Tag : Digital Record Keeping

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An Open Letter to the FDA & the National Restaurant Association in regards to Digital Record Keeping

Digital Record Keeping In Restaurants is Coming

It has been pretty widely known in the restaurant industry over the last couple of years that digital record keeping is going to be mandated for restaurants in the near future, it just makes sense.  The biggest bellwether of this impending change was FSMA, the Food Safety Modernization Act, which requires extensive digital record keeping for food service manufacturing facilities. I was speaking with a consultant and friend of mine, Scott Turner, who is a FSMA consultant and he was telling me that they originally wanted to combine the Food Code and FSMA into one standard for all food service manufacturing and restaurants, which would be the efficient and smart thing to do by the government, but hasn’t been implemented yet.

In September I attended at the Colorado Restaurant Show that is hosted by the Colorado Restaurant Association. At that show, they had a speaker from the National Restaurant Association who was the VP of State and Local Affairs. Basically, he is the chief lobbyist for the NRA in DC on State and Local issues that could affect the restaurant industry.  I spoke to him after his presentation and asked specifically about the digital record keeping mandate. He said that they were expecting the official conversations to begin in 2019, which is the midpoint of the 4-year food code cycle, and that we probably would see something in 2021 which is the next release year.

The question is; what is digital record keeping in restaurants going to look like and how should it be done?

We at OpsAnalitica are on the cutting edge of this issue and have a ton of experience with digital record keeping and food service operations for both the BOH/FOH and we have formulated our own approach to how this should be implemented across the industry. We call it Criticals First.

Let’s start with a quick review of where we stand today from a digital recordkeeping perspective.

The FDA publishes the Food Code, which is basically the Federal Governments guidance on best practices around food safety in restaurants and food service establishments every four years. The last release was 2017 and the next one will be 2021. Every 2 years in the cycle they make updates and start conversations around where the Food Code is going.  The Food Code is not mandated for every food service establishment in the country, it is the best practice. States and ultimately counties have the final say of what is the food safety standard for their jurisdictions. Basically, the states and counties review the food code and use what they want in their areas.

Let me preface this next statement, 99% of the time I’m not for more federal government regulation. Food Safety regulation is an area where a lot of money could be saved by foodservice operators and the government if there was 1 federal standard for food safety across the entire country.  We have national chains that are operating in almost every county in the country and in some cases have different regulatory standards county by county in the same state. You could run two restaurants in two different counties that are literally a couple of minutes from each other and have completely different record-keeping standards. Food safety is too important and there should be one standard across the entire country that all establishments are required to adhere.

The food code doesn’t currently mandate any food handling safety procedure or digital record keeping. They suggest that restaurants create and follow a HACCP program. In the Food Code, they state that one of the reasons that there isn’t a mandated HACCP standard for all restaurants in the country is that it would be a burden on the independent operators who might not have the sophistication and resources to create and manage a full HACCP implementation.

I tend to agree that not every restaurant needs a full HACCP plan and that varies by the type of food they are serving. Where I break from the food code is that there should be a national standard of mandated food safety checks and ops checks every meal period in every location no matter if you are a national chain or an independent restaurant. Those checks, which we’ll get into more detail on below, should be recorded digitally and reviewed by health inspectors during health inspections. There should be huge fines for not completing those checks regularly and being able to provide that information. I would go as far as saying that you should fail your health inspection for not completing food safety checks and documenting your results.

The public is relying on the government’s annual health inspections to ensure that food service establishments are operating safely. The reality is that restaurants get people sick all the time, check out Iwaspoisoned.com. There are systematic roadblocks for reporting foodborne illness, like the requirement of a doctors diagnosis that keep these issues underreported.

Also, health inspections happen so infrequently that restaurants often go months at a time without seeing an inspector, in  San Francisco, it was reported a few years ago that due to a lack of inspectors restaurants were going 18 months between inspections. My point is this, the public thinks the government is regulating this better than they are able to and the responsibility for food safety is squarely on the shoulders of the operators.

The only way inspectors can ensure that restaurants are running safe operations between their inspections is to have the operators conduct their own checks on a daily basis and record their results. The system breaks down if the health inspectors are unable to verify that those checks are being completed on a daily basis accurately. Food service establishments operating safely and checking their own operations daily is the first line of defense against foodborne illness (this doesn’t address ready to eat foods that are contaminated in the manufacturing process).

Let me wrap up what is currently happening with this last thought. As a customer, I don’t care if you are a mom and pop or a national chain, I want my food to be safe and I expect that you are checking your food safety operations every shift. You don’t get on a small plane and think it’s ok if they didn’t check the engine and the wings because it’s not being operated by a major airline, hell no, you expect small and large operators to follow the same safety standards.

