Frequently asked questions, nuances, and clarifications from my inspections
* Expertise is an ongoing journey and a mind set rather than a destination. These answers and clarifications are based upon my many conversations with clients and state inspectors. As with all rules and regulations, there is some room for individual interpretation. Thanks to Gary and Ed at the Orange County Department of Health for their assistance.
HOW FAR MUST CHEMICALS BE FROM FOOD?
Common sense dictates chemicals and food must be separate, but what about sealed chemicals and sealed foods? I ran into a situation this month where an inspector had cited a client for having an unopened bottle of chemicals next to an unopened bottle of vinegar, on the same shelf, both were clearly labeled, yet this was cited as a high priority violation.
Following up with the DBPR, the rule is "completely separate," one of those "subject to interpretation" types of rules. These same rules apply to sanitizer. Make sure sanitizer buckets are not stored on a shelf near food, even food in closed containers. Many inspectors will not cite this as a violation but some will. Where ever you put sanitizer, make sure it is at least 6 inches above the floor.
I HAVE A BACK FLOW PREVENTER ON MY FAUCET WITH A SPLITTER, WHY IS THE INSPECTOR TELLING ME I NEED ONE ON EACH SIDE?
After a bit of research, I have gotten a straight answer to this question. Most of you have a faucet in your mop sink like this one:
This faucet clearly has a vacuum breaker "bell" on it. Once you add a splitter with two hoses, you double the potential amount of water that can be siphoned into the public supply and the pressure no longer works with the bell. This faucet is designed to handle only one attachment. It is important to note, the back flow preventers must be attached after the split, not before. You can get a vacuum breaker at Lowe's or Home Depot for about $6, so spend $12 and take this issue off the table. If 1/2 of your split is used to supply water to chemicals, the chemical dispenser may or may not have a back flow preventer on it.
CLARIFICATION ON BIG 5 FOODBORNE ILLNESS REQUIREMENTS.
Last month I wrote in my newsletter that inspectors are starting to ask hourly staff members about the Big 5 Foodborne illnesses and the Big 8 allergens. Certified professional food managers are expected to have these memorized but it is different for hourly staff members. An inspector will ask one of your staff members randomly about the Big 5. The hourly staff member only needs to be able to show the inspector where the information is located. I send all of my clients this information. Post it on a board, let you staff know where to find this info and you are covered with the inspector.
UNWASHED PRODUCE
As with all of us, inspectors develop a routine and pet peeves. The health code changes rapidly as events develop. For example, ten years ago, the Norovirus was relatively unknown. A couple of big time outbreaks on cruise ships made it more commonly known and it is now one of the Big 5. It usually takes inspectors a while to "catch up" to the changes, they are busy, they deal with staff turnover, and like us, their level of urgency is often determined by the supervisor's hot button issues. One of the standards adopted in 2013 by Florida that has been inconsistently enforced is the policy regarding separation of unwashed produce from ready-to-eat food. A common high priority violation is a service staff member failing to wash "skin-on" fruits prior to cutting them or prepping them. Lemons, limes and oranges cut by the front of house staff are common mistakes.
Unwashed produce, fruits or vegetables cannot be stored above "Ready to Eat" So if you have bagged lettuce, cut lettuce, diced tomatoes, or any other ready to eat product it must be stored above or away from unwashed produce. This is a high priority violation, treated the same as raw chicken over lettuce (I know all of you cringe when I say this because it has been drilled into your heads since day one in the business, make your staff see it the same way).
EGGS
There has been a lot of confusion about the proper storage of raw eggs. Eggs are a bit odd because shelled eggs can actually be held as high as 45°. I've seen inspectors treat eggs as poultry, that is, always on the bottom shelf. The food code distinguishes raw shelled eggs from poultry in one important way, they need to be on bottom shelf, but cannot be underneath raw meat as raw chicken can be. So when you store eggs, the best solution is to store them on a bottom shelf with items like cheese or milk above them. That way, you cover all the bases with various interpretations. Hard boiled eggs are treated like Ready to Eat food. Any other version other than raw eggs in the shell must be held at 41° or less.
COOLER CARE & MAINTAINING TEMPERATURE
Refrigeration is a massive expense for restaurants, both in the prices of the equipment and the prices of the repair service, here are a few tips to follow to troubleshoot, maintain, and manage this high dollar equipment.
1) Check the plug. Don't laugh, I bet all of you have called out a repair tech only to discover the cooler was not plugged in. Always check the plug.
2) Check the breaker, sometimes in Florida we get lightning, power surges can pop a breaker and kill your refrigeration.
3) Clean the coils. The coils on your coolers "breathe" 24/7 much like we do. When our lungs inhale too much dirt, dust, grease, we cough or sneeze to get rid of it. Since coolers don't, their coil lungs need to be cleaned manually. A long soft bristle brush and some soapy water will do the trick. Be careful not to bend the "fins" on the coils, they bend about as easily as aluminum foil.
4) Make sure fans are not obstructed. If your cooler has exposed fans like many drawer coolers do, it is possible a piece of film from a pan has come off and wrapped around one of the cooler fans, check this before you make that costly phone call. Also check for film in front of coils or maybe even a cleaning cloth. Anything obstructing the flow of air in the coolers will dramatically effect your temperatures.
