The Impact of Desk Audits on the Consistency of Retail Food Inspection Reports in Alaska: A Trend Analysis
Morgan Poloni, M.S, REHS
Environmental Health Officer III
State of Alaska, Department of Environmental Conservation – Food Safety and Sanitation Program
International Food Protection Training Institute (IFPTI)
2012 Fellow in Applied Science, Law, and Policy: Fellowship in Food Protection
Abstract
The State of Alaska Food Safety and Sanitation Program has 25 full-time Environmental Health Officers (EHOs) located throughout the state that regulate 9,300 permitted facilities. Many EHOs are located in remote offices throughout the state. As a consequence, there may not have been consistent reinforcement of program protocols or Food Code interpretation necessary to ensure uniformity and consistency among staff. To address this concern, the State of Alaska Food Safety and Sanitation Program implemented the General Food Desk Audit outlined in the Voluntary National Retail Food Regulatory Program Standards (VNRFRPS) and recorded progress over the course of a year. This study explored the effectiveness of desk audits through a trend analysis. Results showed an improvement in staff consistency over the course of one year.
Background
Alaska has 25 full-time Environmental Health Officers (EHOs) responsible for regulating, primarily through permitting and inspection, 9,300 food establishments and public facilities. Many EHOs are located in remote locations where they are expected to work independently, and direct oversight is not practical. As a consequence, there may not have been consistent reinforcement of program protocols or Alaska Food Code interpretations necessary to ensure uniformity and consistency among staff.
Inconsistent communication has resulted in many offices developing their own inspection styles and methods within the culture of their community. These varying styles and methods include independent filing systems, interpretations on permitting, and interpretations of how to address violations found in food establishments. The inconsistency was identified as a problem by the State of Alaska Food Safety and Sanitation (FSS) Program Managers.
The State of Alaska Food Safety and Sanitation Program enrolled in the FDA’s Voluntary National Retail Food Regulatory Program Standards (VNRFRPS) in 2006. The VNRFRPS provide an outline for food safety programs to follow to become uniform and consistent. The desk audit tool provides a list of 11 key factors that should be verified during each inspection and then documented on the corresponding inspection report. Using the desk audit outlined in VNRFRPS Standard 4, the FSS Program began to assess inspection reports beginning in January 2012.
Training on the Desk Audit process and procedures began in December, 2011, which appeared to create apprehension among the EHOs. Many EHOs had not received feedback on their inspection reports since their initial training, which, for some staff, was as long as 10 years.
Problem Statement
Varying interpretation of Alaska’s Food Code and program policies does not provide uniform and consistent application of inspections and enforcement which may pose a threat to public health.
Research Questions
What is the effectiveness of feedback to Environmental Health Officers using the desk audit form outlined in the VNRFRPS over the course of one year?
Methodology
Using the desk audit as a tool, seven inspections per month were randomly selected and assessed from January 1st, 2012 through December 31st, 2012. The results of the desk audit were first given to the EHO’s supervisor to be reviewed with the EHO. After that, the results were entered into a database, averaged monthly, and then plotted on a graph over the course of the year.
The General Food Desk Audit addressed 11 key factors, 10 of which were observable and were chosen for the purposes of this study. The key factors that were used verified that the EHOs did the following on each inspection report:
1. Verified that the establishment was in the proper risk category;
2. Inspected the establishment at the required inspection frequency;
3. Reviewed past inspection findings and acted on repeated or unresolved violations;
4. Conducted a risk-focused inspection. This was determined by documenting the compliance status of each risk factor and intervention through observation and investigation;
5. Provided an inspection report that is clear, legible, concise, and accurately recorded observations and discussions with establishment management;
6. Cited the proper Alaska Food Code provisions for foodborne illness risk factors and public health interventions;
7. Obtained and documented on-site short-term and long-term corrective action for out-of-control risk factors during the inspection as appropriate to the type of violation;
8. Documented discussion with establishment managers of options for the long-term control of risk factors when the same out-of-control risk factor occurred on the previous inspection;
9. Followed through with compliance and enforcement; and
10. Cited Good Retail Practices correctly.
Results
The results of the one-year trend analysis show a rise in percent compliance on the 10 key factors addressed by the Desk Audit Form (Figure 1). A decrease was observed over late spring/early summer before increasing again (Figure 2). Figure 1 and Figure 2 were calculated by taking an average of the 10 key items each month and plotting them over the course of one year.
Conclusions
There is a distinct upward trend in compliance, which indicates that staff reports were becoming more uniform and consistent across the state after EHOs received feedback. The dip in percentage calculated may be attributed to the hiring of five new field staff in the spring of 2012. The rise may correlate to the new EHOs learning as they are trained in the field and then released to do independent inspections.
In addition, variation within the graph may be attributed to the fact that seven random inspections were pulled each month. Within the confines of this study, every EHO did not receive feedback monthly, and feedback was dependent on the EHO’s activity in the field. Since the program has 25 full-time field staff, and if a different EHO was selected for each desk audit, it would take four months for all staff members to receive feedback. Due to the random selection process, this did not happen, and as a result some EHOs did not receive any feedback until later during the study period.
Recommendations
There were three recommendations noted during the course of this study. First, supervisors need to understand that timely review with EHOs is important to the success of the desk audits. Initially, not all supervisors were reviewing the desk audit information with staff in a timely manner (within 15 days of receiving the desk audit results). The lack of timely feedback decreased the immediate effectiveness of the desk audits in the first six months.
Second, a thorough review of the inspection protocol and marking instructions should happen before beginning the Desk Audits. Although Alaska’s FSS Program staff members were trained in the protocols and marking instructions, the information was not reviewed right before starting the Desk Audits
The third recommendation would be to document all key questions pertaining to the desk audit, food code, or program policies and review them with all staff. Consistent review and uniform communication reinforces the training to EHOs that have had feedback through the desk audits and provides information to the EHOs who haven’t.
Acknowledgments
I would like to thank the International Food Protection Training Institute for the opportunity to participate in the Fellowship Program. I would also like to thank the International Food Protection Training Institute Instructors and Staff and my mentor Cameron Smoak. In addition, I would like to thank the State of Alaska, Department of Environmental Conservation – Food Safety and Sanitation Program Staff and my supervisor Kimberly Stryker.