Presentation on theme: "Solving the Survey Puzzle for F371"— Presentation transcript:
1Solving the Survey Puzzle for F371 Sara Gosnell, RD, CD
2ObjectivesDescribe the relationship between the regulation and the interpretive guidanceDescribe how to use the investigative protocolDescribe and apply components of the investigative protocolIdentify areas of noncompliance with the sanitary conditions regulationAppropriately categorize the scope and severity of noncompliance
3F371 Revisions F370 merged into F371 Regulatory language was kept the sameRevisions now provide:13 new definitionsEducationExplanationsExamples for surveyors to reference
4Defined by Federal Regulation The facility must483.35(i) (1) Procure food from sources approved or considered satisfactory by Federal, Stated, or local authorities483.35(i) (2) Store, prepare, distribute and serve food under sanitary conditions
5IntentFacility obtains food for resident consumption from sources approved or considered satisfactory by federal, state, or local authoritiesFollows proper sanitation and food handling practices to prevent the outbreak of foodborne illness; beginning with the vendor through the facility’s food handling processes.
7Cross ContaminationThe transfer of harmful substances or disease-causing microorganisms to food by hands, food contact surfaces, sponges, cloth towels, or utensils that are not cleaned after touching raw food, and then touch ready-to-eat foods. This may also occur if raw food touches or drips onto cooked or ready-to-eat food.
8Danger Zone Used for PHF Temps between 41°-135° F* that allow rapid growth of pathogenic microorganisms that can cause foodborne illness>4 hours during preparation>6 hours for items cooked and cooled*the temps are based on the food code which are the most stringent
9Dry StorageStoring and maintaining dry foods (e.g., canned goods, flour, sugar) and supplies (disposable dishware, napkins, and kitchen cleaning supplies)Examples: ensuring paper goods are open from the right end and plastic bags of silverware are sealed and not left open
10StorageThe retention of food (before and after prep) and associated dry goodsExample: NOT keeping scoops in flour or sugar bins even if the handle is up
11Food ContaminationThe unintended presence of potentially harmful substances, including but not limited to microorganisms, chemicals or physical objects in food.Example: fake fingernail in food
12Food PreparationThe series for operational processes involved in getting foods ready for serving, such as: washing, thawing, mixing ingredients, cutting, slicing, diluting, concentrates, cooking, pureeing, cooling and reheating.Example: not washing fruit; rinsing a knife, not washing it and using it again
13Foodborne IllnessIllness caused by the ingestion of contaminated food or beverages►Foodborne outbreak2 or more unrelated people that ate a similar meal
14Food Service/Distribution The processes of getting food to the residentHolding foods hot on the steam table or under refrigeration for cold temp controlDispensing food portions for individual residentsFamily style and dining room serviceDelivering trays to residents’ rooms or units
15Highly Susceptible Population Persons who are more likely than the general population to experience foodborne illness because of their susceptibility to becoming ill if they ingest microorganisms or toxins (e.g., immunocompromised, chronic disease and advanced age)
16PathogenAn organism capable of causing a disease (e.g., pathogenic bacteria or viruses)Norovirus
17Potentially Hazardous Food (PHF or TCS) Food that requires time-temp control for safety to limit the growth of pathogens or toxin formation٭TCS- time/temp control for safety
18Ready-to-Eat FoodFood that is edible with little or no prep to achieve food safetyIncludes foods requiring minimal preparation for palatability or culinary purposes, such as mixing with other ingredients (e.g., tuna, chicken or egg salad)Examples include deli items and raw fruits and vegetables
19ToxinsPoisonous substances that are produced by living cells or organisms (e.g., pathogenic bacteria) that cause foodborne illness when ingested
20Overview The risk for foodborne illness (FBI) Importance of effective food safety systemsIdentify hazards and critical control points (CCPs)Operational steps to eliminate hazards
21Types of Food Contamination BiologicalChemicalPhysical
25Chemical Contamination Monitor to ensure spray cleaners are not within proximity to food prep area to prevent food from being sprayedEnsure bottles are properly labeledSoap should not be stored in an unlabeled styrofoam containerPowder cleaners could be mistaken for a cooking product
26Physical Contamination Foreign objects in foodHairFingernailsMetal shavingsJewelryDo NOT use:a glass as an ice scooperA steel scouring pad to clean
