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Document, Document, Document, everything you do around COVID-19

If you don’t document it, it didn’t happen.

The FDA has recently stated that restaurants should start Pre-Screening their employees and taking their temperatures to determine if the employee is safe to work that shift.

This is an update to current ADA procedures Section 501. This guidance was updated because of the COVID-19 pandemic. I fully expect that this will change when we come out of this pandemic as it did after the SARS pandemic in 2009.

The immediate question is how should you undertake the pre-screening of employees? The larger question is what else should I be documenting around my COVID-19 response.

I’m going to argue that you document all of it.

A lot of you are sighing out loud right now because documentation is boring and a pain in the butt.

Documentation, especially when using a checklist, or checklist program, is very easy to do, because completing a checklist is self-documenting.

I’m growing increasingly concerned that COVID-19 is going to spur a lot of legal actions in the near future. I believe we are not seeing these legal actions today because of the following reasons:

  • We are all being asked to stay home and self-isolate.
  • We are in the middle of the outbreak and there is no way to figure out where or whom you got COVID-19 from.
  • These new guidances, pre-screening of employees, is brand new.
  • We haven’t had a chance to see how the negative pre-screen of an employee that is sent home for being ill conflicts with some of the more restrictive labor laws that you see in places like Seattle and California.
    • Those will probably be decided in the courts in the next couple of months.

Soon, in the next couple of weeks/months, as we are released from this mandatory self-isolation. We are going to be out and about again and the COVID-19 virus is still going to be very active.

Part of the strategy moving forward to deal with people infected with COVID-19 is going to be the practice of testing, self-isolation, and contact tracing.

I literally heard Dr. Fauci on the daily White House press conference yesterday talking about contact tracing. He was stating that the government will release the stay at home orders when:

  • When the virus is not as active in an area
  • When they have the medical supplies and hospital bandwidth to handle an outbreak.
  • When they have the contact tracing system in place.

Here is a description of Contact Tracing from the World Health Organization. A quick summary of it, is that when you get tested positive for COVID-19:

  1. Contact Identification: the government asks you to identify all the people you have been in contact with and places you have gone.
  2. Contact Listing: Identified contacts are added a list and contacted about their exposure to you. They are asked to take the appropriate medical steps.
  3. Contact Follow-up: people are tracked for symptoms etc..

Once we enter this phase of our COVID-19 response and absent any new laws that state you can’t sue a person for spreading COVID-19, which I don’t know if we’ll see, people are going to be able to trace back where they got COVID-19 from. There will be epicenters at places/events or it will be traced to people who infected a lot of other people.

If you want to see something chilling check out this Reuter’s article about patient 31 in South Korea.

I think once people can assign blame for getting COVID-19 and quantify their financial losses from being isolated or medical bills. I believe we’ll start to see a lot more law suits around this stuff.

So that is why I’m very much in support of self-documenting your COVID-19 procedures to help protect your business from potential litigation. This can be accomplished by creating checklists and forms to use in your business highlighting your procedures.

Also, remember that with any new process or documentation strategy, consistent execution will always show your commitment and due diligence. It is better to do something less times a day but to do it consistently than to require it be doe more times a day and not have 100% compliance.

Now let’s be clear, my assumption in all of this, is that you are doing the right things to protect your customers, employees, and your brand. If you are and you are documenting those steps as well, it could potentially help you in any kind of government review or legal action.

I’m not a lawyer, if you are concerned you should contact yours, but this just seems logical to me.

How can OpsAnalitica help you with this documentation?

The OpsAnalitica Platform is the ultimate Restaurant Operations and documentation platform. Our goal is always to do the following:

  1. Take the guesswork out of any process.
  2. Guide the employee through the process and identify in real-time any remediation actions.
  3. Act as a self documentation platform, storing all completed checklists digitally for review.
  4. Notifying management when a process has not been completed or critical violations were detected.

We have created an Employee Health Verification Process that you can use to document your employee COVID-19 Pre Screen questionnaire including the taking of temperatures. Also, we have a Sick Employee and Customer incident forms that you can use to record the actions your took when you identified either a sick employee or customer.

All of these forms are fully customizable and available for free through May of 2020, no strings attached. In addition, we will set your organization up for free so you can take advantage of this system immediately.

