Relationship Between Retail Food Facility Risk Rating and Observed Food Code Violations in Lubbock, TX
Charles Seifert, RS
Environmental Health Sanitarian II -
City of Lubbock Environmental Health Department
Abstract
The purpose of this study was to evaluate the relationship in five areas of violation observed in food establishments on higher risk facilities within the city of Lubbock, TX, during calendar years 2021 and 2022. Food establishments in Lubbock are inspected one to four times per year, as assessed by risk, which is determined by a points-based metric involving number of employees, menu complexity, and processes. Only facilities rated at higher risk food 3 and 4 were included in this study (City of Lubbock Environmental Health Department, 2018). Additionally, facilities serving a highly susceptible population were identified and included in the study. Data was collected and analyzed using the Hedgehog software suite. Results showed that Protection from Contamination was the area containing the most violations. Facilities serving highly susceptible populations were found to have fewer violations than facilities not serving highly susceptible populations. Facilities serving highly susceptible populations were found in violation more often than those not serving high risk populations in the Protection from Contamination category. Inspection target numbers were not met during the calendar years 2021 and 2022.
Keywords: Lubbock, risk, violations, HSP, hedgehog, Texas
Relationship Between Retail Food Facility Risk Rating and Observed Food Code Violations in Lubbock, TX
Background
Food establishments within the City of Lubbock, TX are categorized according to risk. The risk rating of a facility is determined by a points-based metric system and includes number of employees, menu items, specialized processes, and population served. In Lubbock, food establishments are rated at a food risk of between 1 and 4. Food facilities having limited menus such as bakeries are assessed as food risk 1. These establishments are inspected annually. Incorporating raw product and TCS (time/temperature control for safety) foods increases the likelihood of food code violations such as cross contamination. Most fast-food establishments are assessed in the risk 2 category. These facilities are inspected biannually. Food risk 3 facilities are assessed as such due to having an expanded menu or primarily serving a highly susceptible population (HSP), which are individuals with lower or compromised immunity. These facilities are inspected three times a year. Facilities that have extensive menus are assessed as food risk 4. These facilities often utilize special processes and have menu items with multiple preparation steps. Risk 4 facilities are inspected on a quarterly basis.
Higher risk ratings, due to the complexity of menus and populations served, allow for a greater likelihood of food code violations. Determining areas of greater concern in higher risk facilities is important for health inspectors. The risk rating of an operation may influence the type and number of violations. Active Managerial Control (AMC) is essential in retail food safety. The U.S. Food and Drug Administration (FDA) defines active managerial control as: the purposeful incorporation of specific actions or procedures by industry management into the operation of their businesses to attain control over foodborne illness risk factors. It embodies a preventive rather than reactive approach to food safety through a continuous system of monitoring and verification (FDA Food Code, 2017). A certified food manager may be a resource for employees responsible for food safety in a retail food establishment. Lack of active managerial control may increase the probability of food code violations. Currently the Texas Food Establishment Rules require one certified food manager per facility. Certified food managers are not required to be onsite during all hours of operation. Data pertaining to common violations may aid inspectors in understanding which areas to pay more attention to, depending on a facility’s risk rating and population served.
Problem Statement
The relationship between higher risk rated facilities and violations observed during retail food inspections in Lubbock, TX from January 2021 through December 2022 has not been evaluated.
Research Questions
What are the most frequent areas of food safety violations observed during inspections of higher risk food establishments?
What trends, if any, may be identified by violations observed during inspections within higher risk facilities?
How may these observations be utilized to ensure a greater level of food safety within higher risk food establishments?
Is there a correlation between higher risk facilities and areas of violation observed?
How does a facility that serves a highly susceptible population (individuals with lower or compromised immunity) influence type and number of violations compared to a same risk facility that does not serve a highly susceptible population?
Methodology
The City of Lubbock Environmental Health department began using Hedgehog software in March 2022. Data was collected using the Hedgehog software suite with custom reports written in DevExpress. This software allows for filtering of violations in a grid representation. Violations were enumerated according to facility risk. Reported violations were compiled into a dataset. The data was evaluated to determine which violations were common among higher risk facilities. Certain violations observed at higher risk facilities serving a highly susceptible population (HSP) were evaluated and compared to higher risk facilities not serving a highly susceptible population. The areas of violations that were evaluated were: Time and Temperature for Food Safety, Protection from Contamination, Prevention from Contamination by Hands, Chemical, and Demonstration of Knowledge/Personnel.
