE A standards as specified in law
o Frozen milk products such as ice cream shall be obtained pasteurized as specified in 21 CFR 135 Frozen
Desserts

37
Approved Source – SHUCKED SHELLFISH

Raw shucked shellfish shall be obtained in nonreturnable packages which bear a label that identifies the:

 Name, address, and certification number of the shucker-packer or re-packer of the

molluscan shellfish (see the pictures below); and
 The "sell by" date for packages with a capacity of less than one-half gallon (1.89 L)
or the date shucked for packages with a capacity of one-half gallon (1.89 L) or more.

NOTE: a package of shucked shellfish of 1.89L or more is NOT required to have a “sell by” or “best if used by” date on
the packaging.

NOTE: A package of raw shucked shellfish that does not bear a label or which bears a label which does not contain all
the information as specified shall be subject to a hold order, as allowed by law, or seizure and destruction in accordance
with 21 CFR Subpart D - Specific Administrative Decisions Regarding Interstate Shipments, Section 1240.60(d) Molluscan
Shellfish.

Dealer name & address,

Dealer certification #,

Nt. weight > 64 ounces,

Shuck date

NOTE: You MUST verify that shucked shellfish are from an approved source and listed on the Interstate Certified
Shellfish Shippers List (ICSSL) during your inspection. You should have access to the ICSSL during your inspection. The
ICSSL can be found at the following link below:
http://www.fda.gov/food/guidanceregulation/federalstatefoodprograms/ucm2006753.htm

38
 Approved Source – SHELLFISH VERIFICATION

You should discuss with the operator & review menus, invoices, and products to determine if shellfish are being served
(fresh and frozen shellfish have to be verified) at any time during the year.

IMPORTANT : you should always have immediate access to the most current Interstate Certified Shellfish Shippers
List (ICSSL). It can be found at the link below:

http://www.fda.gov/food/guidanceregulation/federalstatefoodprograms/ucm2006753.htm

During your inspection you should review and notate information from shellfish tags/containers/labels within all
coolers and that are held on file in the establishment for 90 days.

NOTE: there could be multiple tags/containers/labels from shellfish to review and verify using the ICSSL.

NOTE: there may be 2 companies with 2 different certification numbers on the tag(s) that you must verify
(such as a shellfish dealer certification number and the original shellfish shippers certification number). Please
be mindful of all certification numbers on all tags – all need to be verified by you.

You should verify if shellfish tags/containers/labels at the establishment are kept on file in chronological order for at
least 90 days from when the last shellfish was served.

You should also verify that the company that delivered the shellfish (Sysco, PFG, etc.) are listed on the ICSSL as well
during your inspection.

Below is important information for you to assess/verify from shellfish tags by using the ICSSL;

The dealer name and address is This is the shellstock

the distributor of the Shellstock dealer certification

The certification
number of the
original shipper is
listed here (if
applicable)

The harvest date will

39 be notated here
Approved Source – PARASITE DESTRUCTION VERIFICATION

Did you determine/notate which fish are being offered raw/undercooked?

o NOTE: some fish may only be served/offered during certain times of the year – think seasonally and think
species of fish; for example Thunnus albacores, (Yellowfin tuna).
o NOTE: there could be an extensive amount of fish that is being offered raw/undercooked (salmon is often
offered raw/undercooked in many establishments – customers often request “medium, medium rare”, etc.).

Did you determine/verify through discussion, record review, or observation each and every supplier that provides fish
to the restaurant?

• NOTE: a facility may use multiple suppliers for their fish products because of prices, specific cutlet sizes, fresh,
or frozen, etc. (invoices and records for all suppliers will have to be determined/reviewed for compliance).

Did you determine/verify through discussion, invoice/record review, or observation which fish products are received
fresh or frozen and are offered raw/undercooked?

• More than likely, you will have to notate how each fish product is received (fresh or frozen) so that you can
evaluate for proper parasite destruction?

Did you determine which fish products are received fresh (unfrozen) and discuss with the operator if that particular
fish is being served fully cooked or raw/undercooked?

