Food Safety Magazine, June/July 2009

THE SANITARIAN’S FILE
By Robert W. Powitz, Ph.D., MPH
Taking a Closer
at Inspections
Look
^Tt _fT^{here is a common thread that is woven}hroughout our industry, and that is the _{unction of inspection. The act of in-}

Richard North, a practicing Environmental Health Officer in the British Commonwealth, it is packed with good information presented in a light, non-stodgy manner and should be required reading for everyone who professes to be a sanitarian in regulatory practice.

So, unless the fledgling inspector’s mentor was well trained or learned by making and correcting his or her own mistakes, the convention of the act of inspection is by no means uniform; at best it is unpredictable and at worst, a poorly performed inspection can actually do more harm than good.

specting is the core activity universally
performed by public health sanitarians
at all levels of government. In fact, we
often define ourselves as “Health Inspectors,” a descriptive phrase
used worldwide, regardless of the language. However, what makes
this task unique in the U.S. is the fact that training is almost entirely
focused on code interpretation, while the actual act of inspecting is
left to the individual to learn by following a mentor, who also learned
from a mentor or by trial and error. There is very little formal instruc-
tion on the art and science of inspection, with the notable exception
of inspectors in the military. If a new public health sanitarian is lucky,
his or her mentor will have perfected this practice and will pass along
the routine in a correct manner.

Unfortunately, there are neither courses that are readily available to provide instruction in this important skill nor any printed guidelines on the actual performance of conducting food safety-related inspections. Academia does not think it important enough to add this to their environmental health curricula, even though it is defined as a basic skill set for the graduate who aspires to become a sanitarian. I am aware of no formal textbooks on this topic, with the exception of a single, wonderfully written paperback book that deals with this subject in a broader, albeit peripheral manner. The book, Some Observations on Food Hygiene Inspectors, was published in 1999 by Chadwick House Group, Ltd. Although it was written by Dr.

The Need for Training

Before I offer some suggestions on the conduct and performance of inspections, I would like to relate a recent account that reinforces the need for formal training in this arena. I received a call from a food manufacturer, asking for my counsel and presence at his plant during an ongoing FDA inspection. The purpose of the inspection was certainly valid. It was a follow-up to a recent ingredient recall. However, the conduct of the inspection was not exactly the gold standard that one would expect from a government agency. The inspection was conducted by a small army of state and federal employees, most of whom were allegedly “in training.” Because so many individuals descended on the small plant, they had to split into two teams, and my client had to cease production operations to allow supervisory personnel to be with the inspectors as guides and to answer questions. Even though this inspection was not in response to a complaint, nor were food-contact surfaces, end lines, finished products or employees monitored, the on-site activities disrupted production for the better part of two weeks. As if this interruption was not enough, the hoard of inspectors and trainees went from clean, traffic-re-stricted areas to areas open to the environment and back again. While they wore hats and lab coats, they wore no shoe covers and most did not remove their jewelry before entering the plant.