Most of Michigan’s food regulatory programs are based on enforcement of the Michigan Food Law and the federal Food Code. The Food Code that Michigan and most states adopt has standards built on:
- Scientific research on what practices make or keep food safe
- Actual outbreak investigations that have identified the most common ways people become ill from food.
The Food Code uses the control of risk factors to ultimately reduce illness. Just as reducing smoking is expected to lead to reduced rates of lung cancer, reducing the following five risk factors is expected to reduce the number of people getting sick from food.
The top 5 foodborne illness risk factors are:
- Improper hot/cold holding temperatures of food that requires temperature control for safety.
- Improper cooking temperatures of food
- Dirty and/or contaminated utensils and equipment
- Poor employee health and hygiene
- Food from unsafe sources
The Food Code contains violations grouped into three categories.
- Priority (P)
- Priority Foundation (Pf)
- Core (C)
The top five foodborne illness risk factors are all contained in the P and Pf violations and evaluations focus on identifying and correcting these type of violations as quickly as possible.
MDARD’s goal during routine evaluations of food businesses is to find no “Priority” or “Priority Foundation” violations 90 percent of the time. Currently, we only find about 57 percent of establishments free of a P or Pf violation during a routine evaluation. Helping food establishments eliminate P and Pf violations to reach the 90 percent goal is the primary reason MDARD is currently working to add staff and improve technology. We want our inspectors to be able to provide information and advice to food businesses to help them reach their own compliance goals, improve food safety at their establishments, and protect the investment they have made in their businesses and customer bases.
Knowing the most common Food Code violations cited by MDARD inspectors in the past year may help you eliminate these from your establishment.
Priority violations:
- Improper holding temperature for food (cited 439 times)
- Utensils and food-contact surfaces not sanitized (cited 141 times)
- Food not protected from cross-contamination (cited 133 times)
- Employees not washing hands when needed (cited127 times)
- Toxic materials not stored separately from food (cited 123 times)
Priority Foundation violations:
- Lack of test kit to measure sanitizer concentration (cited 594 times)
- Hand sinks without soap or paper towels (cited 549 times)
- Dirty equipment and utensils (cited 452 times)
- Food not marked with date to indicate last use by or sell by date (cited 329 times)
- Hand washing sinks not accessible or used for other purposes (cited 302 times)
- Person in charge not properly assuring food safety (cited 191 times)
- Lack of thermometers to measure food temperatures (cited 179 times
- Lack of proper pest control (cited 139 times)
Under the Food Code, definitions for Priority (P) and Priority Foundation (Pf) are:
- “Priority item” means a provision in the Food Code whose application contributes directly to the elimination, prevention or reduction to an acceptable level, hazards associated with foodborne illness or injury and there is no other provision that more directly controls the hazard.
- “Priority item” includes items with a quantifiable measure to show control of hazards such as cooking, reheating, cooling, and handwashing.
- “Priority foundation item” means a provision in the Food Code whose application supports, facilitates or enables one or more Priority items.
- “Priority foundation item” includes an item that requires the purposeful incorporation of specific actions, equipment or procedures by industry management to attain control of risk factors that contribute to foodborne illness or injury such as personnel training, infrastructure or necessary equipment, HACCP plans, documentation or record keeping, and labeling.
I encourage you to work closely with your MDARD food inspector if P or Pf violations are found in your establishment during a routine evaluation. By working together, we can limit future violations, protect or financial investment in your business, improve the overall food safety at your food establishment and protect your customers from foodborne illness.
