sional courtesy dictates placing a brief
phone call to determine the best time
for an inspection. By simply stating that
one wants to see the facility in full operation, but not interfere with heavy traffic
patterns at peak times, an inspector is
more to receive an accomodating—and
grateful—response from the operator.
Consider also the distance and travel
time to the site, their hours and scope of
operation (including multi-shifts), and
the facility’s internal operating schedule
when preparing for a visit.
General Rules of Conduct
There are a few rules of conduct that
are universal to inspections. The most
important is never to discuss findings
anyone other than the designated contact person. It is their decision whether
to include anyone else in the deliberations. In addition, never disclose proprietary information to others. This is not
always easy to achieve because the proprietary information may be part of the
inspection report. If there is a question
about language, the contact person
should be consulted. The inspector has
an obligation to be honest and impartial
by avoiding conflicts of interest. When
unethical activity is observed, it should
be verified, recorded and reported. Inspectors should protect any property entrusted to them. And, as much as time
and circumstance permit, the inspector
should always communicate the progress
of the inspection.
Reporting
Report results of the inspection truthfully and in a clear, concise and complete manner. Verify nonconformance
issues and communicate the importance
of findings. There is a reason for everything in regulation. It is the inspector’s
obligation to interpret those reasons specific to the operation under investigation. Ensure that all results are traceable
to the requirements. This is the area in
which most mistakes are made. Reporting minor imperfections found during
the inspection and reporting individuals
are not germane if there is no added
value. Although not a requirement,
every inspection should list positive
practices or noteworthy achievements
that include some aspect of the opera-
tion, system or process that is done very
well.
Finally, no inspector should take
ownership of problems found but serve
as an information conduit. Examples of
this would be putting the operator in
touch with other businesses that faced
similar problems and solved them in a
cost-effective manner, suggesting appropriate vendors and services and, if applicable, providing resources, such as
printed information, notices of training
opportunities, new developments and
code interpretations or anything else
deemed educationally appropriate.
The Bottom Line
I have by no means exhausted this
topic. It is at best a cursory overview and
hopefully a beginning. If we expect our
regulators to protect our food supply
and build confidence in the food production and food retailing industries, we
need to provide them with the knowledge, skills and attributes necessary for
them to do their job effectively. We all
prefer that the outcome of the regulatory
process is because of, rather than in spite
of, their actions. This may sound harsh,
but until there is uniformity in the
process of enforcement, these outcomes
will remain random. Apart from the sanitarian learning about the interpretation
and nuances of regulation, the science of
environmental microbiology and the
fundamentals of sanitation, he or she
also has to learn the skills necessary to
conduct an inspection that includes
sampling and acquire the skill to apply
and communicate this knowledge.
“Inspection” is the single fundamental aptitude we universally expect from
people in our profession, yet it is the
only competency that is neither standardized nor has become part of the formal learning process. Like any other
skill, the art and science of inspection
must be learned and practiced. Collectively, we in the food safety industry
need to ensure that is done correctly.
Forensic sanitarian Robert W. Powitz,
Ph.D., MPH, RS, CFSP, is principal consultant and technical director of Old Say-brook, CT-based R. W. Powitz &
Associates. He can be contacted at
Powitz@sanitarian.com.
