Strategies to Improve Food Safety Communication Between the St. Cloud, Minnesota Environmental Health Program and East African Food Operators
Emily Herbst
Assistant Health Director, City of St. Cloud, MN
Abstract
This article describes the results of research conducted on communication strategies to promote compliance of retail food establishments in the City of St. Cloud, MN. A Certified Food Protection Manager Training was hosted by the City of St. Cloud in conjunction with two partner agencies to offer translated education to the East African community of retail food operators in St. Cloud. While offering free training, research was conducted to evaluate where communication strategies need improvement between inspectors of the St. Cloud Health and Inspections Department and operators of various retail food establishment types. Data was collected in the form of a post-training questionnaire. Additional data was obtained through follow-up interviews with attendees of the training. Analysis of the data revealed that translated training resources, and additional time spent in the field with operators using translation services would help bridge communication barriers in English as a second language based retail food establishments.
Key words: Risk Assessment, Communication, Compliance, Training, Translation, non-English and Barriers
Background
The city of St. Cloud is located in Central Minnesota and home to nearly 70,000 people (Minnesota Compass, 2021), with over 200,000 people in its metro area (City of St. Cloud, 2021). The Health and Inspections Department houses the Environmental Health Program which has two environmental health specialists who conduct inspections at nearly 500 food establishments. St. Cloud is a culturally diverse community and has a diverse food culture that is expressed through special events, food trucks, restaurants, and community grocery stores.
The St. Cloud Health and Inspections Department has dual jurisdiction to conduct routine food safety inspections on behalf of both the Minnesota Department of Health and the Minnesota Department of Agriculture. Through this delegation there are specific requirements such as routine risk assessments to understand the compliance trends in each jurisdiction. The risk assessments show which violations are occurring most, how often inspectors are marking certain violations, which establishments have good/poor compliance history, etc. Risk assessments are invaluable tools to determine shortfalls within an inspection program.
While reviewing a risk assessment from January 2019 to January 2020, the top 20 establishments with the highest number of marked non-compliant priority-one and priority-two items[1] were evaluated. Sixty percent of the 20 establishments were ethnic-based food establishments whose employees and owners speak English as a second language. Forty percent of these ethnic establishments were East African based food establishments.
The risk assessment also identified two areas of non-compliance specific to the Person-in-Charge and the Certified Food Protection Manager (CFPM). The Person-in-Charge is expected to demonstrate a knowledge of foodborne disease and prevention during an inspection, while ensuring safe food handling practices at all times. The CFPM has a good working knowledge of the food industry and has the authority to conduct CFPM duties at an establishment. Such duties include identifying hazards, developing policies to address foodborne illness, leading employee food safety training, and conducting in-house inspections to ensure food safety policies are followed.
The CFPM also is required to attend an accredited food safety training, pass an exam, and maintain the certification as long as they are employed as the designated CFPM with the establishment. The Person-in-Charge is a required designation at each food establishment. The CFPM is not required at every food establishment; only those that meet a certain risk designation of high-risk and in some cases medium-risk[2] or establishments that reheat ready-to eat TCS (Time-Temperature Controlled for Safety) foods for hot holding. Exemptions from this requirement would include establishments that meet the definition of low-risk, or those that are not considered high- or medium-risk establishments. Both the CFPM and the Person-in-Charge are considered critical members of the food service establishment, with respect to foodborne illness intervention and monitoring foodborne illness prevention measures.
Routine inspections and the risk assessment show high numbers of violations in the establishments owned/operated by East African people. The City of St. Cloud’s Health and Inspection program may not be responding to the educational needs of this community for food safety success.
Problem Statement
The effectiveness of the City of St. Cloud Health and Inspection’s food safety education strategies currently employed at East African food establishments is unknown.
Research Questions
1. What barriers do St. Cloud East African food establishment operators believe exist relative to fully meeting food safety education requirements?
2. How are the current requirements for the Certified Food Protection Manager and the Person in Charge being implemented to increase food safety knowledge for St. Cloud East African food establishment operators?
3. What strategies can the City of St. Cloud employ to assist St. Cloud East African operators in meeting food safety education requirements?
Methodology
The City of St. Cloud received a small project grant to fund a translated Certified Food Protection Manager (CFPM) training and provide translation services for the associated exam necessary to obtain a certificate of completion. The goals of the training were to provide a translated food safety course, meet the compliance requirements of the CFPM and Person-in-Charge code sections, increase knowledge of core food safety principles, eliminate cost restrictions, and reduce time away from the business. During this training, city staff asked the attendees to complete a written questionnaire to better understand demographic information regarding who attended the class, previous work experience, job functions in the establishments at which they are employed, previous training received, and immediate feedback on the training. This questionnaire was provided as a way to learn more about the establishments and employees who attended the course.