Did you determine through discussion, invoice/record review, or observation which fish products;

o were frozen for parasite destruction,

o which fish products are exempt from parasite destruction such as species of Tuna see chapter .04 of
the GA Food Code [if applicable],
o which fish products are frozen on-site for parasite destruction [if applicable], and/or
o which fish products are aqua-cultured fish (such as salmon) [if applicable]

You will have to verify the parasite destruction method that was used for each fish product being offered
raw/undercooked for each supplier that provides fish to the restaurant.

Did you verify that all parasite destruction records are up-to-date/current for each supplier of fish?

o NOTE: if fish are frozen on-site at the restaurant for parasite destruction or are obtained from an aquaculturist,
then records shall be kept on file for 90 calendar days beyond the time of service or sale of the fish [see
chapter.04 of the GA Food Code].
o NOTE: If a restaurant purchases its fish frozen from a supplier, a letter must be provided indicating that each
fish product supplied has been frozen for parasite destruction to the time/temperature parameters in Chapter
.04 of the GA Food Code. The letter should be recently issued- meaning it should have been issued within the
last 90 days of receipt of the fish products and the letter should be maintained current by the establishment.

**See an example of a parasite destruction letter on the next page

40
Approved Source – SAMPLE PARASITE DESTRUCTION LETTER

111 Ocean Drive

Coastal, GA 30398
1.877.233.3464 Name and address
of the fish supplier

Date

October 29, 2013

Fishy Business Restaurant Name of the restaurant

112 Pleasantly Fishy Blvd. and address
Atlanta, GA 30303

Dear Owner;

This letter is to inform you that the mackerel (3 lb. filets – product #312M) and the red snapper (1.5 lb. cutlets –
product # 021RS) have been frozen and stored at a temperature of -20°C (-4°F) or below for a minimum of 168 hours
(7days) in a freezer prior to being shipped to your restaurant.

If you should have any questions, please feel free to contact me at 1.877.233.3464 ext. 521.

Sincerely,
Phil Phisherman • A list of all fish that have been
CEO - Operations frozen for parasite destruction &
have been provided to the
restaurant
Contact information for
• The exact temperature in which the
the person in charge of
fish have been frozen to
the parasite destruction
• The length of time in which the fish
at the supplier
have been frozen at the
temperature specified in the letter

41
 ** ALWAYS assess the final
Cooking Temperatures
cooking temperature of food
items off of the heat source –
Do NOT take the final cooking
 Are the cooking procedures product specific (roasts, hamburgers, etc.)? temperature of a burger while
o Employee knowledge of cooking time & temperatures? the burger is still on the grill.

 Are cooking procedures based on equipment calibrations (temperature setting and time setting)?

 Is a slow cook process or non-continuous cook process used for any foods (roasts, wings)?

o A slow cook process is similar to ribs being smoked in a smoker or a roast being slow cooked in a crock
pot/oven – the cooking process is usually done at low temperatures for longer periods of time.
You should be knowledgeable and able to explain adequate cooking of roasts by using the oven
parameters and cooking temperature charts in chapter .04 of the GA Food Code.

For example;

 You should be able to show a level of understanding on how the two charts should be used. For
instance, if a facility is cooking a 9 pound beef roast in a “Still Dry” oven, then the internal oven
temperature based on roast weight should be 350°F and the roast should be cooked at minimum
to heat all parts of the food to 130°F, and be maintained at 130°F for 112 minutes to be considered
fully cooked and being served as fully cooked.

o A non-continuous cooking process in which the initial heating of a food item such as chicken wings is
intentionally halted so that they may be cooled and held for complete cooking at a later time prior to sale
or service. Currently a non-continuous cooking process is NOT allowed by the GA Food Code.

 Are raw animal foods cooked to customer requests (rare, medium, medium-well)?
o If so, which food items? Are consumer advisory’s (reminder and disclosures in place) posted on
menus/menu boards?

 How are cooking temperatures monitored at the facility – you should determine this during your inspection?
o What types of equipment/procedures are used to measure final cooking temperatures?
 Calibrated routinely?