27Other Factors Involved in Foodborne Illness Poor personal hygieneInadequate cooking and improper holdingContaminated equipmentUnsafe food sources
28Prevention of Foodborne Illness Food handling and preparationEmployee healthHand washing, gloves, antimicrobial gel
29Employee IllnessAn employee will be restricted from working with food if they are experiencing symptoms of:FeverCough/sore throatDiarrheaOpen wound, not bandaged/covered
30Safe Food StorageFIFO!!Dry food storage should be maintained in a clean and dry areaSafe refrigerator practicesMonitoring tempsProper handling/cooling of hot foodsSeparation of raw, cooked and ready-to-eat foods
31Safe Food Preparation Cross contamination Thawing Final cook temps Modified consistencyCoolingReheating foodNO pooled eggs unless pasteurized
32Thawing Foods Properly Under cold water, < 70°F, agitating enough to get off iceIn the coolerMicrowaving; food needs cooked immediately followingCook from frozen state
33Final Cook Temperatures PoultryStuffed Foods165° FGround Meat155° FFishEggs (unpasteurized)Pork145° F
34Proper Cooling Techniques Shallow pans for smaller quantitiesIce bathFrequent stirringCooling paddles135° F ► 70° F ► within 2 hours70 ° F ► 41° F ► within 4 hours٭Total time not to exceed 6 hours
35Proper Reheating Procedures Required internal temp = 165°F for 15 seconds minimumOnly for foods properly cooledCan only reheat a food item once!٭Facility-made pureed food cannot be reheated
36Equipment and Utensil Cleaning and Sanitization Machine wash and sanitizeManual wash and sanitizeCleaning fixed equipment√ Test strips should be at each station and used!!
37Food Service and Distribution Tray line, alternative meal preparation and service areFood distributionSnacksSpecial eventsTransported foodsIceRefrigeration
38Wiping Cloths Service area wiping cloths are cleaned and dried, or Place in a chemical sanitizing solution of appropriate concentration√ test strips need used periodically as sanitizer strength decreases over time
39Surveying Facilities That Receive Food Prepared by Off-site Kitchens When a nursing home receives food services from an off-site location, the surveyor must assess whether the facility is compliant with 42 CFR (i)٭Your facility should have on hand a copy of the most recent sanitation inspection from the off-site location
40Culture Change Provisions Family members, or other resident guests, who bring in food for the resident’s consumption are not regulated under this federal tag.● many state regs address thisDietary is responsible for foods cooked by recreation department, and should be trained accordinglyA cake from the bakery is ok, but bake sales to the residents should not be doneFamilies/guests can bring food in for the individual but it should not be set out for others
41Pathogenic Microorganisms and Strategies for Their Control Commonly identified ingestible items associated with illness-producing organismsPrimary agents of concern (hazards) are organisms associated with the food sourcePHF/TCS primary control strategies to minimize potential for foodborne illness outbreak
42Investigative Protocol Sanitary Conditions Use this protocol to investigate complianceat F371 ( (i) (1) and (2))
43ObjectivesTo determine if the facility procured food from approved sourcesTo determine if the facility stores, prepares, distributes and serves food in a sanitary manner to prevent FBITo determine if the facility has systems (e.g., policies, procedures, training, and monitoring) in place to prevent the spread of FBI and compromising of food safetyTo determine if the facility utilizes safe food handling from the time the food is received from the vendor and throughout the food handling processes in the facility
44Investigative Protocol Procedure During Survey ObservationsInterviewsRecord reviewsReview of facility practices
45Observation Surveyors will observe food procurement Service of food during mealsService after mealStorage of food
46Observation of Food Procurement Procedures Observe when, where and how food is procuredInvoices (to verify sources)Vendor recordsSource verificationTemps upon arrivalVisually observe itemsAre boxes wet?
47Observation of Food Preparation Procedures Food handling practicesFood labeling and datesHand washingHandling of potential cross contamination foodsAcceptable cooking and cooling temps
48Observation of Trayline Service Observe staff measuring the temp of all hot and cold menu items at all points of serviceCold food should be ≤ 41° FHot foods should be ≥ 135° F٭ ensure staff are taking temps from the middle of the food item
49Observation of Dish Room Procedures Observe whether staff are properly operating dish machine and evaluate sanitization processesCheck for proper equipment and supplies to evaluate dish machine operationObserve the 3 step process of manual pot and pan washingWhat sanitizer do you use with what test strip?
