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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.