OpsAnalitica’s Criticals First Approach

Every health inspection in the country has critical and non-critical items that the inspector is looking for, they generally contain but are not limited to:

  • Temperature control: Hot/Cold Hold, refrigeration, time controls, cooling procedures
  • Sanitation: Dish machine rinse temperature/chemical ppm, sanitizer buckets, no cross contamination, sanitary conditions
  • Storage: making sure products are being stored correctly
  • Rodents/Pests: no infestations
  • Foreign Contamination: no chance of foreign objects getting into food like dust or paint chips

The Criticals First approach we are recommending is to create checklists and logs for every location that are executed every meal period that focuses on the critical items in that operation. Checking temps of your refrigeration and your line items. Making sure sanitizer buckets and your dishwashing facilities are operating efficiently, doing a quick walk around to ensure that there is no cross contamination and that all of your products are being handled safely. These are the basic things that every foodservice operator is already expected to be doing every shift anyway.  This isn’t new and this isn’t rocket science.  The only thing we are adding is that operators should have to record these checks every shift and store them digitally to meet the future mandate for digital record keeping.

Restaurant operators should look at their current health inspection standard, identify the critical violations, create their checklists and start recording that data today. Health inspectors should take a crawl, walk, run approach with operators, especially independents and work with them to get their checklists and logs finalized to meet the counties standard. Once finalized, health inspectors should hold operators accountable for completing these checks every meal period because this is how we are going to ensure that restaurants are taking their food safety responsibility seriously.

As you can see this is a pragmatic approach to mandating a national food safety standard that takes into account the different types of operations. Now let’s talk about some standards of a good digital recordkeeping platform.

  1. Every record should be time/date stamped and that time date stamp should not be able to be tampered with.
  2. There should be a checklist duration captured, this will help identify if people are pencil whipping and not being forthright with their inspections.
  3. You should not be able to edit answers to questions after they have been submitted.
  4. It should be able to require comments and photos – to get more information.
  5. There should be adequate reports so that an inspector can see how an operation has performed over time both in the completing of their checklists but also to be able to identify individual issues over time.
  6. The system should be able to grant regulators access to reports and data without an account.

Taking a Critical First approach to mandating food safety procedures and requiring digital record keeping will not be an extraordinary burden on the food service industry. If implemented as we have described in this blog, it would be formalizing what food service operations are already expected to do.  Recording these activities digitally so they can easily be reviewed by inspectors is just adding that level of accountability that is currently missing from the system.

This is a pragmatic approach to increasing food safety across our country and providing restaurant patrons with an added layer of confidence and protection from foodborne illness.

P.S. two random thoughts

If you are a food service operator, you should make the move to digital record keeping today, because it is the right thing to do. Also, you should get locked into affordable pricing now, as soon as this is mandated you will see the prices increase dramatically because the providers, we included, will be able to charge more and you will have to pay it.

I predict that digital record keeping will happen nationally before 2021. When conversations begin in 2019, that will clue one of the big liberal states like California or New York, who enjoy setting the regulatory standards across the country to mandate digital record keeping in their states. Once that happens, the top 200 chains will have to adopt a strategy around digital record keeping immediately and they will implement it across their entire system vs. managing two processes.  Once the top 200 go, there will be no one with lobbying money fighting against this and therefore the country will move to this standard very quickly.

Thanks for reading and let me know what I missed and where I’m way off.

Everyone has a Letter Grade in Their Window Now

If you haven’t heard yet, Yelp is now displaying health inspection scores on your restaurant page. Which means, every restaurant in the country could have a health inspection letter grade in their online window. Make sure you read the whole blog as I put together a list of things all restaurant operators should start doing in regards to this move by Yelp.

There is a great Forbes Article entitled Yelp To Display Health Inspection Ratings On Restaurant Pages Nationwide that I encourage you to read. To save you a little time I will summarize the big bullets from the article below:

  1. Yelp will be posting your Health Inspection Score on your business page.
  2. They plan to have 750,000 health inspection scores posted by the end of the year. There are about 1.1 million food service establishments in the US.
  3. They are getting the data from local governments and a startup named HDScores.
  4. HDScores has 1.2 million scores in 42 states
  5. Yelp gets 30,000,000 unique mobile visits a month, 50% of those are restaurant searches.
  6. “A Harvard Business School study, in collaboration with Yelp and the City of San Francisco, found that displaying restaurant hygiene scores on Yelp led to a 12% decrease in purchase intentions for restaurants with poor scores compared with those with higher scores.” – Forbes Article

What does all this mean to restauranteurs? It means that you have to actually take Yelp and your restaurant’s cleanliness more seriously than ever before because not doing so could affect your revenues and profits.

