Food Safety Inspection Officers’ Awareness of Reduced Oxygen Packaging (ROP) Requirements in Wisconsin

Anthony P. Anderson

Environmental Health Specialist

Milwaukee Health Department (Wisconsin)

International Food Protection Training Institute (IFPTI)

2012 Fellow in Applied Science, Law, and Policy: Fellowship in Food Protection

Abstract

Reduced oxygen packaging (ROP) is the reduction of the amount of oxygen in a package by removing, displacing, or replacing oxygen with another gas or combination of gases; or otherwise controlling the oxygen content to a level below that normally found in the atmosphere (US FDA, 2013).  As the ROP process creates an anaerobic environment, foods in reduced oxygen packages are more susceptible to the growth of both anaerobic pathogenic bacteria such as Clostridium botulinum and facultative psychotropic bacteria such as Listeria monocytogenes. Food Safety Inspection Officers (FSIO) must understand ROP processes and food code requirements in order to adequately address the associated hazards. This paper examines Wisconsin FSIO awareness of ROP processes in addition to current and proposed food code requirements in relation to ROP. A thirteen-question survey was developed to capture Wisconsin FSIO awareness with ROP practices and code requirements, and to identify opportunities for ROP training. A key finding was that participants were not familiar with proposed code changes in relation to ROP. In addition, many respondents stated more training in ROP would be beneficial.

Background

As more retail food establishment operators utilize specialized processes to maximize production, improve food flavors and extend shelf life, there is an increased need for Food Safety Inspection Officers (FSIOs) to understand these processes and any associated risks (Rodgers, 2002). The national trend of implementing specialized processes is being experienced first-hand by Milwaukee FSIOs, who are discovering on their inspections an increasing number of restaurateurs and chefs who are utilizing or inquiring about complex food processes such as Reduced Oxygen Packaging (ROP).  For example, a newly opened Milwaukee restaurant is the second establishment using an ROP process within a one-block radius (Lazarski, 2012).

Two distinct methods of ROP being encountered throughout the U.S. and within some of Wisconsin’s retail food establishments are Cook-Chill (CC) and Sous Vide (SV) processes. CC is an ROP procedure of placing a fully-cooked hot food item into an impermeable bag and rapidly cooling the food product to a safe cold-holding temperature. SV is an ROP procedure of placing a partially cooked or raw food product into an impermeable bag, removing the oxygen, and cooking and serving or cold-storing until customer service. This paper will explore the familiarity of Wisconsin’s food safety inspection officers (FSIOs) with code requirements as they relate to retail ROP processes including CC and SV.

Wisconsin FSIOs currently enforce food safety regulations under the 2006 Wisconsin Food Code (WFC), which is a modification of the FDA 2001 Model Food Code. This regulatory document has requirements that address controls for Clostridium botulinum (C. botulinum) during ROP practices. However, the 2006 WFC may be limited regarding ROP in Wisconsin’s retail food establishments. The WFC is not based upon the most current scientifically-based 2009 FDA Model Food Code which, in comparison to previous versions, offers in-depth information on the control of Listeria monocytogenes (L. monocytogenes) in addition to C. botulinum for retail ROP practices. These controls are important because ROP creates an ideal anaerobic growth environment for psychotropic pathogens such as L. monocytogenes.

The Food Code is the FSIOs’ core reference tool for protecting public health and preventing foodborne illnesses. The Food Code addresses the 5 major risk factors associated with foodborne illnesses as identified by the CDC: food from unsafe sources; inadequate cooking; improper holding temperatures; contaminated equipment; and poor personal hygiene. (National Advisory Committee on Microbiological Criteria for Foods, 1998).

In 2010, Wisconsin proposed adopting FDA’s 2009 Food Code with modifications. Adoption of an updated regulation will strengthen the ability of Wisconsin FISOs to protect consumers from foodborne illnesses in addition to strengthening Wisconsin’s ROP requirements.

As Wisconsin is operating under a modified 2001 FDA Model Food Code, there is an education and enforcement gap regarding the control of L. monocytogenes in ROP. The conversion to a modified 2009 FDA Food Code within the state of Wisconsin will result in the need for increased education and sanitation requirements for retail establishments performing ROP procedures.   

Problem Statement

Wisconsin’s Department of Agriculture Trade and Consumer Protection and Department of Health Services (DHS) are slated to adopt a food code based on the 2009 FDA Model Food Code, which contains the most current science-based provisions for ROP processes. The 2009 Code contains significant changes related to ROP, yet FSIOs may not be familiar with these provisions. As a result of this potential knowledge gap, FSIOs may not be educating retail food service operators appropriately, nor enforcing the ROP provisions in the current Wisconsin Food Code appropriately.

