PREVENTION IS THE BEST CURE

By Edward D. Engoron, President/CEO
PERSPECTIVES™/The Consulting Group, Inc.

One of your worst fears has come true. A guest has gotten ill eating food served or purchased from your restaurant, supermarket, convenience store, manufacturing facility, etc. Obviously, you must try to make it right for your guest, but you must also begin immediately to find out exactly what happened so you can determine the size and scope of the problem and prevent it from occurring again.

Most large foodservice corporations, including the big restaurant chains and quick service restaurants have entire Quality Assurance and Public Relations departments whose jobs are to respond to this type of emergency. One example is the E. coli 0157:H7 incident involving Burger King and Hudson Foods, where a Burger King task force was formed and met, uninterrupted for days, until all the facts were identified and decisions were made and action plans implemented to make sure another food safety problem would never arise.

Of course, having the right programs in place—and in practice—in your organization, such as clean rooms (to prepare, process and package your foods, especially proteins) and an active HACCP program (Hazard Analysis Critical Control Points) is vital to providing early warnings of potential problems. Establishing Good Manufacturing Practices (GMPs) and ensuring that your vendors employ operate at the same high standards is also very important. However, as the Hudson Foods incident showed us, mistakes do happen. It’s critical for you and your organization to be ready to investigate the cause of the incident and implement solutions to ensure that it will never happen again.

If you don’t have an in-house micro testing lab, our recommendation is to retain a reputable, third party, testing laboratory. This will have a two-fold benefit. It will result in having experienced professionals collect reliable samples with assurances of accurate test results. In addition, it will legitimize the results of the investigation by providing your guest and the public with the comfort that you are willing to allow a laboratory outside the direct control of your organization to conduct the testing. Unfortunately, the public today can be somewhat cynical. The use of the third party testing lab will help address that issue.

Another important aspect of the “search for the truth” is to have a key member of your team specifically accountable to work with the testing laboratory. This will ensure that your organization is fully involved; that you have a point person to address any issues and that all obstacles are removed for the outside lab to be able to best do the job for which you hired them. Lastly, it is critical that a senior team member from your organization always be available to review the data, listen to and evaluate the recommendations and to approve immediate implementation to prevent the incident from recurring.

Hopefully, you can either obtain a sample of the food your guest ate or there is a product remaining from the same batch. Testing of the final product will allow you to determine the severity of the problem. Your response may be very different in dealing with low levels of coliform—resulting in a mild stomachache—versus E. coli contamination, with the potential for much more severe illness. Once you know the cause of the illness you can then begin to determine how it happened and when and how your food became contaminated.

The process used to identify what caused your problem is not unlike detective work. The results are in the details. It is slow, meticulous work, requiring sampling of products, raw materials, equipment and packaging throughout the production and distribution chain. Often, the problems you have are coming to you from somewhere else, as was the case with Hudson Foods and Burger King. On the other hand, sometimes the problem can be traced back to your guest’s negligence in handling the prepared food product after purchase. We’ve all heard of the guest who left a prepared tuna salad sandwich in the back seat of their car for many hours and then ate it, getting a pretty good stomachache. This is especially sensitive as more time-stressed consumers want to eat on the run or bring dinner home from restaurants or food markets.

Educating the guest about proper product handling must be a critical component in any “to-go” program. Packaging graphics and/or stickers on the package should be used to communicate with the guest about the need to refrigerate the product and the temperatures for safely re-heating and serving their purchases.

How to get started? Well, as in anything else, start at the beginning. Thorough testing of all raw materials is the first step. If the guest became ill after eating one of your salads you should test every ingredient in that product. Although proteins are often the most obvious culprits, contamination can come from anywhere. We suggest testing unopened as well as opened bags and packages of every vegetable, block of cheese, turkey breast, etc. Unless you’ve tested every ingredient as far back in the distribution chain as possible, you will never be completely sure of whether your vendor had a role in this problem or not. Or, maybe, the bag that your pre-cut lettuce came in fell on the floor and into a puddle of raw beef or chicken juice. Sure, your employee may have thought they thoroughly washed the package and were very careful about transferring the lettuce to the mixing bowl, but it only takes a small amount of contamination to start a very big problem.

Once you have completed testing on all raw materials the next step is to check your production areas—surfaces of all bowls, utensils, cutting surfaces and equipment should be sampled with swabs. It may be that the throat of your mechanical dicer was not cleaned as thoroughly as your specifications indicate. Remember that human beings make mistakes, especially during times of high stress and pressure. As your business grows and your employees’ hours increase on the production floor, pressure builds. That’s when mistakes can happen. That’s another reason why it is always important to reinforce Good Manufacturing Practices with your team members—both tenured veterans and new recruits.

How about packaging? It could be that even with the best of intentions and segregation of packaging from raw materials, contamination occurs in or on the package prior to the finished product being packed. In that instance, even techniques such as gas flushing (as is sometimes used on chilled prepared meals) designed to retard the time it takes for the food to begin to spoil, won’t help. Again, it’s important to test everything in order to prove or eliminate a potential contamination source.

The final steps of the analysis and testing are a little trickier. They involve evaluation of product quality throughout the distribution system and during shelf life. This may be harder to pinpoint as the contamination may have been affected by poor product handling on a single day only. Often, once a product quality issue occurs all employees in the production and distribution system have heightened awareness of the impact they can have on food quality. At that time they are even more conscientious about adhering to GMPs. This may prevent you from discovering where an error occurred. You may have to “recreate” potential trouble spots by purposefully exposing your product to out of specification conditions to determine whether that may had some level of responsibility in causing your food quality issue.

Once all the facts are available you will have a clearer picture of the causal factors responsible for your food quality issue. From there, it’s a matter of increasing your inspection rates, having a more thorough focus on GMPs, and stressing the need for maintaining specifications during the distribution and food preparation system. No matter what the cause of your quality issue, the solution you put into place should be monitored by establishing “fail-safe” systems and by reviewing information generated by those systems on a regular basis. This is essential to minimize the potential for reoccurrence of any product quality issue.

Quality control and food safety are not boxes to be checked off a one-time “to-do” list. Continual focus on quality improvement is the best way to give you and your guests the satisfaction that you are doing everything possible to provide them with a flavorful and safe meal.
 

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