communicating with industry for a safer pima county - chf… · uses the “3 legs of the stool”...

from Consumer Health and Food Safety in Pima County

NEWSLETTER

APRIL 2018 • Issue 2

Communicating with industry for a safer Pima County

Prsrt StdUS Postage

PAIDTucson, AZ

Permit #2216

5086-041118-RTP HT

NEWSLETTER from Consumer Health and Food Safety in Pima County

APRIL 2018 • Issue 2 •

Pima County Health Department’s Consumer Health & Food Safety (CHFS) Program monitors over 8,500 permitted facilities and an additional 3,114 temporary and special events each year, requiring over 17,000 indi-vidual inspections. The program each year also records and investigates more than 2,000 complaints that require timely inspections. The combination of all those responsibilities requires a concerted commitment by CHFS staff in order to reduce the risk to members

of the public who frequent, restaurants, retail food stores and temporary events or swim in recreational waters, stay in hotels/motels or live in mobile home parks. There have been some chang-es over the past few years with a new Food Code and our effort to improve health and safety. To enlist the aid of our many community partners, CHFS has developed an incentive program that will offer food service operators who participate an up to 25 percent reduction in the cost of annual permit fees and creating a safer Pima County.

CHFS also will look for ways to con-tain Health Department costs through technology. Moving forward, our inspectors will use handheld computers running the innovative Hedgerow soft-

ware system and capable of providing electronic copies of all inspections and automatically populating our databas-es and thus eliminating duplications necessary in the current paper and pen mode of inspections. This “win-win” opportunity also will provide educa-tional materials, code cross references and the ability to track our efforts to provide innovative programs. Reports will be typed and food service operators no longer will have to strain to under-stand some inspectors’ handwritten comments. The new software not only will be used in CHFS’s permitted facili-ty program but also by vector control to further contain costs.

It is our goal to have the system “Go Live” by the start of the Fiscal Year on

Important updates for 2018!From the desk of David Ludwig

Staff is responsible for conducting routine/complaint investigations of the roughly 2,500 permitted pools/spas.



July 1. New programs will include a promotional means to advise the public when an operation is participating in the various incentive programs further protecting their customers.

Another new feature of the program will be an award system highlighting inspection trends that will be posted on individual permits. It will visibly demonstrate to the public those estab-lishments that are truly multiple star

“Gold Award Winners.” In an effort to be consistent and fair to all opera-tors, the department will be rotating inspectors on a regular basis. Don’t be surprised to see a new face conducting inspections. Inspector training is being standardized to ensure all inspections are consistent and fair. If you ever have a problem, call a CHFS supervisor, but first review the health code to better understand the violation. The fact that

it was never written in the past is not a good excuse and it reflects that the department is in need of improvement. The Health Department’s delegated agreement with the State of Arizona requires not only that inspections are conducted but that all violations are included in written reports.

Here’s an overview based on the his-tory of inspections from 2016/2017 the award percentages would look like this:



In November 2017, I had a very good meeting with the Chief Operating Officer from the Arizona Restaurant Association. He asked a question con-cerning how the Department deter-mines Probationary Status and the fee associated with that process. When the County adopted a new Code in 2016, the terminology for the lowest-per-forming operations changed from “Provisional” to Probationary.” The fee for additional inspections remained the same: $190 after the initial decla-ration of probationary status; $380 for a second declaration. The County does not expect those fees to be a major source of revenue and inspectors will not have quotas to meet. Establish-ments are subject to Probationary Status when they experience five (5) or more Priority or Priority Foundation violations as governed by the Food Code. Additionally, if an establishment exhibits a Pattern of Non-Compliance where during the inspection three (3) items of Priority or Priority Founda-tion violations in the same violation number, (Foodborne Illness Risk Factors (items 1- 29) or Good Retail Practices (item 30-56)), during the past five (5) inspections (routine or follow up inspections) or if they have four (4) of the same Core violations in the last 6 inspections. It is essential that the operator take the appropriate action to prevent future violations of the same type by adjusting equipment, training staff or completing structural changes. It is essential that an operator takes the appropriate actions and gains long-term compliance. It is possible for an establishment to go into a Pro-bationary Status for five (5) or more items, have a re-inspection with all the items being corrected in 10 days thus coming off the Probationary status. If during the next routine inspection the establishment were to exhibit a pattern of non-compliance, this would result in a second Probationary status with the higher cost. I would suggest you review

all of your previous inspections and see if you have the same violation numbers on a repeat basis. If you do please take the appropriate action to protect your customers and your business from potential foodborne illness. My point here is not to alarm you, but to make you aware of the Probationary Status and assist you in providing a safer food supply.

