83 12.7: Crisis Management
12.7 CRISIS MANAGEMENT
The Role of Plan Review and SOPs in Food Establishment Safety
SOPs provide clear, written instructions for employees, reducing ambiguity and ensuring consistency in food safety practices what standard operating procedures (SOPs) typically cover:
Who performs each task.
What materials and equipment are needed.
Where and when tasks are done.
How each task is performed to ensure safety and quality
At the Beginning of the Operation. At the plan review stage, regulatory authorities often interact with representatives who may be focused on construction or permitting rather than food safety. Despite this, the plan review is a critical opportunity to establish a strong foundation for long-term compliance with the FDA Food Code, which is essential for protecting public health and preventing foodborne illness. The FDA, USDA, and CDC all emphasize the importance of this proactive approach in their guidance documents.
Key Points to Elaborate and Explain:
The plan review process is not just a regulatory hurdle; it is a strategic step to ensure that food establishments are designed and operated to minimize food safety risks from the outset.
Standard operating procedures (SOPs) are a vital part of this foundation. They should be developed alongside facility design to ensure that food safety practices are integrated into the physical and operational structure of the establishment.
SOPs must be finalized by the preoperational inspection and implemented as soon as the food operation begins, ensuring that food safety practices are in place before any food is served to the public.
Why Standard Operating Procedures (SOPs) Matter:
SOPs provide clear, written instructions for employees, reducing ambiguity and ensuring consistency in food safety practices6. Written SOPs must be:
Available for reference by the person in charge (PIC).
Communicated to all relevant employees.
Accessible for review by regulatory authorities during inspections6.
Essential Components of SOPs (per FDA Food Code 2022):
Employee Health and Hygiene: Procedures to prevent foodborne disease transmission by managing job applicants and employees.
Approved Food Sources: Ensuring all food is received from approved suppliers, as required.
Food Protection: Safeguarding the safety and integrity of food from delivery through storage, preparation, and service.
Time/Temperature Control: Maintaining safe temperatures for foods during all stages-freezing, holding, cooking, cooling, reheating, and serving.
Effective Warewashing: Procedures for cleaning and sanitizing utensils and equipment, including correct chemical concentrations and contact times.
Recordkeeping: Retaining required records for inspection.
Training and Compliance
During the plan review phase, regulatory authorities have a unique opportunity to influence the future safety culture of a food establishment. Even if the individual seeking a building permit is not directly involved in food safety operations, early discussions about standard operating procedures (SOPs) are essential.
Training Requirements:
During plan review, regulatory authorities and management should discuss training programs for food employees and the person in charge.
By the preoperational inspection, the establishment must have operating procedures that detail how employees will be properly trained in food safety, in accordance with paragraph 2-103.11(N) of the Food Code.
SOPs should be developed in tandem with facility design, ensuring that food safety practices are built into the physical and operational framework of the establishment. By requiring written, accessible, and comprehensive SOPs before the preoperational inspection, regulatory authorities help ensure that critical food safety controls-such as employee health monitoring, sourcing from approved suppliers, temperature management, effective warewashing, and proper recordkeeping-are in place from day one. This proactive approach, supported by FDA, USDA, and CDC guidance, lays the groundwork for sustained compliance and public health protection.
By following these guidelines, food establishments can proactively manage risks and demonstrate a commitment to food safety from the earliest stages of planning and operation.
Ceasing Operations and Reporting. A permit holder should immediately discontinue operations and notify the regulatory agency if an imminent health hazard exists because of an emergency such as a fire, flood, extended interruption of electrical or water service, sewage backup, or misuse of poisonous and/or toxic materials.
Circumstances Requiring Cessation of Operation
Food establishments must immediately discontinue operations and notify the regulatory authority if an imminent health hazard may exist due to emergencies such as:
Fire
Flood
Extended interruption of electrical or water service
Sewage backup
Misuse of poisonous or toxic materials
Onset of an apparent foodborne illness outbreak
Gross insanitary occurrence or condition
Any other circumstance that may endanger public health.