According to epidemiological data collected by the U.S. Centers for Disease Control and Prevention (CDC), the most commonly reported risk factor contributing to foodborne illness is improper holding temperature. This was followed in short order by inadequate cooking of food. Rounding off the top five, CDC also listed as risk factors poor personal hygiene, contaminated equipment and foods from unsafe sources. While these five risk components are significantly linked to management practices, I could not help but wonder what weighting the facility has on the first two: improper holding temperature and inadequate cooking of food?
I went back over the many reports and articles I’ve written and collected over the years relating to institutional food service, particularly those in correctional facilities. I think it’s safe to say that problems with food protection rise exponentially with crowding and overuse. Kitchens that were built to feed the design capacity of the facility are suddenly expected to feed twice that number—with an expectation of safe and wholesome food. While every effort is taken to upgrade security, generally no provisions are made to accommodate the increased demand in the kitchen. Cold holding, dry storage, cooking and ware washing simply cannot keep up with the demand; regardless how thorough and diligent the operators are with their implementation of Good Manufacturing Practices (GMPs) and Hazard Analysis and Critical Control Points (HACCP) plans. Throughout the retail food industry new owners take over existing establishments and radically change the menu to serve a different clientele without any modifications to the kitchen. Or, they create a new establishment based on available capitalization—without regard to the menu, type of service or number of anticipated customers. These examples are all too common and often a recipe for disaster.
Planning for Success
Many of the problems inherent within a food handling facility, and particularly with kitchen design, can be avoided by conducting a simple exercise known as the Plan Review. The Plan Review is a mutual effort that builds relationships and trust between regulatory officials, owners, operators, builders and designer/architects in an effort to optimize the functionality of a food establishment. The process allows industry to establish an organized and efficient flow of food and helps management and staff to better understand and comply with regulatory expectations. If the Pan Review process is a thorough one, the facilities will support food protection, loss control relating to worker and customer safety, and a realization of significant economic benefits because modifications can be made before costly purchases, installation and construction begins. A thorough Plan Review will justify the location, type and utility of equipment, outline traffic patterns in the production and service areas and review the diagramming specifications for electrical, mechanical and plumbing systems. Yes, a Plan Review seeks code compliance, but more importantly, it realistically helps ensure the public health and safety of a facility without undue financial burdens.
Three decades ago, many of us old-timers were fortunate enough to take a course in Plan Review that was offered by the quintessential sanitarian: D.L. Lancaster of NSF International. I distinctly remember being taught how to properly size refrigeration equipment, storerooms and water heaters, and, what to look for in a preconstruction design review. When D.L. retired, so did universal training until the most recent initiatives were introduced by the U.S. Food and Drug Administration (FDA). In the late 1990s, the Northeast Region Plan Review Development Committee for the Conference for Food Protection published the Food Establishment Plan Review Guideline, based on the 1999 Food Code. This work-in-progress put “Plan Review” back in the limelight, although its full potential impact on consumer safety has yet to be realized. Through my experiences, I remain absolutely convinced that a uniform, thorough, detailed, practical and cooperative Plan Review before new construction of a food establishment or remodeling an existing facility is absolutely essential in reducing the risk of facility mediated foodborne illnesses and injuries. Uniformity and thoroughness are the key components to make this happen.
Late last fall, I proposed developing a Plan Review training program and Plan Review Personnel certification Program for NSF International. NSF was delighted to have this important program started up again, and was hopeful of continuing the legacy of “DL”. As such, I was recruited by NSF International to continue what D.L. had started. NSF’s plan was to provide this training to all interested individuals and make it as widely available as possible. I therefore embarked, along with Harry Grenawitzke, consultant to NSF, to rework some of the existing FDA training materials and fashion them into a two-day training program. We also started development of a competency-based credentialing program for industry and regulatory professionals that would encourage, and hopefully achieve greater uniformity in the Plan Review process. As of this writing, the new NSF Plan Reviewer training and credentialing program is completed and available to all who are interested.
Building on Details
In doing the research for the Plan Review Training Program, I reviewed the Food Code, visited numerous websites and scoured texts and other materials related to this subject. Except for numerous local compliance initiatives, I was rather amazed (more like, appalled) at the scarcity of information specific to the groundwork and foundation of the Plan Review process, as well as its details. Most texts and popular training materials barely make mention of plan reviews, if at all. And I could find no published paper that proffers a compelling argument for its utility and economy. I am also quite puzzled that the topic appears in Chapter 8 of the Food Code, “Compliance and Enforcement.” While it seems that the topics encompassed by the Plan Review process are related to code compliance, most of the issues have a different emphasis than that of enforcement. Most of the nuances of the Plan Review are based on good common sense that is not covered under the Food Code or local ordinances, with a few exceptions.
Because the process precedes new construction, conversion of an existing structure for use as a food establishment; remodeling of an existing facility, or change of type of food establishment or operation, it asks certain questions and makes certain assumptions. The Plan Review begins with the intended menu and anticipated volume of food to be stored, prepared and sold or served, and from this, it validates the design of the facility. In its prescription for Plan Review, the Food Code asks for information that includes the proposed layout, mechanical schematics, construction materials and finish schedules. It also seeks information to demonstrate conformance with Code provisions on the proposed equipment types that will be part of the operation, including manufacturers, model numbers, locations, dimensions, performance capacities and installation specifications. In addition, many regulators require a properly prepared HACCP plan along with the Plan Review. This makes quite a bit of sense when you consider that the emphasis of the HACCP plan is time and temperature, which is inextricably linked to the facility. The questions to consider in preparation of the Plan Review process are nicely outlined in the FDA/CFP Food Establishment Plan Review Guide, also known as the “Blue Book.” With gratitude to its authors, these questions are:
• Will the menu offer food that requires extensive preparation such as washing, cutting, mixing, etc.? For instance, the more handling of the food and the increased complexity of the menu requires a greater need for handwashing and culinary sinks, prep areas and temperature maintenance facilities. A full-service facility also will require greater warewashing capability, along with increased hot water requirements, than a take-out establishment. In addition, each type of food establishment will also have its own unique storage needs.
• What are the hours of operation and service? Extended hours require greater equipment capacity and storage space. Because of increased usage, floors, walls and ceiling finishes of higher durability should also be considered.
• How much food will be cooked and immediately served, or prepared in advance for later service? Advance preparation requires more refrigeration space for thawing, cooling hot foods and storing cold foods. Likewise, there are differing needs for hot and cold-holding service facilities.
• How often will food and supplies be delivered? Delivery frequency, as well as meal size, is important in determining the space required for refrigerated, frozen and dry storage.
• What is the maximum number of employees working on one shift? This will determine work/aisle space, toilet and locker facilities and their accessibility.
• Has everyone been trained in both food safety and HACCP principles? The knowledge that comes with this training helps establish traffic patterns to prevent cross contamination and temperature abuse. These traffic patterns can then be effectively built into the plan.
As you can see, the process can be as much an art as it is a science and compliance tool. The approach is one of objectivity where menu items are qualified and quantified to determine the facility layout and operating systems. I urge everyone in this industry to consider both the universality and uniformity of approach to this process. To learn more, visit the FDA, the Conference for Food Protection and the NSF International websites. Additionally, several local health departments have excellent programs that outline the plan review process and are available through their websites.
Forensic sanitarian Robert W. Powitz, Ph.D., MPH, RS, CFSP, is principal consultant and technical director of R.W. Powitz & Associates, a professional corporation of forensic sanitarians who specialize in environmental and public health litigation support services to law firms, insurance companies, governmental agencies and industry. Contact him at sanitarian@juno.com.
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