 What actions do employees take when food does not reach the proper cooking temperature?

Below are some tips to consider when assessing cooking procedures & the PIC on their cooking processes:

 Are specific procedures in place for cooking foods?

 Are the cooking procedures product-specific (roasts, hamburgers, etc.)?
 Are any cooking procedures based on equipment temperature for a set amount of time?
 Is a slow cook process used for any of the food products (like roasts)?
 Does the facility receive steaks as whole muscle intact beef? Is there labeling to document this?
 Does the staff know the correct cooking temperatures?

42
  Are raw animal foods cooked to customer order (i.e. rare, medium-rare, medium, or well-done)? If yes, what
food items?
 If raw animal foods are intentionally undercooked or served raw, does the establishment have a proper
consumer advisory?
 Are there any meats that are partially cooked and cooled in preparation for large volume preparation later?
 How are cooking temperatures monitored?
 What type of equipment is used to measure the final internal product cooking temperatures?
 What actions do employees take when food does not reach the proper temperature?
 Are cooking logs maintained (although not required per the food code)?

NOTE: PAY CLOSE ATTENTION TO FROZEN BREADED FOOD ITEMS SUCH AS FROZEN BREADED CHICKEN TENDERS –
MANY TIMES THESE FOOD ITEMS APPEAR TO BE FULLY COOKED; HOWEVER, AFTER REVIEWING THE BOXES THEY WERE
RECEIVED IN, IT HAS BEEN OBSERVED THAT CHICKEN TENDERS ARE IN FACT RAW/UNCOOKED!

Reheating for Hot Holding Temperatures

The potential for growth of pathogenic bacteria is greater in reheated cooked foods than in raw foods. This is because
spoilage bacteria, which inhibit the growth of pathogens by competition on raw product, are killed during cooking.
Subsequent recontamination will allow pathogens to grow without competition if temperature abuse occurs.
Proper reheating provides a major degree of assurance that pathogens will be eliminated. It is especially effective in
reducing the numbers of Clostridium perfringens that may grow in meat, poultry, or gravy if these products were
improperly cooled. Vegetative cells of C. perfringens can cause foodborne illness when they grow to high numbers.
Highly resistant C. perfringens spores will survive cooking and hot holding. If food is abused by being held at improper
holding temperatures or improperly cooled, spores can germinate to become rapidly multiplying vegetative cells.
Although proper reheating will kill most organisms of concern, some toxins such as that produced by Staphylococcus
aureus, cannot be inactivated through reheating.
Below are some things to consider when assessing food items that are reheated for hot holding:

 What happens to leftover foods? Do they typically have leftover food items?
 How does the facility reheat foods for hot holding (commercially processed or previously cooked)
 How are food items reheated (range top, oven, steamer, microwave, steam table, kettle)?
 What are their procedures for monitoring re-heating (time and temperatures)?
 What type of instrument is used to verify re-heating temperatures (calibration)?

NOTE: it is important to determine if food items are going to be REHEATED for HOT HOLDING. If a left -over food item
such as a made in house fully cooked lasagna is ordered by a customer and the PIC explains to you that their procedure
is to place a portion of the fully cooked lasagna into the microwave for 3 minutes and once reheated, place the lasagna
onto a plate and immediately serve it to the customer – then there would NOT be a minimum REHEATING temperature
requirement because it is being served immediately to the customer.

 Contrastly, if the PIC explained to you that their procedure is to REHEAT the lasagna in the oven and
then place it onto the steam table to HOT HOLD until ordered, then you MUST verify their REHEATING
for HOT HOLDING procedures – to ensure the leftover in house fully cooked lasagna is REHEATED to
165°F for 15 seconds and the REHEATING process does not exceed 2 hours.

NOTE: it is important to determine if food items being REHEATED for HOT HOLDING have been fully cooked and
commercially processed and packaged in a food processing plant – because those food items shall be REHEATED to a
temperature of 135°F when being heated for HOT HOLDING.
43
NOTE: Please be mindful if a facility is REHEATING foods for HOT HOLDING in a microwave, then the food shall be
REHEATED so that ALL parts of the food reach a temperature of at least 165°F and the food is rotated or stirred,
covered, and allowed to stand covered for 2 minutes after REHEATING.