A lot of operators have scoffed at Yelp reviewers and Yelp the company for years. Thinking that every bad review was a competitor trying to steal your business or some snobby know-it-all that thinks they are a professional restaurant critic.  In addition, Yelp hasn’t always been the best corporate partner, accusations of review placement manipulation and strong-arm advertising tactics have been lofted at the site.

The fact is this, by posting health inspection scores, Yelp just made itself more relevant for restaurant patrons than it ever was before. With Yelp displaying health inspection scores, right next to customer reviews, pertinent data about the business, links to making reservations, and links to the menu. Most savvy customers are going to look at Yelp before they even visit the restaurant’s website.  Because the restaurant’s website isn’t going to advertise that they got 70% on their last health inspection, but it will be right there for the Yelp customer who is reviewing your Yelp page.

At first glance, Mr. Mike’s 3 stars and captioned reviews would not stop me from trying this restaurant, Their 58 out of 100 health score would. 

One thing restauranteurs have to acknowledge is that patrons have always cared about restaurant cleanliness, they want to eat in clean restaurants that serve safe and delicious food.  In the past, there was never an easy way for them to add health inspection scores into their decision-making process because it wasn’t easy to get them.

Now that this information is available, look at bullet point 6 above – a 12% decrease in purchase intent for low hygiene scores, you better believe that it will enter into their decision-making process. If you have a low Yelp star rating and a bad health inspection score, you could be in real trouble.

Another thing to consider with Yelp posting health inspection scores, it’s going to be a flawed process. HDscores and Yelp are dependent on county health departments to provide them with the inspection data. Each county is staffed differently and they all have different procedures for handling health inspections, critical violations, scoring, reinspections, etc..

In some cases, a restaurant might get a bad health inspection score with a lot of critical issues but they might correct all critical violations while the inspector is on site. They have a low score but have fixed their issues and are technically safe for business, it won’t matter because the low score is what is going to be recorded by the health department.

Another nightmare scenario for restaurant owners, you get a bad health inspection score and can’t get reinspected for 90 days because the county is backed up. Who knows how many times HDScores or Yelp query the health department databases to update their info or how quickly the health departments get their data updated from their inspectors? All of these time lags could affect how long a bad score stays up on Yelp’s website.

Normal people outside of the food service industry don’t understand the nuances of health inspections and they don’t care. Click here to see a summary of the health inspections for Mr. Mike’s above, I got to this page by clicking on the Health Score link right next to their health score on their Yelp page. The general public isn’t sanitarians and won’t know why bumpy surfaces on walls or the lack of a thermometer could be huge issues.

The general public assumes that all health inspections are equal, they are fair, and that they happen in a timely manner. They trust that the health inspector is looking out for their best interest and they are willing to believe them. My point is this, you aren’t going to be able to educate the general public on the in’s and out’s of health inspections and defend a bad score, they could care less about all the injustices in this system, they are just not going to eat at your restaurant.

The only way to make sure that these health inspection scores don’t hurt your business is to get A health inspection scores every time. The only way to do that is to implement basic sanitation and food safety programs in your restaurants and hold your teams accountable on a shift-by-shift basis to following those procedures so you are 100% ready for every health inspection.

For years, we at OpsAnalitica have been preaching for an increased emphasis on food safety, restaurant cleanliness, and increased hygiene. To be honest, this messaging has never worked for us. Restaurant Operators haven’t been reaching out to us saying, help make me safer so I can protect my customers and my brand. The reason why is because, before this move by Yelp, a bad health inspection score didn’t affect most restaurants in the country. You got inspected maybe twice a year and probably corrected most issues while the inspector was on-site. The score wasn’t posted anywhere that your customers could easily find, only a few jurisdictions post letter grades in the window, so a bad score didn’t affect customers perceptions of the restaurant. That has changed.

Here are some steps that restaurant operators need to take immediately to ensure that their restaurants aren’t negatively affected by their Yelp Rating and Health Inspection Score.