Swimming Pool and Spa operators, in an effort to ensure recreational water safety we have instituted a train-ing program for all of our inspectors to ensure that they are following our delegation agreement. It is more than alarming to see the number of viola-tions being noted by our newly trained inspectors. Please note that like the food program, inspectors must evalu-ate each aspect of the code and for all items that are sub-standard, a written violation will be noted on the report. For items that are sub-standard for

structural issues (fence not meeting height requirements, pool depth not meeting swim lane standards, etc.) there is a clause that states if the pool was constructed according to code at the time of construction it will be al-lowed to exist without modification un-less there is a change of ownership or a remodeling has occurred. The violation would still be noted but if the operator is able to prove that it was constructed to code and they were the owner at time of construction no modification will be required. Pool fence require-ments of 5 and 6 foot were enacted in 1974. Should we find your pool has challenges in fencing, the department is giving operators six months to cor-rect. Other violations like unprotected drains and potential entrapment issues require immediate action and may re-quire temporary closure. If this is your slow season for your pool, now is the time to take the appropriate actions.

Computer generated inspector reports will be ellectronically sent to permit holders in the future

resulting in reduction of paper reports.



By Shelby Calvillo RS – Training Officer

We carry 100 trillion microorgan-isms in and on our bodies at all times. Among those microorganisms can be E Coli, Staph aureus, Shigella, Norovirus, Hepatitis A and the list goes on. Stud-ies have shown that handwashing has a 2 log reduction in microorganisms (meaning if you start with 2,000,000 organisms on your hands, washing your hands will reduce the number down to 20,000 organisms – unfortu-nately it takes only 10-100 organisms to cause certain forms of foodborne illness). So what is the best way to

reduce the risk? Gloves offer protec-tion from microorganisms we carry on our hands and bodies at all times, the physical barrier provided by the glove prevents organisms from being trans-ferred onto food items. Gloves should be worn whenever handling ready-to-eat foods. Ready- to-eat foods are foods that can be immediately served and are not going to undergo a temperature kill step, (high heat will kill organisms and that is why bare hand contact with food that will be thoroughly cooked is permitted). For example, a lemon for a drink garnish or a lettuce salad would be considered a ready-to-eat food while

raw chicken would not be. Alternatives to glove use can be items

such as tongs, skewers, deli paper, forks, etc. Whatever you want to use to prevent bare hand contact must ensure that your hand does not come into contact with that food.

You are allowed to bare hand some food items, but they must be things that will undergo a temperature kill step. For example, you are allowed to bare hand breadcrumbs when mixing them into ground beef for meatballs. Remember that whenever handling raw animal foods you must wash hands prior to switching tasks.

(Bare) Hands off Proper hand washing is the first line of defense in preventing foodborne illness.



Consequences of using bare hands to handle foods that will not undergo a kill step could include symptoms such as diarrhea, jaundice, headache, fever, etc. from the various bacteria and vi-ruses that we carry on our hands.

In September 2005, there were high reports of GI illness among rafters who went on trips on the Colorado River. Trace back occurred and found, in a processing plant, that a batch was contaminated from an employee who sliced deli meat with his bare hands one day after recovery from gastro-enteritis. Fecal and/or other body fluid contaminants from both sick or well employees are passed onto the hands and then onto the food. This also brings up a good point of employ-ee illness. Ensuring that ill employees do not return to work until the proper time has elapsed is another step to pre-vent further foodborne illness.

Poor personal hygiene and ultimate-ly foodborne illness can be prevented through proper training and ensuring your staff has the supplies to perform their jobs properly at all times.

Bare hand contact falls under the umbrella of personal hygiene. The FDA uses the “3 legs of the stool” approach when describing personal hygiene as it relates to food safety. In order to prevent foodborne illness from poor personal hygiene all three legs of the stool must be followed. The three legs of the stool are:

1. Employee illness- ensuring em-ployees do not work while ill

2. No bare hand contact and 3. Proper handwashing. All three legs of the stool work

together to prevent contamination from hands during food preparation and serving. The FDA has developed a health and hygiene handbook cover-ing the concept. Request a copy from your district sanitarian Environmental Health Specialist.

If you’re ever in doubt about when to wear gloves or not, it’s always safer

to wear them. A 20-second hand wash is required prior to donning gloves to avoid contamination and maintain the physical barrier. It is also important to remove the glove and dispose of it properly. Most gloves are single-use

and must be discarded after use. Do no not attempt to wash or sanitize single-use gloves. Page 6 - For any questions or to clarify any of the points made here please call Consumer Health and Food Safety at 520-724-7908.



Effective January 2018 the Pima County Health Department launched a new voluntary incentive program for food service facilities intended to im-prove public health and safety, reduce food insecurity in the community and help consumers make more informed choices while also mitigating increased fees for operations regulated by CHFS

that were approved in April 2016.There are four components of the

incentive program. Full participation entitles qualifying facilities to reduce their fees by 25 percent.