Consumer Advisory

During your inspection of facilities you should determine if food items are offered raw/undercooked by discussion
with the operator and menu(s) review?

You will need to thoroughly discuss with the operator food items that may be served raw/undercooked at the
restaurant – this includes seasonal food items, promotional items, special menu items, etc.

 You should notate the specific menu items that are offered raw/undercooked (fish, burgers, steak, eggs) – the
foods items can vary:
For example, the restaurant uses raw shell eggs in the preparation of soft boiled eggs,
scrambled eggs, sunny side up eggs, and French toast in many menu items, but also uses the
same raw eggs to prepare eggnog during the holidays.

 NOTE: the eggs may or may not be fully cooked in how they are prepared – you would need to
discuss/review menu(s)/take final cooking temperature measurements to determine if a
consumer advisory would be needed.
 NOTE: the eggs used in eggnog could be raw eggs and not be heat treated at all.

For example, salmon or other fish products are often offered on menus cooked to the
customers requested doneness (rare, medium rare, medium, etc.) – so you would need to
discuss/review menu(s)/take final cooking temperature measurements to determine if a
consumer advisory would be needed.

 NOTE: if salmon or any other fish is offered raw/partially cooked/undercooked at the

restaurant, then appropriate parasite destruction will need to be verified as well.

For example, the restaurant uses rib-eye (non-whole muscle intact beef) steak product for a
vegetable soup menu item by chopping the steak into chunks after fully cooking it to 155°F for
15 seconds, but the restaurant also offers the same rib-eye steak product as a separate 8oz
rib-eye steak dish on the menu that can be cooked to the customers requested doneness
(rare, medium, medium rare, etc.).

 NOTE: steaks being used at restaurants can either be whole muscle intact beef steaks or non-
whole muscle intact beef steaks.
 NOTE: you should determine which steaks are being used/served at a restaurant and
knowledgeable on the final cooking temperatures of both types of steak. It is imperative for
you to discuss with the operator the specific menu items that are offered raw/undercooked at
the restaurant
44
 Consumer Advisory (continued)

Potential ways to phrase questions to the PIC on determining if foods are offered raw/undercooked:

• “When a customer orders a steak or fish, can he/she ask you to cook it medium or medium well or slightly undercook
it for them?"
• “If a customer orders eggs, can a customer ask you to cook their eggs a certain way for them, such as scrambled, over
easy, sunny side up, etc.?"

FYI: IT IS IMPORTANT FOR YOU TO KNOW THAT THE TERMS “RARE, MEDIUM RARE, MEDIUM, MEDIUM WELL, AND WELL”
ARE CULINARY TERMS AND DIFFER FROM RESTAURANT TO RESTAURANT. MORE IMPORTANTLY FINAL INTERNAL COOKING
TEMPERATURES OF ANIMAL FOODS DIFFER BASED ON THE TERMS ABOVE. YOU SHOULD ALWAYS DISCUSS/VERIFY
PROCEDURES/POLICIES OF FINAL COOKING TEMPERATURES WITH OPERATORS, AND/OR TAKE FINAL COOKING
TEMPERATURE MEASUREMENTS TO DETERMINE IF A CONSUMER ADVISORY WOULD BE NEEDED.

You MUST verify the consumer advisory (reminder & disclosures) on all applicable menu’s/points of selection or service:

• Table menus (breakfast, lunch, dinner, special, weekend, etc.)