Yelp:

  1. Claim your Yelp page. An unclaimed page makes it seem that management is disengaged from its customers.
  2. Respond to good reviews by thanking the customer for their patronage.
  3. Try to contact customers that wrote bad reviews and handle customer complaints that show up on the site within 24 hours. This shows that management cares about its customers. Offer restitution for angry customers in exchange for getting them to remove or amend their reviews to show that you addressed their issues. Some people will abuse this, but in the long run, it is better to not focus on the negative scammers but to focus on wowing every guest that comes to your restaurant and to protecting your Yelp Reputation.
  4. Flood Yelp with good reviews of your own. Incent customers to review your restaurant on Yelp to ensure that you get a high star rating. Hand out cards with a shortened URL to your Yelp page or send an email with a link for a review. Offer a free dessert and have an iPad in the store, have them check-in and give you a good review and then buy them a piece of pie or cake. Every Yelp star is worth a potential 5 to 6% increase in sales. My guess is that sales stat is lower for chain and franchise restaurants but now that Yelp is showing health inspection scores, I will bet that those restaurants will start getting searched more.
  5. Accept that Yelp is a necessary evil and that it adds value to you and your customers. They provide guests with a way to learn about your business and communicate with you about their experiences in a more open way than you typically get from a one-on-one interaction or a guest satisfaction survey. In addition, they provide you with a free business web page that is on one of the most searched websites in the world. Search your restaurant and I guarantee that your Yelp page will be prominently featured on page 1 of your search results.  According to the Forbes article, Yelp is the 25th most visited website in the US. I’ve said this before many times, I was a traveling consultant for years, I used Yelp all the time to find restaurants in the cities I was visiting, I’ve never had a bad experience at a 5 star rated restaurant that I found on Yelp.

Better Health Inspection Scores:

  1. The only way to ensure that you are going to get A’s on your health inspections is to run an A restaurant every day.  It’s not hard to do and it is what you should be doing.
  2. There are two major components to running A restaurants. Proper Procedures and Execution. Most chain restaurants have food safety procedures in place and that doesn’t guarantee that they will get an A.  Procedures aren’t enough you have to hold your team accountable to executing on those procedures every shift.
  3. If you have procedures in place focus on execution. Focus on getting your teams to follow your procedures every shift in every location. It is better to focus on high compliance for a couple of critical checklists than to try to get low compliance on a lot of checklists and procedures. High compliance on critical checks!!!
  4. If you don’t have procedures in place at this time, take critical items first approach.  Look at your local health inspections, identify the critical violations, and build procedures that check those violations every shift. If you just focus on critical violations, you will run better restaurants and you will ensure that you are not going to get dinged on an inspection.
  5. Ditch the paper. Most companies still use paper checklists, you can’t get any accountability on paper checklists. You don’t have any visibility into whether or not your procedures are getting completed if your teams are doing them accurately, or that they are identifying critical violations.  Running restaurants using paper checklists is harder than it needs to be for managers at all levels of the operation. Using a digital checklist platform, like OpsAnalitica, can provide you with effortless accountability, real-time notifications, and digital record keeping of your safety procedures.
  6. One more note on ditching the paper, digital record keeping is coming to restaurants. It has already been mandated for food manufacturers and everyone is expecting that it will be implemented by the government in the next 1 to 3 years. If you are looking to focus on execution, run better restaurants, get an A on your next health inspection, and be ready for the future, you should look at moving from paper to OpsAnalitica, a digital record keeping and shift readiness platform.

Yelp has made itself more relevant than ever by posting health inspection scores on their site. I predict that this is going to change how people decide which restaurants they are going to visit by putting more emphasis on food safety, which is good for consumers and ultimately good for the industry. For restaurants to be competitive and to not have their health inspection score affect their sales, they are going to have to focus on cleanliness and food safety as core values of their operations because if they don’t their failure is going to be on their Yelp profile.

One of the core values of the OpsAnalitica Way, our guide to multi-unit operations, is control what you can control. Restaurant operators need to realize that they are in complete control of what happens in their four walls. Food safety and clean restaurants aren’t just under their control they are their responsibility to their customers and their brands.

We know that this is going to be an imperfect process and a lot of restaurants are going to get hurt in the short term as they get bad health inspection scores and those scores stay on their Yelp profile longer than they should due to inefficiencies between all the parties involved.  This is going to sound like a jerk thing to say, I don’t care. I don’t care one bit. Don’t have dirty restaurants, that is what we should be focusing on.  Focus on being great and doing what you are supposed to do and this change will not affect you at all and may even help increase your sales.

One last prediction, I bet that Yelp will see an increase in monthly restaurant traffic over the next 6 to 12 months because of showing Health Inspection Scores.

If you want to learn more about the OpsAnalitica Shift Readiness and Digital Record Keeping platform, please go to OpsAnalitica.com.

Good luck