What to do with your “draft”
evaluation report and tools
• Michelle Messer, R.S.
• FPLS Partnership and Workforce
Development Unit
Draft of the “Final” Report
• Typically completed within 60 days of the
evaluation
• Includes the tools and summary report
• Appendix H in Evaluation Protocol lists
elements of the summary report.
Tools: Foundation of the Evaluation
• Thoroughly read each program area tool.
• Tell MDH what is missing or misinterpreted.
• In your notes, refer to these items by
Standard number and letter in the tools, e.g.,
“Food Tool, Standard 3-4a.”
• Focus on the essential (orange) and required
(yellow) elements that did not receive a
score of “2.”
Report Summary
• Takes information from the tools and summarizes the entire
evaluation
• Provides comments and discussion per each program standard
• Summary addresses the overall performance status according to
the terms used in the Delegation Agreement
– (Acceptable, Exceeds Minimum Standards)
– Acceptable
– Acceptable with Improvements Needed
– Conditionally Acceptable
– Unacceptable
– (Subject to Termination)
– Termination.
Changing the Draft Report
• If agencies don’t agree or MDH
misunderstood something, the draft stage of
the evaluation is the time to correct these
items.
• Respond in writing to MDH within 30 days of
receiving the draft with any comments or
changes to tools and report.
Next Steps:
• MDH will make changes that are needed
and issue a final report and tools.
• Corrective action plans due to MDH within
30 days of receiving the final report.
Evaluation Standards and
Observations
• Michelle Messer, R.S. and Angie Cyr, REHS
• FPLS Partnership and Workforce
Development Unit
Standard 1: Regulatory Foundation
• Ordinances
Standard 2: Trained Staff
• Training
• Managerial Oversight
Standard 3: Risk Based Inspections
(documented procedures)
• Risk category
• Written policies
• Inspection frequency
Standard 4: Uniform Inspection Program
• Active managerial control
• Proper code citations
• Current license list
• “Z” orders and clearly written orders
Standard 5: Illness and Injury
Investigation and Response
• Foodborne and Waterborne Outbreak
Protocol
• Teamwork
Standard 6: Compliance and
Enforcement
• Follow-up activities and inspections
• Time of inspection
• Enforcement actions
• Violations in comment section
• Floors, walls, ceilings
Standard 7: Industry and Community
Relations
• Participation in workgroups, advisory boards,
task forces, or other committees
Standard 8: Program Resources
• Qualified staff
• Staffing levels
Standard 9: Self-Assessment
• Continuous improvement
Combined Inspection Frequency from
Evaluations for All Program Areas
Combined Inspection Frequency from
Evaluations for Food Establishments
Combined Inspection Frequency from
Evaluations for Lodging Establishments
Combined Inspection Frequency from
Evaluations for Swimming Pools
Combined Inspection Frequency from
Evaluations for MHP/RCA Establishments
Combined Inspection Frequency from
Evaluations for Youth Camps
MDH Inspection Frequency, All
Program Areas
Field Evaluation Trends
• Employee Illness
• Bare hand contact with ready to eat food
• Cooling
Successes
• Recent improvement on employee health
knowledge
• Better use and understanding of selfassessment
• Program gaps identified during selfassessment and corrections made
• Ability to hire additional staff based on
evaluation
Active Managerial Control
(AMC) & Risk Based Inspections
• Angie Cyr. REHS
• FPLS Partnership and Workforce
Development Unit
Origin and Meaning
FDA Food Code Annex 4: Management of Food
Safety Practices – Achieving Active Managerial
Control of Foodborne Illness Risk Factors
• Used to describe industry’s responsibility for
developing and implementing food safety
management systems to prevent, eliminate, or
reduce the occurrence of foodborne illness
risk factors.
Foodborne Illness Risk Factors
• Poor employee health and personal hygiene
• Food from unsafe sources
• Improper hot/cold holding temperatures of
potentially hazardous food
• Improper cooking temperatures of food
• Dirty and/or contamination utensils and
equipment
AMC Required
Minnesota Food Code Rules, 4626.2010, Subpart 5
duties of a certified food manager involves AMC
Subp. 5.Duties of certified food manager. An owner or operator, through the
certified food manager, is responsible for ensuring that:
A. hazards in the day-to-day operation of the food establishment are identified;
B. policies and procedures to prevent foodborne illness are developed and
implemented;
C. employees are trained to ensure that there is at least one trained individual
present at all times food preparation activities are conducted who can
demonstrate the knowledge required in the Code;
D. food preparation activities are directed and corrective action is taken, as
needed, to protect the health of the consumer; and
E. in-house self-inspections of daily operations are conducted on a periodic basis
to ensure that food safety policies and procedures are followed.
Assessing AMC on Inspections
• Conduct risk-based inspections
• Evaluate the effectiveness of the food safety
management system being utilized in an
establishment
• Assist operators in developing SOP’s and risk
control plans to attain long-term managerial
control of the foodborne illness risk factors
• AMC is more than assessing compliance with
the Code
Assessing Active Managerial Control
vs. Code Compliance
• An establishment may be in compliance with
the code when you are there but what
happens when you are not there?
• Ask open-ended questions to help determine
what happens at times you are not there
–
–
–
–
Training
Monitoring
Corrective actions
Verification (management oversight)
Assessing AMC
Assessment involves:
• Discussion with the person in charge and food
employees
• Observations
• Reviewing logs, procedures and any other
documentation they have for their food safety
system
• Conducting a gap analysis
Risk-Based Inspections
Includes:
• Menu review
• Making good observations
• Focusing on the risk factors that are present at that
establishment
• Assessing AMC
• Conducting a review of their processes
• Taking corrective actions
• Obtaining long-term compliance
Focusing the Inspection
• Take the time to communicate. Ask Questions!
• The majority of your time should be spent on assessing
AMC of risk factors
• GRP’s are also assessed but, most tend to be static,
whereas risk factors tend to be more dynamic
• Conduct a quick walk-though (2 minutes) so you know
what processes are being conducted
• It is important that the inspector knows the food
preparation processes conducted in a facility so they
can assess the risks
• INSPECT PROCESSES, NOT AREAS!
Achieving Long-term Compliance
• AMC helps achieve long-term compliance
• Is tailored to the establishment’s resources and
needs
• Eliminates frustration from the “roller coaster” of
compliance and enforcement
• Since it is tailored to their needs, it does a better
job at affecting long-term behavior change
• Can ultimately save you time