• “To-Go” menus (breakfast, lunch, dinner, special, weekend, etc.)
• Seasonal menus/promotional menus (breakfast, lunch, dinner, special, weekend, etc.)
• Menu boards/displays (breakfast, lunch, dinner, special, weekend, etc.)
• Drive-Thru menus (breakfast, lunch, dinner, special, weekend, etc.)
• Menu ordering cards (such as those offered at sushi bars or raw oyster bars)
• Menus (room service) in hotel rooms
• On or at self-service bars (buffet) that offer raw/undercooked foods

Example of proper disclosures and reminder statement is below:

*Hamburgers all the way………………..$3.50

Chicken Fingers………………………………. $3.00
**Spicy Tuna Roll……………………………. $9.00

* ADVISORY: HAMBURGERS CAN BE COOKED TO CUSTOMERS REQUEST.

**CONTAINS RAW FISH.

CONSUMING RAW OR UNDERCOOKED MEATS, POULTRY, SEAFOOD, SHELLFISH, OR EGGS MAY INCREASE YOUR
RISK OF FOODBORNE ILLNESS, ESPECIALLY IF YOU HAVE CERTAIN MEDICAL CONDITIONS.

All of these are the necessary This statement is a necessary

Disclosures needed Reminder statement needed (it
should be in all CAPS & be no
smaller than #8 font)

45
 Cold Holding

 How does the operator monitor the internal food temperatures of TCS foods the refrigeration units – food temps?
 How does the operator monitor ambient air temps of refrigerators?
 How does the operator know if their temperature measuring device is calibrated?
 Does the establishment cold hold TCS foods using an alternative method (ice baths)?
If so, who replenishes the ice and how often is this done?

NOTE: Be mindful that temperatures of ALL TCS food items held cold using an ice bath SHOULD be taken during your
inspection. For instance, if a facility is holding tuna salad, egg salad, and sliced tomatoes in 3 separate containers on 3
separate ice baths, then you should take the temperature of all 3 food items to ensure they are being cold held at 41°F or less
– each food item on its respective ice bath has to be evaluated independently.

Things to consider when you assess COLD HOLDING;

 Are coolers overburdened with food products (too much food in a cooler thus not allowing cold air to
circulate well)?
 Are prep coolers or reach-in coolers too close to a wall?
 Are air vents blocked inside of refrigeration units (prep coolers)?
 Are there adequate refrigeration units available?
 Are containers of foods over-stocked (think about prep-coolers)?
 Does the facility do catering (how are foods transported to maintain 41°F)?
 Does the facility attempt to cold hold TCS foods in clam shells?
 Be sure to assess ALL coolers – there may be coolers outside of the kitchen area (bar area, outside,
transporting carts, etc.)
 Cold holding temperature control does not stop once food items leave the kitchen. How does the facility
ensure cold holding temperatures are maintained for products sent to satellite schools, patient rooms, or
other food distribution points that may be off-site?
 Who is responsible for monitoring the temperature once it leaves the kitchen areas? Is it the kitchen
foodservice personnel or is it the nursing staff in hospital facilities? Are satellite school facilities
responsible for checking temperatures when the food arrives? How is this done and reported back to
the main commissary kitchen?

Below are some questions that you could ask the PIC in assessing COLD HOLDING at an establishment:

 How do you monitor the refrigeration units to ensure they are maintaining proper temperature?
 Are there any refrigeration/cold food storage units located outside of the kitchen area (salad bars, food
transportation units, etc.)?
 Do you use methods, other than storing under refrigeration, to maintain foods cold (e.g. storage in ice)?
 What kind of monitoring procedures do you implement for ensuring food is at the proper cold holding
temperature?
 What type of equipment is used to check the food product temperatures? How often is this done? How do you
know your temperature measuring devices are accurate?
 Do you keep temperature logs? Do you record the temperature of the refrigeration units, product temperatures,
or both? (not required per the food code)
 What corrective actions are taken when food is not cold held at 41°F?

46
 Hot Holding

 How are cooked foods held until service (in an oven, on a stove-top, steam table, hot box, kettles)?
 How does the operator monitor hot held foods?
 How does the operator know if their temperature measuring device is calibrated?
 Are there hot food storage units located outside of the kitchen area (hot food bars such as those at a buffet, food
transportation units, etc.)?

