Food Code Compliance for Food Retailers: Ace Your Audit

Dr. Karla Acosta
Contributing Writer

There are a number of details many food retailers overlook when it comes to food code compliance. In this blog, Food Safety Manager, Karla Acosta, provides a walk-through on food code compliance so food retailers can pass their audits.

In our recent webinarSo You Think You Can Pass? A Guide for Food Retail Audits, Dr. Karla Acosta, Food Safety Manager at The Acheson Group (TAG), covered Acosta’s key points to teach you how to comply with food code regulations and learn to think like a health inspector so you can ace your next audit.

Acosta was a health inspector for five years before pursuing her PhD focused on Food Safety Training research, and is now adjunct faculty at multiple universities for graduate and undergraduate students. Her experience uniquely positions her and others on the TAG team to offer tactical food safety advice through a supportive, educational approach.

At TAG, we specialize in providing honest proof and feedback as well as recommendations for deficiencies — with the eyes and brains of a health inspector, but the heart of a friend

Dr. Karla Acosta / The Acheson Group

We recap her top points. Topics include:

  1. Who's At the Top of Your List for Food Safety Inspections

  2. How to Overcome Any Level of Risk and Ace Your Audit
    a. Self-Audit Regularly
    b. Standardize Training Materials for Food Code Compliance
    c. Shift From Management to Leadership

  3. Two Most Common Food Safety Violations

  4. Keeping Compliance Within the Food Code

Who's At the Top of Your List for Food Safety Inspections?

Inspections can happen at any time, ranging from once a month to once a year. However, you are more likely to be inspected more frequently if one or more of the following apply.

  • You serve high-risk products. Especially raw and ready-to-eat foods. In general: the more procedures that go into that food product, the more likely it’s high-risk.

  • You have previously reported compliance violations in past inspections. Are you a new manager at your company? Take a look at your inspection history for a good indication of what your next inspector will focus on

  • You have previously reported compliance violations in past inspections. Are you a new manager at your company? Take a look at your inspection history for a good indication of what your next inspector will focus on

  • You serve high-risk populations. Child care, nursing homes, hospitals, and similar institutions cater to individuals with compromised immune systems

  • You have high foot traffic. Open 24/7? Longer operating hours and larger operations mean more exposure to potential pathogens.

...Or you're in the hospitality business

Just being in the hospitality industry alone is enough to get yourself on the FDA’s radar. Why? Foodborne illnesses specifically stem more from hospitality than any other industry.

The hospitality industry, including restaurants, caterers, and food banquets, accounts for approximately 75% of all foodborne illnesses.

A major contributing factor to this is the industry’s high turnover rate. The hospitality industry is particularly vulnerable to external factors. When COVID-19 hit the turnover rate in the hospitality industry jumped to 130.7% in 2020, compared to 78.9% in 2019.

But never fear: companies can learn how to comply with food code regulations so audits can proceed smoothly and even help your organization improve its food safety practices.

How to Overcome Any Level of Risk and Ace Your Audit

Self-audit regularly.

If the idea of a food safety inspection triggers anxiety in you or your workforce, then you’re not fostering a positive food safety culture. Regular self-audits help keep frontline employees cool and collected during a real audit, and give management a strong understanding of what’s happening on the floor and how new employees are adapting.

Nothing to hide? Nothing to fear. Perform self-audits regularly to boost confidence and competence across your workforce.

When devising your self-audit, it’s vital to develop a solid understanding of how food laws work and to review the forms that will be required during an actual audit. Create a checklist that includes fundamental items that will help during your real audit, such as:

  • a record of all documents you will be asked for in a consolidated location;

  • implementation and adherence to HACCP;

  • schedules;

  • pest control records;

  • and employee training records.

Standardize training materials for food code requirements.

Training materials and onboarding procedures are particularly important in the food industry because of the high rate of employee turnover. On average, the turnover of a single front-line hospitality employee leads to $5,864 in costs between recruiting, selection, orientation, training, and productivity loss. Creating training materials and a scalable, replicable, food safety training architecture can help minimize some of the indirect costs associated with new or novice employees.

Some important topics that should be included in your training materials for how to comply with food code laws include:

  • techniques to prevent cross-contamination;

  • sanitization protocols, particularly the difference between cleaning and sanitizing, how to use a test kit to check sanitizer concentration levels, and when to change the solution;

  • correct food labeled procedures;

  • and special considerations for equipment that handles or ingredients that contain allergens.

Employees should be retrained regularly — at least once a month — and policies should be revised when laws or science change.

Shift from management to leadership.

A strong leader is visible and involved, not siloed in the office all day every day. Scheduling a few hours to be on the floor has a wealth of benefits impacting food code compliance for food retailers, including:

  • setting an example for employees by modeling correct behavior;

  • supervising employees to ensure rules are being followed;

  • and maintaining an open line of communication with frontline workers, which increases engagement and retainment, while helping employees feel comfortable with reporting food safety issues so they can be addressed as they arise.

Furthermore, it’s up to leadership to take advantage of the experience of your auditor. Always accompany your inspector so you can ask questions and learn how to improve operations from a food safety perspective.

Pay Close Attention to the Two Most Common Food Safety Violations

Food code violation 1: Personal hygiene

Personal hygiene rules are simple to overlook, especially if employees aren’t provided with adequate training or access to materials to maintain a level of personal hygiene that is up to food safety standards.

Some critical aspects to train your employees on when it comes to food code compliance for food retailers include:

  • hand washing techniques, frequency, and accessibility of resources;

  • single-use glove policies;

  • hair restraints policies

  • employee health symptoms and reporting policies;

  • jewelry policies (no jewelry other than a plain band wedding ring, including smart-watches);

  • and cell phone policies. (While cell phones are not categorized as jewelry and policies may vary between businesses, the recommended advice is to prohibit cell phones on the floor, but allow breaks for employees to check their phones.)

Food code violation 2: Time and Temperature

Time and temperature is a tricky category simply because there’s a lot of memorization involved for values like minimum internal cooking temperatures, reheating temperatures, cooling time, and more

Pathogens grow most rapidly between 70°F and 125°F (21°C and 52°C), but food held between 41°F and 135°F (5°C and 135°C) is considered time-temperature abused.

Time-temperature abuse most often occurs when food is:

  • cooked to the wrong internal temperature;

  • held to the wrong temperature;

  • or cooked or reheated incorrectly.

Help employees avoid time and temperature abuse by providing frequent retraining and visual aids posted throughout the floor as reminders.

Keeping Compliance with the Food Code

Learning how to comply with food code policies is an ongoing process that will change as your company and the industry evolve. SafetyChain’s FSMA Fridays are a free and convenient way to stay current with the latest updates to food code compliance for food retailers.

About the author: Dr. Karla Acosta Acosta was a health inspector for five years before pursuing her PhD focused on Food Safety Training research, and is now adjunct faculty at multiple universities for graduate and undergraduate students. Her experience uniquely positions her and others on the TAG team to offer tactical food safety advice through a supportive, educational approach.