Research Question

The three primary research questions are:

·       What is Wisconsin FSIOs’ awareness of ROP?

·       What is FISOs’ awareness of Wisconsin’s proposed food code requirements in relation to retail ROP?

·       What are the training needs for Wisconsin FSIOs in ROP?

Methodology

 A thirteen-question electronic survey was developed to gather information about Wisconsin FSIO awareness of ROP processes, Wisconsin’s current and proposed ROP food code changes, and ROP training needs. The Wisconsin DHS Food Safety Program Manager was asked to forward a survey email invitation to a constituent list of Wisconsin FSIOs. The email included information about the study, an invitation to participate, and the link to the online survey. The survey was also distributed by International Food Protection Training Institute staff to Wisconsin FSIOs using the AFDO Directory of State & Local Officials. A total of 105 potential participants were solicited. Data for the research project was collected online via Survey Monkey™ and analyzed by the study author.

Results

Sixty five participants responded to the survey within a two-week time frame (61.9% response rate).  Four questions from the survey were determined to be not formatted correctly and therefore were omitted from results. Forty-five of the respondents (69.2%) were familiar with Wisconsin’s proposed Food Code change; however, thirty-two (49.2%) of the respondents were not familiar with changes in relation to ROP. Thirty-five of the respondents (53.8%) were familiar with Cook-Chill, and thirty-three of the respondents (50.7%) were familiar with Sous Vide (Figure 1).   

More than two-thirds (67.6%) of the respondents reported never encountering ROP practices within licensed establishments. Similarly, 72.3% of the respondents reported having no experience educating operators on relevant changes related to ROP in Wisconsin’s proposed food code. Approximately half (33/65) of the respondents stated their Department/Agencies provide training material (literature) for operators engaged in ROP and that their Department/Agency is familiar with ROP (32/65) (Figure 2). The overwhelming majority (54/65) of the respondents indicated that they would benefit from additional training in ROP.

Conclusions

          This research assessed Wisconsin FSIOs’ awareness of ROP processes, awareness of proposed food code changes, and training needs regarding ROP. From analysis of the data three main conclusions emerged:

1)    One-third of FSIOs were unfamiliar with proposed food code changes. Therefore, education and outreach is needed to assure all FSIOs are aware of the ROP changes in the code, specifically in addressing Listeria monocytogenes concerns.

2)    Experience with ROP is limited. A system must be set up to provide FSIOs opportunities to observe specialized processes and become truly prepared to deal with the processes when encountered in the field.

3)    Though FISOs reported having knowledge of ROP, the vast majority indicated they could benefit from additional training, which indicates that the level of proficiency with ROP is low and training should be made widely available.

Recommendations

Adoption of the 2009 WFC, statewide training and review of the State variance and/or HACCP requirements for ROP may strengthen FSIOs’ enforcement and knowledge base.  Even though a majority of FSIOs within Wisconsin are familiar with ROP practices, there is still an added benefit to education related to ROP practices. A statewide training session for Wisconsin FSIOs on ROP practices and equipment would aid in addressing ROP practices that are becoming more prevalent in retail food establishments.

Acknowledgments

This educational journey was made possible by the care of IFPTI and their affiliates, IFPTI support staff and their passion for an integrated food safety system; the leadership of my mentor, Dr. Joanne Brown, support from Angela Hagy (Director of Consumer & Environmental Health, MHD); and the guidance of Julie Hults (Environmental Health Coordinator, MHD). I also would like to extend my gratitude to Wisconsin’s AHJs and FSIOs for your survey responses and for holding the frontline on food safety daily.

Corresponding Author

Julie Hults, Training Coordinator, Milwaukee Health Department

References

Lazarski, T. (2012, July 11). First Impressions. Retrieved from  http://www.avclub.com/milwaukee/articles/c-1880,82288/

National Advisory Committee on Microbiological Criteria for Foods. (1998). Hazard Analysis and Critical Control Point Principles and Application Guidelines. Journal of Food Protection, pp. 1246-1259.

Rodgers, S. (2002). Survival of Clostridium botulinum in Hot-Fill Meals. Food Service Technology, pp. 69-79.

US FDA. (2013, February 28). FDA Food Code 2009: Chapter 1- Purpose and Definitions. Retrieved from  http://www.fda.gov/Food/FoodSafety/RetailFoodProtection/FoodCode/FoodCode2009/ucm186464.htm