THE FDA CANNOT PROVIDE CORRECT HAZARD CONTROL INFORMATION. The FDA talks about training its personnel in HACCP, but the FDA retail food code does not contain correct control information for the cook. It never will, because the FDA never validates in a kitchen that what it writes is correct. The FDA does not have a test kitchen where it can put pathogens in food and then validate hazard controls such as:
1) Using a thermocouple to validate destruction of pathogens
2) Washing pathogens off of produce
3) Making salads and salad dressings with raw eggs
4) Roasting beef to kill parasites
5) Washing fecal pathogens off of fingertips.

The people in the Retail Food Protection Branch do not know how to prepare food to make it safe in a commercial kitchen. We are naive to believe that the FDA code will ever be a reliable source for what the cook must do to make food safe. Interestingly, the FDA, through HACCP has cleverly transferred the entire responsibility for finding out all of this information to every cook in the U.S. If HACCP is done the FDA way, every operator will spend thousands of dollars finding correct controls. Why not have this done once for everyone? This is where I come in.

Many people teach the ServSafe course, which the NRA has been promoting. Take a careful look. Virtually all of the food safety rules in ServSafe come from the FDA code. This course simply does not teach correct information. The NRA has no kitchen or food scientists working on improving the FDA control information.
HAZARD CONTROL. The cook / food handler is the critical controller, and in my education system, the control document is a simple set of written instructions based on my hazard controls, which is used for training employees. This document is sometimes called the policies, procedures, and standards manual (USDA calls it HACCP SOP). This manual should be the FDA Food Code, which every operator could have adapted to his or her operation, depending on the complexity of the food processes, but it never will be.

The owner / operator of the facility writes this policies, procedures, and standards manual to assure uniform employee performance in safe food preparation. The regulatory official should be the verifier / validator of recipe procedures, but that takes a lot of food science and engineering education. The manager empowers the food worker through education and positive feedback for correct performance. The local regulatory agency should then function as "back-up" for the manager in terms of safe food process design--what I call "recipe engineering."

MY NATIONAL INDUSTRY SELF-CONTROL PROGRAM. Legislatures across the U.S. have chosen to continually downsize food inspection programs. While our need for correct food safety control knowledge increases, the inspectors are forced to be greater generalists, because there are fewer of them. They cannot purchase proper thermometers to measure food temperatures, much less pH meters to check on recipes for acid foods. Since retail food operators and their employees are the ones who actually assure the safety of the food, I have chosen to focus on the operators and cooks in my national food safety initiative.
The following program is my national training alternative that costs the government nothing and can bring industry HACCP self-control to the U.S. in a couple of years. It will also change the role of regulatory officials from inspectors to consultants who advise operators on safe "recipe" food handling procedures.
It is based on HACCP standards that were accepted by the FDA in 1991 and reviewed by my food scientist friends. Many constantly review what I write and make suggestions for improvement. I am implementing this industry-regulatory HACCP self-control program through voluntary local demonstration programs. These educational programs have three outcomes: 1) liability control / safety, 2) customer satisfaction / increased tourism, and 3) operating profit because of food handling efficiency and minimum waste. These outcomes are designed so that the government does not spend any money toward industry and regulatory training.
HOW I CAN HELP YOU BEGIN. If a state / city / county regulatory group decides to have a HACCP demonstration program, the first step is to find at least 20 retail food operators who are interested in beginning an industry HACCP self-control demonstration group. These operators need to be willing to pay $250 for my two-day HACCP course for managers, 1901: Food Safety through Quality Assurance Management. (See my web site, http://www.hi-tm.com, for a detailed course outline.)

I teach my two-day 1901 course on Monday and Tuesday for the 20 operators. The operators' inspectors also attend 1901 so that by the end of the two days, the operators and their individual inspectors will be a HACCP team. They will understand all hazards and validated controls, and will know how to write a short, simple policies, procedures, and standards manual / checklist that each operator uses for control.
On Wednesday, Thursday, and Friday, I teach a condensed version of my five-day advanced HACCP-TQM course, 2902: HACCP-Based Safety- and Quality-Assured Retail Food Systems, for the regulators. (See my web site for detailed course information.) Any of the 20 operators who want further education can also attend. This way, the sanitarians would be able to receive five days of education.
The three-day advanced course on Wednesday through Friday provides intense instruction in the technical aspects of retail food process control, to include recipe engineering, chilled food systems, home meal replacement, etc. The course applies equally to all kinds of retail food operations, food markets, and small food processors and includes management and supplier controls etc. Also, it is exactly what the home food preparer needs to know, since problems with home food preparation are basically the same as those in the retail food system.