After hosting the CFPM training and exam, City of St. Cloud inspection staff contacted St. Cloud East African food establishment operators and staff who attended the training to obtain further feedback. During interviews, a translator and inspector, or the researcher, asked questions regarding the general food safety foundation, feedback from the training opportunity, other training opportunities they would like to see available, feedback on inspection processes, and opinions on communication barriers experienced as a food employee.
Interviews were conducted with the assistance of translation services provided by a St. Cloud Health and Inspections’ staff member who is fluent in the Somali language. The researcher reviewed questions with the translator and requested that all questions and responses be translated. The translator clarified questions and meanings during interviews at the request of interviewees or as needed, and follow-up questions were asked. The interviewer recorded shorthand notes to document responses. Once the questionnaires and interview data were collected, the data were analyzed to determine what strategies could be employed to improve assistance and compliance. Data from questionnaires was tracked in a Microsoft Excel spreadsheet, while interview notes were reviewed as recorded and uploaded into Microsoft Word documents to allow for additional comments to be tracked on the document.
Results
The training had a total of seven attendees. Six of the seven attendees own and operate businesses in Saint Cloud. The seventh attendee was from the Minneapolis/St. Paul metro area and attended at the request of the trainer. Six of six attendees from Saint Cloud completed the pre-exam questionnaire. Three of the six Saint Cloud attendees participated in the post-exam interviews. For the purposes of this section, I will be referring to the interviewees as Interviewer 1, Interviewer 2, and Interviewer 3.
The post-exam interviews show that all three interviewees viewed language as a primary barrier between the City of St. Cloud inspection staff and the food establishment owners and staff. All three interviewees explained that they misinterpreted the following items provided by City staff without the help of translation services: City staff explaining violations found while conducting inspections; written inspection reports; handouts; and the Minnesota Food Code (State of MN, 2019). One interviewee explained they want to double their efforts in terms of food safety, but worry they may be misunderstanding something the inspectors are saying and worry they may respond incorrectly resulting in a marked violation (Interviewer 2, personal communication, February 16, 2021). Two of the three interviewees explained they were unaware of the CFPM renewal requirement and asked if there were translated online trainings to maintain the CFPM credential.
All three interviewees who attended the training explained, during the interviews and prior to the training, that they consider themselves both the CFPM and the Person-in-Charge at their business. However, five of the six training attendees marked on their questionnaire that this translated training was the first food safety training they have taken. All three interviewees explained the difficulty of taking a two-day course as all three indicated they work seven days a week and often are the only employee onsite during business hours. One interviewee who has multiple staff onsite, explained that it is hard for staff to stay on board and he does not trust they will continue working, therefore, he feels he has to work seven days a week to ensure that he can monitor staff in case of an emergency (Interviewer 1, personal communication, January 25, 2021). This same interviewee later explained that staff worry during an inspection especially if he isn’t there because they struggle to communicate (Interviewer 1, personal communication, January 25, 2021).
All interviewees rated their experience taking the translated CFPM training course between 8 and 10 out of 10; based on a scale ranging from: they felt they “didn’t learn anything,” to, they felt they “could be a food safety expert.” All interviewees requested that the City of St. Cloud host the translated CFPM training course annually. All interviewees requested translated training documents with pictures for internal use, and for use with the community as well.
When asked how the Department could gain more attendance at trainings, one interviewee explained that the [East African food establishment] ‘community is a team,” and that “they have had such a good experience with the provided training, that they will help promote” trainings in the future. Another interviewee explained that they would like to have additional non-regulatory options available for training such as internal audit checklists, non-regulatory visits, online trainings to earn educational credits for the CFPM, and a packet with information such as a CFPM starter kit.
All interviewees responded that they understood the information delivered in the training. Compliance data post-training has not been recorded as part of this project, however, an interviewee reported that some “challenges to interpretation” are meeting compliance timeframes. All interviewees explained that they hope inspectors can remain “personable,” “fair,” “maintain kindness in their hearts,” “be someone who wants the businesses to succeed,” and help “with small business needs.” Interviewees also requested that patience be practiced during inspections, especially if a translator isn’t readily available.