If you have any questions or would like to learn more about the OpsAnalitica Platform, please initiate a chat in the bottom right hand corner of the screen.

The FDA Has Stated that you Should Take Employee Temperatures Before Their Shift

We have created a Free Employee Health Verification Process that you can use to Pre-Screen your employees. Check out this short video describing the process.

https://www.youtube.com/watch?v=0iuAyTN5wU8

Here is the link to the FDA Site, you should visit this page because it has tons of secondary links to CDC guidance on everything you need to know right now.

FDA is stating that they want you to start Pre Screening employees before their shift. This should include taking the employee’s temperatures and to ask them some questions about their potential exposure to COVID-19 and how they are feeling.

Quick Tip: do this by the door, limit the employees access to the restaurant until you verify they are fit to work. If they are sick, it will be a lot less for your to disinfect.

OpsAnalitica has created a Free Employee Health Verification form that manages the Employee Pre-Screen process. If you want to start using this at your restaurants, please initiate a chat in the bottom right corner of this screen. We are making this available for Free through May.

The Number 1 Factor For Reducing Critical Food Safety Violations is…

The number one factor for reducing critical food safety violations is…

Implementing a Food Safety Management System (FSMS) with daily Active Managerial Control (AMC)

The following is from the FDA REPORT ON THE OCCURRENCE OF FOODBORNE ILLNESS RISK FACTORS IN FAST FOOD AND FULL-SERVICE RESTAURANTS, 2013-2014 Prepared by the FDA National Retail Food Team 2018

Here are my conclusions from the study so you don’t have to read the whole thing

  1. The number 1 factor that predicts less food safety violations, in both Fast Food and Full Service restaurants,  is a well developed, documented and executed daily Food Safety Management System (FSMS) that drives Daily Active Managerial Control (AMC). 
    1. FSMS were the strongest predictor of data items being out-of-compliance in both fast food and full-service restaurants: those with well-developed food safety management systems had significantly fewer food safety behaviors/practices out of compliance than did those with less developed food safety management systems.- Page 39
  2. That the presence of Certified Food Protection Manager (CFPM) on staff positively correlates to having a better FSMS but doesn’t replace an FSMS.
    1. However, upon multi-factor regression, the correlations between certified food protection manager and out-of-compliance become non-significant, indicating that food safety management systems and not the presence of a certified food protection manager predict compliance with food safety behaviors/practices. – Page 40
    2. In fast food restaurants with a CFPM who was the person in charge at the time of data collection, the average FSMS score was 2.645, while the average score for fast food restaurants with no CFPM employed was 1.822. In full-service restaurants, scores were 1.842 and 1.348, respectively. This suggests that having a CFPM present at all hours of operation enhances food safety management systems and reduces the number of out-of-compliance food safety behaviors/practices. – Page 40
  3. If you don’t have a CFPM working every shift, then you might as well not have one at all.
    1. In fact, having a CFPM who was not present was almost no different than having no CFPM at all for the out-of-compliance food safety behaviors/practices evaluated in this study. – page 40
  4. The types of Jurisdiction the restaurant resides in and whether the health inspections that you receive are: Scored/Not Scored, Publicly Available/Not Publicly Available, or that Employee Food Safety Training is Required/Not Required didn’t affect the scores of the Fast Food or Full-Service Restaurants. This makes sense as health inspections only happen a couple of times a year. The quote below is for full-service restaurants but they stated similar conclusions for fast food restaurants
    1. Full-service restaurants located in jurisdictions that graded establishments did not have significantly different results (p = 0.0819) compared to full-service restaurants located in jurisdictions that did not grade. Establishments located in jurisdictions where there was a requirement to make inspection results public did not have significantly different compliance (p = 0.6820) than establishments in jurisdictions that did not require reporting. Establishments in jurisdictions that required food handler training did not have significantly different compliance (p = 0.0626) than establishments in jurisdictions that did not require food handler training. – Page 30
  5. Of the foodborne illness risk factors investigated in this study, restaurants had the best control over inadequate cooking. There remains a need to gain better control over improper holding/time and temperature and poor personal hygiene. Page 39
  6. Multi-unit operators had significantly lower instances of out-of-compliance items compared to single unit operators. Page 26 This was true for both Fast Food and Full-Service Restaurants.