Specific violations included in these areas are as follows:
Time and Temperature for Food Safety:
Proper cooling time and temperature
Proper cold holding time and temperature
Proper hot holding time and temperature
Proper cooking time and temperature
Proper reheating procedures for hot holding
Time as a public health control; procedures and records
Protection from Contamination:
Food separated and protected; contamination prevented during food preparation, storage, display, and tasting
Food contact surfaces and returnables; cleaned and sanitized at proper concentration/temperature
Proper disposition of returned; previously served or reconditioned
Prevention of Contamination by Hands:
Hands cleaned and properly washed; gloves used
No bare hand contact with ready to eat food or alternated method properly followed
Chemicals:
Food additives: approved and properly stored; washing fruits and vegetables
Toxic substances properly identified, stored, and used
Demonstration of Kowledge/Personnel
Person-in-charge present, demonstration of knowledge, and performs duties/Certified Food Manager
Food handler, no unauthorized persons/personnel
Results
A total of 587 facilities were evaluated. Of the 587, there were 363 food risk 3 facilities and 224 food risk 4 facilities. Of the 363 food risk 3 facilities, 27 served a highly susceptible population. Of the 224 food risk 4 facilities, 71 served a highly susceptible population.
A total of 1,276 inspections were completed at these facilities during calendar years 2021 and 2022. There were 716 inspections performed on food risk 3 facilities, 81 were conducted on facilities serving a highly susceptible population.
A total of 560 inspections were performed on food risk 4 facilities with 249 of these inspections conducted on facilities serving a highly susceptible population. The target number of inspections to be conducted was not met in this time frame. Food risk 3 facilities received 65% of their target number of inspections with 100% of food risk 3 HSP facility inspections completed. Food risk 4 facilities received 63% of their target number of inspections with 86% of food risk 3 HSP facility inspections completed.
Figure 1 illustrates the percentage of inspections where violations were found in their respective areas in all food risk 3 and 4 facilities. Protection from Contamination is shown to be the area with the greatest percentage in violation with “Protection from Contamination by Hands being reported as the least.
Figure 1
Targeted violation areas observed during calendar years 2021 and 2022.
Figure 2 displays the percentage of inspections where violations were found in their respective areas in HSP facilities. Protection from Contamination is again shown to be the area with greatest percentage in violation.
Figure 2
Targeted violation areas observed in HSP facilities during calendar years 2021 and 2022.
Conclusions
Protection from Contamination was seen as the prevailing area for observed violations for all food risk 3 and 4 facilities (including HSP)
Violations in all areas were found at food risk 3 facilities at a higher rate than food risk 4 facilities, with food risk 3 facilities showing a 15% higher rate of violations across all areas.
While violations involving Chemicals displayed the most significant difference between food risk 3 and 4 facilities, violations were observed at the same rate in HSP facilities.
Food risk 3 facilities were found in violation at a 6% higher rate than risk 4 facilities when including non HSP facilities. The higher rate of violations observed in the Protection from Contamination and Chemical could lead inspectors to emphasize facility education in these areas.
Higher risk facilities showed a lower rate of violation and HSP facilities showed an even lower rate.
Differences were equal between food risk 3 and 4 HSP facilities except for risk 4 HSP facilities having twice as many Demonstration of Knowledge/Personnel violations, and risk 3 HSP facilities having 8% more violations concerning Protection from Contamination.
Recommendations
During the calendar years 2021 and 2022 the City of Lubbock Environmental Health department conducted more than 4,700 food establishment inspections. The findings in this research led to the following recommendations:
An annual study should be conducted on observe violations.
Increasing the number of inspectors and retention of trained inspectors may help facilitate consistently meeting target inspection numbers.
A study to determine impact of department employee turnover should be conducted.
Further studies should continue to be regularly conducted on food risk 3 and 4 facilities.
Acknowledgements
I would like to thank the following people and organizations:
International Food Protection Training Institute
IFPTI Cohort XI Fellows
The City of Lubbock Environmental Health Department
Stevan Walker (IFPTI Cohort I)
Grady Bergquist (IFPTI Cohort IX)
Doug Saunders (IFPTI)
References
U.S. Department of Health and Human Services, Public Health Service, Food and Drug Administration. (2017.) Food Code. https://www.fda.gov/food/fda-food-code/food-code-2017
City of Lubbock Environmental Health Department. (2018) Risk assessment. Unpublished internal document.
Author Note
Charles Seifert, Environmental Health Sanitarian II
City of Lubbock Environmental Health Department
This research was conducted as part of the International Food Protection Training Institute’s Fellowship in Food Protection, Cohort XI.
Correspondence concerning this article should be addressed to:
Charles Seifert, RS
City of Lubbock Environmental Health Department
P.O. Box 2000, Lubbock, TX, 79457
Funding for the IFPTI Fellowship in Food Protection Program was made possible by the Association of Food and Drug Officials.