Things to consider when you assess HOT HOLDING;

 Are hot holding units overburdened with food products (too much food in a hot hold box)?
 Think about cooked chicken wings being hot held at a buffet bar stacked high in the container. Do you think
the wings on top will maintain 135°F on the buffet table?
 Are steam tables pre-heated or set at appropriate setting?
 How many heating elements are within the steam table? Some units have multiple heating elements and
multiple thermostats.
 Is there enough water in the well of the steam table to ensure the water is touching the container of food?
 Are there adequate hot holding units available for foods?
 Are hot-hold units over-stocked (too much food in a hot box thus not allowing heat to circulate well)?
 Does the facility do catering (how are foods transported to maintain 135°F)?
 Does the facility attempt to hot hold TCS foods in clam shells?
 Does the facility attempt to hot hold TCS foods by using “sternos”?
 Are heat lamps too far from the food?
 Ask about food items on the stove top or check the interior of an oven – many operators hold food items hot on
stove tops and inside of the oven.

Below are some questions that you could ask the PIC in assessing HOT HOLDING at an establishment:

 How are cooked foods held until service?

 How is the temperature of hot foods controlled? Steam table, stove/oven, hot box?
 Are there any hot food storage units located outside of the kitchen area (hot food bars, food transportation units,
etc.)?
 What kind of monitoring procedures do they implement for ensuring food is at the proper hot holding temperature?
 What type of equipment is used to check the food product temperatures? How often is this done? How do they know
their temperature measuring devices are accurate?
 Do they keep temperature logs? Do they record the temperature of the hot holding units, product temperatures, or
both?
 What corrective actions are taken when food is not held at 135°F?

47
 Cooling Time & Temperature

COOLING TIME/TEMPERATURE CONTROL FOR SAFETY (TCS) FOODS

Process / Product Critical Limit

► Cooling of properly cooked  Within 2 hours from 135°F to 70°F AND

TCS foods  Within a total of 6 hours from 135°F to 41°F or less

► Cooling of TCS foods from  Cooled to 41°F within 4 hours

ambient temperature
ingredients
► Cooling of TCS foods
received in compliance with
laws that allow temperatures >
41°F during shipment
 Cooled to 41°F within 4 hours
 Exception – raw shell eggs must immediately be placed
in refrigeration maintaining an air temperature of 45°F
or less

NOTE: It is VITAL to take temperatures of foods being cooled at the beginning of the inspection and again towards the end of
the inspection. An evaluation of the two temperatures in conjunction with the elapsed time between the two readings will
give an indication of the cooling rate. A single temperature check of cooling foods DOES NOT always provide enough
information to properly assess a facility’s cooling procedure(s).

A thorough assessment of cooling requires an evaluation of all the information gained from food employees and
management, in combination with temperature measurements taken.

Below are some questions you could ask the PIC when assessing COOLING TIME & TEMPERATURE

 What TCS foods are cooked then cooled in your establishment?

 What TCS foods are cooled from ambient air temperature (sliced tomatoes, opened can of tuna, opened can of green
beans, sliced melons)?
 What TCS foods are taken from the refrigerator, sliced and then placed back into the cooler to cool (deli ham, deli
turkey, deli salami)?
 Can you explain the cooling time & temperature requirements followed at your facility?
 What do you do with leftovers – particularly at the end of a business day?
 What cooling methods are used for TCS foods (think ice baths, chill sticks, freezers, blast chillers, coolers)?
 How are cooling time & temperatures monitored (think validation)?
o How do employees ensure that cooling time frames are achieved?
o Are different employee’s tasked in ensuring cooling TCS foods?
o Do employees replenish the ice once melted in ice bath slurries?
 Determine if cooling of TCS foods/procedures take place during non-traditional business hours (12 am to 4 am)?

Below are some TIPS when assessing COOLING TIME & TEMPERTURE during inspections:

 Vary the time of day the inspection is conducted to ensure cooling is observed. Early morning inspections allow an
opportunity to verify that leftovers from the night before were cooled properly or cooled using a proper cooling
method. Alternatively, afternoon inspections may allow you to verify cooling of products that may have been
prepared that morning or are still in the process of cooling - become familiar with an establishment’s food production
schedule.