Conclusions
Implementing successful food safety intervention strategies is a goal for both inspectors and food establishments. The best way to facilitate the intervention strategies may not always be obvious, but a few key factors determined during the course of this study will help staff at the City of St. Cloud build on their resources:
1. A primary barrier between the City of St. Cloud and the East African Food Establishment community is misunderstanding basic food safety principles identified during routine food inspections due to a language barrier.
2. The lack of translated educational materials and resources provided by the City of St. Cloud has been identified by the East African Food Establishment community as a missing connection to ensuring the Person-in-Charge and CFPM have the resources necessary to meet the Minnesota Food Code (State of MN, 2019) requirements.
3. As most East African Food Establishment owner/operators are the CFPM, Person-in-Charge, and often the only employee of the food establishment, the availability of translated materials, translation services, and translated educational opportunities available in alternative formats provides increased opportunity for compliance efforts.
4. The City of St. Cloud Health and Inspections Department has utilized available grant funding and partnerships to address language barriers. Based on the success of previous efforts, the City of St. Cloud should continue to seek community support and funding and host events that build community relationships to aid in eliminating communication barriers.
Recommendations
As the City of St. Cloud continues to evaluate the data presented in this project and the feedback from the translated training, continued efforts to provide similar training opportunities as well as alternative educational materials should be considered in aiding compliance efforts for this community. The City of St. Cloud should consider offering translated training materials online, accessible via the website, as well as handouts with pictures.
Outreach from the Department to the community was expressed as a need and a welcome opportunity to share information regarding available trainings and educational opportunities. The City of St. Cloud should continue to offer the free or discounted translated CFPM training opportunity, and also offer educational credit opportunities which CFPM’s can attend to earn and maintain their certification. Not only does this provide an opportunity to gain compliance with requirements of the Food Code, but it provides non-regulatory opportunities for community engagement as well.
Finally, it is recommended that City staff use the standardized methods of marking violations related to the Person-in-Charge and CFPM, while also applying alternative means to ensure compliance. Through routine monitoring of these specific code sections and violations marked in association, alternative corrective action measures may provide an opportunity for continued compliance. By utilizing the proposed educational opportunities and tools to further educate onsite—as well as sourcing translation services when necessary—the city may measure performance efforts through future inspection data.
Acknowledgments
The success of this project was in large part due to the partnerships made while executing the research. Funding for the Certified Food Protection Certification course was made possible by the Association of Food and Drug Officials small projects grant for retail food programs and sponsorship by the Initiative Foundation. The training was hosted and translated by Farhiya Farah, consultant and lead researcher with Globe Glow and Department Head of St. Mary’s University in Minneapolis. Data collection and execution of the training could not be done without help from the staff in the Health and Inspections Department at the City of St. Cloud. Finally, the project was made possible by the supportive restaurant community within the City of St. Cloud.
References
At-a-glance information about St. Cloud. (n.d.). Minnesota Compass. http://www.mncompass.org/profiles/city/st-cloud
City of St. Cloud. (2021). Demographics: St. Cloud, MN - Official Website. Site ID. https://ci.stcloud.mn.us/1261/Demographics.
Official Publication, S. of M. (2019). Office of the Revisor of Statutes. 4626 - MN Rules Chapter. https://www.revisor.mn.gov/rules/4626/.
[1]There are three defined priority items which delineate the inherent risk of each application listed in the code. These three priority items are considered the same as FDA’s – “Priority designation,” “Priority foundation designation,” and “Core designation.”
[2] High-Risk Establishment in brief means an establishment that sells TCS foods with extensive preparation, food preparation hours or days prior to service, a special process, foods commonly associated with foodborne illness, or pulls water from a non-potable supply.
Medium-Risk Establishment in brief means serving a TCS food with a minimal holding time between preparation and service, serves foods that requires extensive handling followed by heat treatment, and serves food that requires moderate preparation.
Author Note
Emily Herbst, Assistant Health Director
City of St. Cloud
This research was conducted as part of the International Food Protection Training Institute’s Fellowship in Food Protection, Cohort IX
Correspondence concerning this article should be addressed to:
Emily Herbst, City of St. Cloud Health & Inspections Department,
400 2nd Street South, St. Cloud, MN 56301
Emily.Herbst@ci.stcloud.mn.us
*Funding for this statement, publication, press release, etc., was made possible, in part, by the Food and Drug Administration through grant 5U18FD005964 and the Association of Food and Drug Officials. Views expressed in written materials or publications and by speakers and moderators do not necessarily reflect the official policies of the Department of Health and Human Services; nor does any mention of trade names, commercial practices, or organization imply endorsement by the United States Government.