In layman’s terms, you have to have food safety procedures for your restaurants daily operations, you have to train your team on how to follow those procedures, most importantly your managers have to complete daily monitoring activities (via checklists, logs, and/or IoT) to ensure that you are identifying and fixing any issues that you find in real-time.

Here is my shameless self-promotion:

  • The OpsAnalitica Platform is the backbone of any good Food Safety Management System. It provides your teams with access to Procedures, Training, and Monitoring functionality in real-time customized to every location and is the foundation of a well developed and documented FSMS. Please click here if you would like to learn more about our platform and how we can help you set up your FSMS. 
  • Time and temperature control was the number one food safety issue identified for both full-service and fast food restaurants. The OpsAnalitica platform integrates with temperature sensors and with our proactive notifications we can alert management to critical food safety violations in real-time so that any problems can be fixed immediately before they affect customers.
  • I have been shouting these conclusions for the last 3 years to everyone in the industry via this blog and our marketing and sales efforts. It feels good to be backed up by this study but the fact that in 68% of Fast Food and 86% of Full-Service Restaurants that there was an observance of improper temperature control means that the status quo system of having paper-based food safety procedures that are largely pencil whipped with no accountability or above store visibility is failing. We as an industry need to take this stuff more seriously.

As food service professionals, we owe it to ourselves, our customers, and our brands to take the conclusions from this report seriously and implement FSMS and daily AMC into our restaurants.

As I mentioned in a blog a couple of weeks ago, we heard from one of the head lobbyists for the NRA that they expect the FDA conversations around mandatory digit record keeping in restaurants to begin in 2019 and would expect to see updates to the food code in 2021. I believe that the conclusions of this report play right into those initiatives for well documented FSMS programs.

Excerpts from the Study

The rest of this blog is going to be summarizing the report and displaying the most interesting charts and graphs from it.  I will try to do my best to make my opinions clear and differentiated from the findings. The above link is my blanket footnote for the information below as you can reference the original text at any point.

Purpose of the Study:

The purpose of each restaurant data collection during the current 10-year study period is to investigate the relationship between food safety management systems (FSMS), certified food protection managers (CFPMs), and the occurrence of risk factors and food safety behaviors/practices commonly associated with foodborne illness in restaurants.

Let’s define FSMS (Food Safety Management System)

FSMS refers to a specific set of actions (e.g., procedures, training, and monitoring) to help achieve active managerial control. While FSMS procedures vary across the retail and food service industry, purposeful implementation of those procedures, training, and monitoring are consistent components of FSMS.

AMC (Active Managerial Control)

To help prevent foodborne illness, the FDA Food Code emphasizes the need for risk- based preventive controls and daily active managerial control (AMC) of the risk factors contributing to foodborne illness in retail and food service facilities. AMC is “the purposeful incorporation of specific actions or procedures by industry management into the operation of their business to attain control over foodborne illness risk factors” (FDA, 2013). A food establishment’s achieving AMC involves the continuous identification and proactive prevention of food safety hazards.

Why are FSMS’s important?

Inadequate FSMS are thought to contribute to the worldwide burden of foodborne disease (Luning et al., 2008). For example, HACCP has been shown to have positive effects on food safety, but the poor implementation of HACCP has been described as a precursor to foodborne outbreaks (Cormier, 2007; Luning et al., 2009; Ropkins and Beck, 2000).

What is a CFPM (Certified Food Protection Manager)

A CFPM is an individual who has shown proficiency in food safety information by passing a test that is part of an accredited program (FDA, 2013a). Research has shown that the presence of a CFPM is associated with improved inspection scores (Hedberg et al., 2007; Cates et al., 2008, Brown et al., 2014). Hedberg et al. (2006) found that the major difference between outbreak and non-outbreak restaurants was the presence of a CFPM.

Table 3 describes how the team rated the risk of different food service establishments, they didn’t study any risk category 1 businesses.

Table 4 talks about what they were looking for in the study.

This next image describes the different scoring criteria for FSMS’s. 

The Results

Study Conclusions

 

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