48
 Determine if food products are being cooled very early in the inspection.
 Discuss the cooling process with the food employee who worked with the product prior to cooling. Accurate time-
temperature assessments related to when the cooling process was initiated are essential to determining the
effectiveness of the cooling procedure being used.
 Ask food employees and managers about the cooling procedures used, even if cooling is not taking place during the
inspection.
 Take temperature measurements in the geometric center of the product, then at various points around the
perimeter of the product. Ask additional questions to determine the time parameters involved. Temperature
differences in a container of food may provide evidence that the product is in the process of cooling (e.g., cooler
temperatures around the outer edges versus warmer temperatures in the middle).
 Ask questions of food employees about the cooling method used. Do they know that the method used cools foods to
the proper temperature within the required time frame? Validating that the cooling procedure works is an important
component of active managerial control, especially for facilities that intend to cool leftovers at the close of business
and will not have staff available to monitor actual temperatures as the food proceeds through the cooling process.
 If an establishment has confirmed (or validated) that a cooling procedure works, they may have implemented a
monitoring system that primarily focuses on the proper implementation of the cooling methods. Visual checks may
be conducted of the depth of foods in containers, number of filled bags placed in cooling tanks, amount of ice added
to recipes, etc. This information is important for assessing the level of active managerial control and determining
whether an establishment follows its own procedures.
 Determine if ingredients used to make menu items are pre-chilled before preparation. After preparation, assess
whether these products are placed in large containers to cool or stacked in a manner that will not facilitate cooling.
Foods that are prepared from ambient air temperature ingredients (even pre-chilled ingredients), such as tuna
salads, meat sandwiches, Cole slaw, all varieties of salad, etc., are often overlooked as ones that require proper
cooling. During batch preparation, the temperature of the ingredients of these products cause rise significantly.
 Assess each cooling method used to determine if sufficient controls are in place. This is because an establishment
may need to implement a variety of cooling methods to address the different variety of foods required to be cooled.
In most cases, however, one cooling method will work for all types of foods (thin liquids; thick liquids; semi-solids;
solid).

Time as a Public Health Control (TPHC)

If applicable - during every inspection, you should ALWAYS review the written procedures a facility has in place for foods
held under TPHC before assessing them for compliance – you need to be familiar with their procedures and discuss with
the PIC if any changes (food items added/removed) to the written TPHC procedures have occurred. Written procedures
for TPHC must be prepared in advance and maintained in the facility. The written procedures must be available to you
and the written procedures MUST include the cooling methods for food that is cooked and cooled prior to using
TPHC.

NOTE: any TCS food item that is placed under TPHC CANNOT be re-conditioned (cooled back down, re-heated, re-cooked)
– once the TCS food item is under TPHC it MUST be served or discarded within the appropriate time frame.

49
 TPHC USED AS A MICROBIAL GROWTH BARRIER FOR TCS FOODS

► Written procedure must be available on-site and:

 Identifies the foods to be held using time only as a public health control
 Describes the procedures for implementing time without temperature as a public health control (procedures,
training, monitoring, documentation)

► Time without temperature control is used as the public health control up to a MAXIMUM OF 4 HOURS
 Food must have an initial temperature of:
 41°F or less when removed from cold holding temperature control, OR
 135°F or above when removed from hot holding temperature control
 TCS Food marked or identified with the maximum 4 hour period when removed from temperature control
 After 4 hours any remaining food product is discarded
 Unmarked containers or packages or containers marked that exceed a 4 hour limit are to be discarded

► Time without temperature control is used as the public health control up to a MAXIMUM OF 6 HOURS
 Food must have an initial temperature of:
 41°F or less when removed from cold holding temperature control
 Food temperature may not exceed 70°F during the 6 hour period
 The food shall be monitored to ensure the warmest portion of the food does not exceed 70°F during the 6-
hour holding period
 TCS Food marked to indicate time when the food is removed from 41°F or less cold holding temperature
control
 TCS Food marked or identified with the maximum 6 hour period when removed from temperature control
 TCS Food is discarded of the temperature of the food exceeds 70°F OR
 After 6 hours any remaining food product is discarded
 Unmarked containers or packages or containers marked that exceed a 6 hour limit are to be discarded