The following are components of the incentive program and their associated fee reductions:

• Active Managerial Control Plan:

10% Fee Reduction• No Trans-Fats on Menu: 5% Fee

Reduction• Caloric Count Displayed at Point

of Ordering: 5% Fee Reduction• Participate in a Food Bank Pro-

gram: 5% Fee ReductionTo qualify for each of these programs,

the owner or management of a facility

New program offers permit cost savings

Your management system can result in reduced annual permit costs.



must meet the criteria set forth by the Health Department. Each of the incen-tives requires different documentation. The Department requires confirmation of compliance before the annual fee will be adjusted. The following outlines the requirements for each of the incentive programs. Required forms are available online. To ensure complete review, documents must be submitted 15 days before the annual permit is due.

Below are more detailed breakdowns of each aspect of the program and the required documentation to qualify.

Active Managerial Control- 10% Fee Reduction

Documents Required:• Signed written agreement• Certified Food Protection Manager

Certificate• Written Standard Operating Proce-

dures (SOP’s) to prevent foodborne illness as applies to your operation, including but not limited to:◊ Employee health◊ Employee training◊ Handwashing◊ Food sources◊ Receiving and Storage◊ Cold holding◊ Cooking◊ Cooling◊ Reheating◊ Hot holding◊ Date marking◊ Cleaning and Sanitizing

To qualify for the Active Managerial Control fee reduction, a facility must show that they have a Certified Food Protection Manager on staff through providing a copy of their certificate. A list of certified courses can be found online.

The facility must also submit SOP’s

(Standard Operating Procedures) to prevent foodborne illness as listed above, as they apply to their operations. These SOP’s attempt to address the most commonly reported food-prepara-tion practices that contribute to food-borne disease according to the Centers for Disease Control and Prevention (CDC). The most common factors are improper holding temperatures (wheth-er at receiving, preparation, service, etc.), inadequate cooking of food, con-taminated equipment, unsafe sources, and poor personal hygiene.

No Trans-Fats on Menu- 5% Fee Reduction

Documents Required:• Signed written agreement• Itemized list of foods and their

ingredients and nutritional infor-mation



To qualify for the eliminating Trans fats fee reduction, a facility must provide the itemized list of foods and their ingredients and nutritional information. This list will be returned after review for the facility to keep on site and update as they modify items on their menu. If an inspector finds the facility to be out of compliance during an inspection, the facility will not qualify for the reduction at the time of their next permit renewal. To

reapply for the reduction when eligi-bility returns, the facility will have to provide documentation that they have removed the items with trans fats in them and replaced those items with alternative foods that do not contain trans fats.

Caloric Count at Point of Ordering- 5% Fee Reduction

Documents Required:• Signed written agreement

• Menu Item Caloric Count form• Copy of menu with caloric countsTo qualify for the caloric count at

point of ordering fee reduction, a facil-ity must calculate the calories in each of its menu items. These items must include not only the items found on the menu, but any beverages and items such as bread or chips and salsa served to customers when they are seated. This information must be submitted to the Department on the Menu Item

Figure 1



Figure 2

Caloric Count form along with a copy of the facilities menu with the caloric counts of the food items available. If the menu is a menu board and there are not individual menus available, a facility can submit a picture of their menu board with the caloric counts visible.

Directions on how to complete menu item form:

In order to provide an accurate calor-ic count for each menu item, the items

must be broken down into specific ingredients. For example, a cheese-burger must be broken down into its different parts (bun, patty, cheese, lettuce, tomato, onions, etc.,) in order for the calories to be properly calcu-lated. Using a calorie tracker website is one easy way to see just how many calories are in each menu item. On the Choose My Plate website, there is a SuperTracker function that you can use to estimate the calories in your meals

throughout the day. You can search for the ingredients in your menu items by using the search bar and selecting the best match. (Figure 1)

You will have to add each ingredient to a specific meal so that you can see your total calories when you have add-ed all of your ingredients. An example is shown below (Figure 2). You can see that the total caloric amount is 553 calories for a hamburger with all of its ingredients.



Figure 3

An example for a macaroni dish is shown below. (Figure 3)

Once you have calculated all caloric counts for the items on your menu, you are ready to submit your paperwork for approval. Ensure that all items are accounted for on the menu, even sides and beverages. If you offer an appetiz-er that is not on the menu, please note that on the Menu Item Caloric Count form.

Participate in a Food Bank Program- 5% Fee Reduction

Documents Required:• Signed written agreement• Donation form with intended

organizations To qualify for the reduction based

on donating food items to a food bank or similar program, a facility must indicate what programs they are plan-ning to donate the food items to. The first year the owner or management of the facility is required to sign the written agreement form that indicates

where they will be donating the food items. The donation form must then be kept on site where an inspector can review it during their inspections to ensure the facility is still meeting the criteria of the incentive. If the facility is not meeting the criteria, they will not qualify for the reduction on their next annual permit. To reapply for the reduction when eligibility returns, the facility will have to provide documen-tation that they have been donating food to a food bank or similar organi-zation during the previous year.