• Finally, if we look at the world’s diverse culinary offerings, they are all
made from animal and vegetable matter
with a little bit of minerals used as seasoning. Only their origins, names and
appearances differ. Potentially hazardous
foods remain potentially hazardous
foods, even under the most bizarre conditions. In short, ethnic foods actually
are not that much different from what
Americans are used to.
“Our basic and, in most instances, only tool for
adjudging ethnic food safety is and will remain
the FDA Food Code.”
An Augmented Approach to
Inspections
Aside from the ideal situation of applying huge doses of education and
training with sensitivity to ethno-cultural
differences, the approach to assessing exotic menu items and kitchen practices
for compliance with food safety regulations requires a bit of departure from
convention. This approach in no way
compromises our primary focus on
foods from unsafe sources, inadequate
cooking, improper holding temperatures,
cross-contamination, unsanitary equipment and poor personal hygiene. I must
admit that with many ethnic establishments, agreement on what constitutes
proper personal hygiene is still the most
difficult to achieve, evaluate and enforce.
Therefore, several of my colleagues
and I have redoubled our efforts to
apply evaluation methods that rely on
more quantitative criteria. We have done
this by incorporating three food safety
tools into our inspection protocols.
These include a comprehensive menu review and a modified “as-built” plan review to match the menu items with the
kitchen; an abbreviated form of Hazard
Analysis and Critical Control Points
(HACCP) or “Street HACCP” that
specifically targets high-risk ingredients
and methods of preparation, packaging
and service; and the use of additional
field instruments to allow more objective
assessments of time/temperature and determine which foods are potentially hazardous. While these three strategies may
not be particularly inventive, we have
found that by shifting our approach to
ethnic food safety slightly outside of
convention, we have achieved a better
understanding of the ethnic food system
within the limited time and resources
given to us.
Menu and “As-built” Plan
Review
The menu review provides me with
the “what.” The modified as-built plan review gives me the “how.” To begin, no
matter how well-known an ethnic restaurant is to the community or how many
times it has been inspected, I start each
visit with a comprehensive menu review.
In fact, I insist on obtaining a copy of the
menu well in advance of my inspection.
Although this applies to all restaurants, it
is particularly important in the assessment of ethnic foods. As a sanitarian, I
need to know what goes into each menu
item, including any unconventional ingredients coming from unconventional
sources. A comprehensive menu review
completed in my office, with the help of
the Internet, lets me do this quite nicely.
I start each menu review by using the single most valuable resource I know of: A
Food Inspector’s Guide to Ethnic Foods in
Michigan, by Dr. Lillian G. Po of Michigan State University. This manual is in
the public domain and can be downloaded as a portable document format
(PDF) file from the Internet by typing
the title into any search engine. While
this guide primarily covers Asian and
Mexican foods, it does so with a unique
approach. It focuses on practical food
safety issues and challenges in evaluating
the different ethnic dishes by listing the
various ingredients and describing in detail the cooking and preparation
processes for each menu item catalogued.
Probably the most valuable section of
this 158-page manual is its glossary of
terms. While I’m fairly well versed in
English and get by comfortably in German, I have very little acumen in the
other 6,700 languages in the world. The
glossary really helps me muddle through.
The modified as-built plan review lets
me match each menu item to the
kitchen, storage and service areas, with
an eye toward design flaws and conditions contributory to foodborne hazards.
•
The physical layout of the facilities, the
processing equipment (including those
items specific to cooking and refrigeration), the utensils, the traffic patterns
and the sanitation capabilities are evaluated, along with any specifications of existing material that meet food protection
and production requirements. By completing this exercise, the modified as-built plan review can be integrated with
requirements detailed in the Food Code.
A Modified Approach to
HACCP
For most applications to ethnic eateries, I prefer a modified approach to
HACCP. From our vantage point,
“Street HACCP” would be particularly
attractive as a component of the regulatory inspection. “Street HACCP” that
focuses on HACCP steps 2, 4 and 7
seems best suited for this application
and will meet the least resistance from
the owner/operator. These HACCP
steps include:
• Identifying CCPs. These are points in
food preparation, from raw state
through processing, storage and serving to the customer, which have the
greatest risk of promoting a foodborne misadventure. These also represent the points at which the hazards
can be controlled or eliminated.
Establishing procedures to monitor
the CCPs. This is basic and straightforward time and temperature control
that can be accomplished using an inexpensive thermocouple or thermistor thermometer, leaving the
preference as well as the practice to
the owner/operator. In this way, ownership for food safety is formally established.
• Establishing effective record keeping
to document the modified HACCP
system. I let the owner/operator decide on the level of documentation,
but encourage, at a minimum, two-hour temperature monitoring inter-