Below are some helpful questions on assessing a PICs managerial control of TPHC:

 How long is TCS food being held out of temperature before or after cooking?
 How do you monitor how long products are out of temperature control?
 Do you have specific food products for which you use time instead of temperature as a food safety control?
 What type of system do you have in place to monitor the time?
 Who is responsible for ensuring that time frames for holding product out of temperature control are not exceeded?
 What happens to food that exceeds the time frames for holding?
 For the products that you hold using time rather than temperature, what action do you take after 2 hours if it appears
that all the product will not be sold or served within the 4 or 6 hour time frames?

NOTE: Keep in mind that using TPHC is an intentional use of time rather than temperature to control growth of pathogens.
Using TPHC as a corrective action of a cold holding issue is NOT allowed. The PIC needs to have a distinct system in place if
TPHC is used. TPHC is NOT meant to be used as a “safety net” in order for operators to avoid a violation and/or in cases of
refrigeration equipment failures, improper design, or lack of maintenance of refrigeration equipment.

NOTE: When assessing TPHC you should not only assess the written procedures in place, but the rotation of the product.
Does the facility add product to a container under time control in busy periods or does the system incorporate procedures
for completely changing out the containers? Are foods intended to be held cold without temperature control, stored or
commingled with foods intended to be temperature-controlled?

50
 Food contact surfaces: cleaned & sanitized

 You should thoroughly assess dish machine(s); there usage and sanitization methods being used (if applicable)?

o For example, assessing a dish machine for compliance during inspections is more than checking the sanitizer
levels. Below are some aspects to verify when assessing a dish machine:
 What are you looking for on the data plate? (hot water or chemical, required
temperatures/concentrations, pressure gauge range for hot water units)
 How did you determine which sanitizing method they are using?
 How do you know if the PIC and the dish washing employee know how to operate the dish machine
in the correct parameter?
 How do you verify that the water at the utensil level reached 160°F if the dish machine uses hot
water to sanitize dishes?
 How will the PIC verify that the water reaching the utensil level is 160°F?
 How will the PIC verify that the dish washing employee(s) know how to monitor the machine and
which method to use?
 Be sure to assess sanitizer strengths/concentrations by swiping your test strip onto a cleaned and
sanitized dish such as a lexan container – you should assess the concentration of the sanitizer on the
dish surface. Do NOT assess sanitizer strengths/concentrations by placing the test strip in the water
at the bottom of the dish machine.

• You should assess the 3 compartment dish washing procedure.

• You should assess and verify the types of sanitizers used and their concentrations (sinks, spray bottles, dish
machines) during inspections.
• You should discuss and verify with the PIC their methods on how they clean and sanitize “clean-in-place” equipment
(slicers, meat saws, mixers, cambros, kettles, cutting boards, large prep tables, chip bins).
• You should discuss and verify the frequency of when in-use utensils (spoons & ladles at the buffet line, knives, tongs)
are cleaned and sanitized during your inspection.
• Verify with the PIC their methods on cleaning/sanitizing food preparation sinks (meat, vegetable, etc.).
• Discuss and verify their methods on how they clean/sanitize the interior of ice machines/bins.
• Discuss and verify their methods on cleaning/sanitizing large equipment that cannot be immersed in the 3
compartment sink or cleaned/sanitized in dish machine (bulk flour, sugar, corn meal container).

51
Resources used to develop this manual are listed below:

 Georgia Food Service Rules and Regulations (290-5-14)

 Rules and Regulations for Food Service – Chapter 290-5-14 Interpretation Manual
 Food & Drug Administration (FDA) Food Codes - versions include; 2005, 2009, and 2013
 FDA’s Job Aid; Assessing Compliance and Active Managerial Control of Risk Factors
 FDA website - http://www.fda.gov/
 Conference for Food Protection (CFP) website - http://www.foodprotect.org/