HACCP And Restaurants Part 2

In my previous post, I went over the basics of how a HACCP plan is put together using a home security analogy. I recommend you read that first if HACCP is something that is vague for you. With that said, let’s get into the specifics of how food safety incidents differ between food manufacturers (factories) and restaurants. Along the way we’ll be able to look at restaurant HACCP, were it is strong, and where there are serious gaps in the industry.

The most important difference between a food manufacturer and a restaurant, at least from a food safety perspective, is that when a factory has a food contamination issue, be it allergenic, or pathogenic or by mineral toxin, it is by definition an outbreak. The easiest way to picture this is a vat of contaminated milk. One industrial bulk holding tank may hold between 500 and 800 gallons of milk. If the milk in that tank is contaminated with Listeria monocytogenes, when the milk is packaged and shipped, each carton or bottle may be contaminated, and you could be looking at anywhere from 1000-20,000 people who could be exposed in the states that received that milk. The FDA and USDA must act quickly to pinpoint the vector of an outbreak and pull that material to keep the illness and potential loss of life down to a minimum. As a result of this set up, food manufacturers are under increasing regulatory pressure to have extensive documentation and procedures to make it fast and accurate when a recall must occur.

In contrast, restaurants are often single location establishments that serve customized menu items in relatively small amounts. If a restaurant is handling a shipment of contaminated cucumbers for example, I may get sick because I ordered a Bánh mì sandwich, but if my wife ordered Pho, I will get sick and she won’t. Beyond the lack of even distribution, most restaurants cook food to order, and the cooking itself kills pathogens effectively. In this instance, the tomato on my cheese burger might get me sick, while the tomato soup made from the same tomatoes will likely be safe. So right here we can see that a food contamination issue at a single restaurant will not necessarily effect customers in a way that is easy to detect. Further complicating the matter is the fact that most people who get sick at a restaurant don’t report it (they just have a seriously unpleasant experience in a bathroom for a long period of time). It’s usually only when hospitalizations or fatalities occur that food safety incidents involving restaurants materialize.

With all that in mind, restaurant culture has generally treated HACCP programs as perfunctory, with the main emphasis on holding temperatures, cooking temperatures, sanitation and training of servers. The other main safety issue is keeping the cooking spaces clean (all of these are very justifiable control points). If we are eating at a restaurant that serves deep fried foods, pizza, steak/burgers, or pasta, just about everything is cooked, which means all the restaurant needs to focus on is making sure the kitchen is clean when the shift starts, the food is refrigerated before cooking, cooked to the proper temperature and served quickly enough to prevent contamination (within 4 hours). Keep the staff trained to avoid spreading human caused illness (norovirus) and there should be a minimum of food safety issues.

Where we are running into trouble in our society is in the move towards lightly cooked or non-cooked foods. I want to stop here and make a point that I’ll be coming back to over and over again. The foods that we as a culture have come to understand as the most nutritious and healthy are also the most dangerous from a safety standpoint. We are already seeing the effects of this oddity in our eating habits through increased restaurant incidents, and I expect that we will see more going forward.

Because restaurants respond aggressively to trends, as high income consumers have increased their desire for food without chemical additives and with little to no cooking, restaurants are giving consumers those options, even if they don’t fully understand the need for a change in their safety program. Most restaurants are operating as if the system in which almost everything is cooked is acceptable, even if they are serving primarily uncooked food.

I do not want to be an alarmist, but there is a good chance that cold press juice bars are going to cause serious illness and/or death in the coming year. Sushi restaurants are already seeing this increased issue, and the whole food convenience restaurants model (like Chipotle, but with “fill in the blank”) has also seen issues recently. The reason is simple, but illusive: if the restaurant doesn’t cook the food, any ingredients that came into the restaurant with a pathogen are going to make it to the customer intact. That means the HACCP plan needs to be rearranged to focus as much on keeping infected ingredients out as they do to temperatures and hold times. Where restaurants are doing that is unknowable, but my hunch is that they are not.

The last issue I want to point out here is the improvement in technology used by the FDA and other food safety agencies, and why whole food restaurants are going to have to make the change in their hazard analysis sooner rather than later. The very recall of Sabra hummus is a perfect example of why restaurants should be far more frightened of getting caught for food safety problems then they are. The crazy aspect of the Sabra recall is that they did not have any Listeria found in the hummus at the time of the recall. When I saw that, I was very confused because finding Listeria in a factory is normal, and if regulators are going to force recalls whenever a pathogen is found, we’re going to have a hard time keeping food on our grocery store shelves.

But that is not what happened. Instead, the FDA was able to link the exact strain of Listeria found near the hummus line to an illness in 2015 (over a year previous). That is a huge deal, and restaurants should be very frightened by that. That means that everyone who reports a food poisoning event is going to get their bodily excretions cataloged with the exact strain of pathogen causing the illness, and if that exact strain shows up in a restaurant ingredient, that restaurant is going to be caught dead to rights, and they are going to get shut down. It’s a brave new world in food safety, and my hope is that raw food restaurants get educated quickly on the risks there exposing their businesses to before they wind up on the wrong side a very public mishap.