50Observation of Service After Meals Observe store dishes, utensils, pots/pans, and equipment for evidence of soilingCan the lowerator be splashed by dirty water?Evaluate whether proper hand washing is occurring between handling soiled and clean dishes to prevent cross contamination of the clean dishes
51Observation of Food Storage Look for evidence of pests, rodents and droppings and other sources of contaminationObserve whether foods are labeled and datedObserve whether foods are stored off of the floorCheck for canned goods that have a compromised sealObserve whether staff access bulk foods without touching the food
52Interview ProtocolSurveyor will interview multiple staff regarding the policies and procedures for procurement, preparation and service of food to the residentsStaff need to be able to answer these questions, as well as, possibly perform the task if asked correctly
53Record Reviewal Protocol Resident recordsDietary/kitchen policies and proceduresMaintenance records, such as work orders and manufacturer's specifications, related to equipment used to store, prepare and serve foodFacility infection control records
54Determination of Compliance for F 371 Did the facility:Procure food from approved sources?Properly store, prepare, distribute and serve foods for residents’ consumption?٭٭٭Important to review food temps in resident council, or food committee, monthly to ensure temps are palatable at point of service to the residents. After point of service, it becomes a palatability issue, rather than a temp issue.
55Criteria for Compliance with F371 Procures, stores, handles, prepares, distributes and serves food to minimize the risk of FBIMaintains PHF/TCS foods at safe temps, cools food rapidly, and prevents contamination during storageCook food to the appropriate temp and hold PHF/TCS foods cold or hotUtilizes proper hand washing and personal hygiene practices to prevent food contaminationMaintains equipment and food contact surfaces to prevent food contamination
56Noncompliance with F371May include, but is not limited to, one of more of the following, failure to:Procure, store, handle, prepare distribute and serve food in accordance with the standards summarized in the guidanceMaintain PHF/TCS foods at safe temps, at or below 41°F (for cold foods) or at or below 135°F (for hot foods.Exception: during prep, cooking or coolingEnsure that PHF/TCS food plated for transport was not out of temp control for more that 4 hoursStore raw foods properly to reduce the risk of contamination of cooked or ready-to-eat foodsEnsure that foods are cooked to the appropriate temp and cooled properly to prevent FBI
57Severity Determination Harm/negative outcome(s) or potential for negative outcomes due to a failure of care and serviceDegree of harm (actual or potential) related to noncompliance, andImmediacy of correction required
58Determining Actual or Potential Harm Actual or potential harm/negative outcomes for F371 include:Foodborne illnessIngestion or potential ingestion of food that was not procured from approved sources, prepared, distributed or served under sanitary conditions
59Determining Degree of Harm How the facility practices caused, resulted in , allowed, or contributed to harm (actual/potential)If harm has occurred, determine if the harm is at the level of serious injury, impairment, death, compromise, or discomfort, andIf harm has not yet occurred, determine how likely the potential is for serious injury, impairment, death, compromise or discomfort to occur to the resident.
60Severity Level 4 Deficiency Categorization Immediate JeopardyTo Resident’s Health or Safety
61Level 4 Immediate Jeopardy Has allowed/caused/resulted in, or is likely to cause serious injury, harm, impairment, or death to a resident; andRequires immediate correction, as the facility either created the situation or allowed the situation to continue by failing to implement preventative or corrective measures.
62Level 4 Deficiency Example #1 A roast thawing on a plate in the refrigerator had bloody juices overflowing and dripping onto uncovered salad greens on the shelf belowThe contaminated salad greens were not discarded and were used to make salad for the noon meal
63Level 4 Deficiency Example #2 The facility had a recent outbreak of norovirus as a result of a food worker experiencing episodes of vomiting and diarrhea, and the facility allowed the staff to continue preparing food.Observations and interviews indicate that there are other food service staff experiencing gastrointestinal illnesses who are still permitted to prepare food.
64Severity Level 3 Deficiency Categorization Actual Harm that is not immediate jeopardyThe negative outcome may include but may not be limited to clinical compromise, decline, or the resident’s inability to maintain and/or reach his/her highest practicable level of well-being.