The 2902 course outlines in detail the correct approach to flow charting recipes / food processes, which I pioneered 20 years ago, and how to turn a flow chart into a standard recipe procedure, which is what the cook needs in order to prepare a given product. Flow charts are great analysis tools for the person who is trying to design the most efficient, effective recipe. However, the flow chart is not for the cook; the cook uses a recipe. Therefore, I teach people how to convert flow charts into simple standardized HACCP recipe formats.
Because I am thoroughly trained in commercial cooking and have a Ph.D. in food science and nutrition, I can teach people both flow charting and recipe science. I find that there is no problem in teaching people how to do flow charts and convert them into recipes, if they can cook. Because of my experiences in the kitchen, I can "talk the language" of the employee on the line.
CONTINUING THE TEAM WITH THE OPERATIONS MANUAL / CHECKLIST. My intent is that after the last day of class, this industry-regulatory HACCP team will work together, with regulatory oversight, so that the industry will develop and implement simple HACCP self-control programs. The regulators will coach these operators to help them write and implement simple, individual policies, procedures, and standards for their units, following the model manual taught in class. (Thousands of people have written these using my model.) These policies, procedures, and standards will then be used for employee instruction. Each operator and their regulator agree as to what will be on the critical control checklist and what will be on the non-critical, "floors, walls and ceilings" checklist. Actually, there should not be a non-critical checklist, but that is up to each team.
These HACCP policies, procedures, and standards are really quality assurance manuals / checklists that guarantee that all of the hazards in each operator's establishment are controlled. For a simple operation, a checklist-style manual is adequate. It is critical and possible to keep these manuals short and yet have them be adequate. I believe that this HACCP program can be a positive influence on increased tourism, because food is so carefully handled to assure its safety, which actually leads to better quality in the food operations and happier customers.
WHAT ABOUT GOVERNMENT AUDITS AND VERIFICATION? When inspectors audit these operations, they need only to determine if the operators who came to class have been following their agreed-upon, HACCP operating manuals / checklists and have been training new employees in basic instruction for hand washing, cleaning cutting boards, and measuring and controlling food temperatures, etc. What the inspectors verify, then, is that the agreed-upon operators' hazard self-control programs are working. They verify this by talking to employees first and then, the operators. This is the HACCP we want, because it is the operator who controls the behavior of the employee. This is exactly how OSHA approaches Process Safety Management. Month by month, the operator is coached to higher levels of self-control by advice from regulatory officials. If both work regulators and the industry toward increased tourism because of food quality, the food gets safer, and everyone "wins."
INFORMATION FOLLOW-UP. My job does not end after the class. I keep participants up to date with current materials, new technology, and information about better control methods from my lab, etc. This happens as we do follow-on training. Any student can call me with any question.
SUMMARY. This five-day manager / regulatory group education costs the government nothing. The industry will bear the training cost. However, the industry will benefit, because inspections become consultations for continuous quality improvement. The entire focus will become recipe engineering and hazard control, not floors, walls, and ceilings. All forms of future retail processes are possible. I do the necessary research and validation, as I have been for 20 years. The FDA does not have the capability to do this.
IF YOU ARE INTERESTED. I would be most pleased to discuss this HACCP self-control demonstration program with anyone who is interested.  The technology is easy. An operator can be capable of zero defects with a fingernail brush and a thermocouple.

Employee training must be kept simple and must be done on a regular basis. There is no HACCP program if the employee on the line does not know the controls for his or her job. Some very large companies have been using my training for years. It works. The key is building a regulatory-industry team whose members work as equals and where the regulatory officials stop dictating inadequate controls from the FDA that have never worked.
If you would like to have a demonstration program, please contact me. Note, this is not a high-profit venture. All profit goes back into research and writing better training materials, not marketing and advertising, as some do. This food safety problem is a simple problem to solve, requiring mostly discipline and for us to look to ourselves, not to the government, for the solution.
O. Peter Snyder, Jr., Ph.D.
Hospitality Institute of Technology and Management
670 Transfer Road, Suite 21A
St. Paul, MN 55114
TEL 651 646 7077     FAX 651 646 5984
e-mail: osnyder@hi-tm.com

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