65Level 3 Deficiency Example #1 Example #2 An outbreak of nausea and vomiting occurs in the facility related to the inadequate sanitizing of dishes and utensilsExample #2A milk episode of food poisoning occurred because the facility had a special even tin which tuna, chicken, and potato salads served in bulk were not kept adequately chilled and were left out for eating after 5 hours
66Severity Level 2 Deficiency Categorization No actual harm with potential for more than minimal harm that is not immediate jeopardy
67Level 2 Deficiency Categorization Noncompliance tat results in a resident outcome of o more than minimal discomfort, and/orHas the potential to compromise the resident’s ability to maintain or reach his or he highest practicable of well-being
68Level 2 Deficiency Example #1: food service workers sliced roast pork on the meat slicerThe meat slicer was not washed, rinsed and sanitized after usageDuring the dietary service system assessment, two days later, the surveyor observed the meat slicer soiled with dried meat underneath the bladeThe facility failed to educate and train staff on how to clean and sanitize all kitchen equipment
69Level 2 Deficiency Example #2: During the tour of the kitchen, two food service workers were observed on the loading dockOne was smoking and the other employee was emptying trashUpon returning to the kitchen, they proceeded to prepare food without washing their hands
70Severity Level 1 Deficiency Categorization No actual harm with potential for minimal harm
71Level 1 Deficiency Categorization The failure of the facility to procure, prepare, store, distribute and handle food under sanitary conditions places this highly susceptible population at risk for more than minimal harm.Therefore, Severity Level 1 does not apply for this regulatory requirement.
72Additional Investigation Potential tags from additional investigationF322- Nasogastric TubesF325- NutritionF353- Sufficient StaffingF361- Dietary Services- StaffingF362- Standard Sufficient Staffing42 CFR (h) Paid Feeding AssistantF441- Infection ControlF444- Handwashing TechniquesF456- Maintain All Essential EquipmentF465- Other Environmental ConditionsF469- Effective Pest control ProgramF540- Quality Assessment and Assurance
73F371 and the Food Code Application Know what the Federal Regs and your state have adopted in regards to a Food CodeCompare with F371, which uses the 2005 FDA Food Code
74Implications for the Foodservice Supervisor Must be more observant of staff practices and accountable for safe food handlingBe able to use the new surveyor “Investigative Protocol” to self-survey the kitchenEnlist the Consultant, or in-house, RDTo help review the policies and procedures concerning current industry standards for safe food handlingDevelop and implement thorough orientation and ongoing inservices in food handling
75Implications for the RD If you haven’t already, now is the time toBegin developing inservicesBecome certified in food safetyDetermine if you will need more time in your facilities to ensure regulation compliance is maintained
76Implication for Administration As surveyors are trained on the revision of F371, the new Investigative Protocol for Sanitary Conditions, and the new Scope/Severity determinations NO Administrator will want a deficiency in “unsafe food handling”, especially NOT and Immediate Jeopardy
77Post Test1. Glove use is not important when handling ready-to-eat foodsTrue False2. Which of the following is not part of the revisions for F371DefinitionsEducationScope of practiceExplanationsExamples
78Post Test Continued3. During the Investigative Protocol, the surveyors are to have no contact with the staff, only with paper records.True False4. The Food Danger Zone is 40°F -140°F.
79Post Test Continued5. A surveyor observed an employee load dirty dishes in the dish machine, then walk to the clean end to unload them without washing his hands. What level of severity would the facility be tagged with?a. Level 1b. Level 2c. Level 3d. Level 4
80Post Test Continued6. It is important to have an RD involved in developing and implementing policies and proceduresTrue False7. What is the time frame allowed to correct a Level 4 Severity, or Immediate Jeopardy?Immediately1 month3 months6 months
81Post Test Continued 8. Which is not a potential for citation? A cloth being kept in sanitizer solutionA roast in the cooler labeled and dated from the prior dayTemp of hot foods at point of service being 135°FA staff member delivering a tray with no glovesAll of the above
82Post Test Continued9. If you receive food from an off-site facility, you do not need to be concerned with sanitation checksTrue False10. Which of the following is not part of the Investigative Protocol?ObservationsInterviewsEducationRecord ReviewsReview of Facility Practices
83Answers 1. False 2. C 3. False 4. False 5. B 6. True 7. A 8. E