5) Product levels. Especially for food in cooler tops, make sure to keep the level of product below the line in the pans, plastic pans will have a line, metal pans will be dimpled at the fill level. Keep the tops closed as much as possible, especially in the middle of the day, when it is hot outside and all your hot equipment is on. Cooler tops are like regular ice coolers, they cool very well when an item is "submerged" in the ice, not so well on top of the ice. In closed coolers, the air circulation keeps product much colder just like a windy cold day feels much colder than a windless cold day. Product has to be submerged in the cooler top to keep temp.
6) Don't insulate product from the cold. Portion controls like souffle cups, squeeze bottles, double inserts and the like create additional layers of air, metal or plastic between the product and the cold. If you have cheese in a souffle cup with a lid inside a pan, there are four layers of insulation between the cold and the product, air in the cup, the plastic of the cup, air in the pan and the material of the pan. Since there is no circulation, the product often never gets cold. In addition, portioning is usually done for the shift and the portions often go directly into the cooler top or pan before they can cool. My tips. For squeeze bottles, put ice inside the pan in which they are stored so the product is directly in contact with cold. For portion cups and souffles, put them on a sheet tray after you potion them, uncovered in the walk in until they are below 41°, then cover and store in the bottom of your line coolers. Put them up top a couple at a time as needed.
7) Line coolers are designed to hold temperature, not to lower it. Walk-ins, freezers and ice baths are for cooling. Any time an item is being prepped, portioned or worked with at room temperature, please put it back into the walk in, freezer or ice bath until it is down to temp. Many items out of temp on the line were never properly cooled in the first place. Anytime an item is heated and then cooled, it must be separated into smaller batches to be cooled properly. You have 2 hours to get the product below 70° and 4 hours after than to get the product to 41°.
8) Periodically check defrost timers. Defrost timers on coolers do not usually have a battery back up. If you lose power, your circuit breaker pops, or you unplug your coolers when you move them to clean, your defrost timers become less and less close to the actual time. Unplugging your coolers for just 5 minutes to clean each night will result in the timer being off more than an hour after just two weeks. Murphy's law says your coolers will go into defrost mode while they are uncovered in the middle of the day you have a health inspection. If you have a monthly maintenance company, they should be checking this, but ask them about it. Like doctors, many techs will check only the obvious. Each cooler is different and most manuals are available on the manufacturer's website. If you do this in house, please make sure the person in charge has a working knowledge of refrigeration. Often, timers are located inside coolers near fans and electricity.
Follow these few tips before you call a repair service and to prevent temperature issues. Do this each time you encounter a temp problem and you will pay for my services many times over each year. All of these solutions are low or no cost, only a re-engineering of existing processes. Find a key employee with career goals, show he/she what you want done, put that person in charge of driving these results. Tell them part of the job is to educate co-workers. As an operator, you have many conflicting demands on your time, turn a key member of your staff, or two, into bulldogs in this area.
I HAVE A BACK FLOW PREVENTER ON MY FAUCET WITH A SPLITTER, WHY IS THE INSPECTOR TELLING ME I NEED ONE ON EACH SIDE?
After a bit of research, I have gotten a straight answer to this question. Most of you have a faucet in your mop sink like this one:
CLARIFICATION ON BIG 5 FOODBORNE ILLNESS REQUIREMENTS.
Last month I wrote in my newsletter that inspectors are starting to ask hourly staff members about the Big 5 Foodborne illnesses and the Big 8 allergens. Certified professional food managers are expected to have these memorized but it is different for hourly staff members. An inspector will ask one of your staff members randomly about the Big 5. The hourly staff member only needs to be able to show the inspector where the information is located. I send all of my clients this information. Post it on a board, let you staff know where to find this info and you are covered with the inspector.
UNWASHED PRODUCE
As with all of us, inspectors develop a routine and pet peeves. The health code changes rapidly as events develop. For example, ten years ago, the Norovirus was relatively unknown. A couple of big time outbreaks on cruise ships made it more commonly known and it is now one of the Big 5. It usually takes inspectors a while to "catch up" to the changes, they are busy, they deal with staff turnover, and like us, their level of urgency is often determined by the supervisor's hot button issues. One of the standards adopted in 2013 by Florida that has been inconsistently enforced is the policy regarding separation of unwashed produce from ready-to-eat food. A common high priority violation is a service staff member failing to wash "skin-on" fruits prior to cutting them or prepping them. Lemons, limes and oranges cut by the front of house staff are common mistakes.
Unwashed produce, fruits or vegetables cannot be stored above "Ready to Eat" So if you have bagged lettuce, cut lettuce, diced tomatoes, or any other ready to eat product it must be stored above or away from unwashed produce. This is a high priority violation, treated the same as raw chicken over lettuce (I know all of you cringe when I say this because it has been drilled into your heads since day one in the business, make your staff see it the same way).
EGGS
There has been a lot of confusion about the proper storage of raw eggs. Eggs are a bit odd because shelled eggs can actually be held as high as 45°. I've seen inspectors treat eggs as poultry, that is, always on the bottom shelf. The food code distinguishes raw shelled eggs from poultry in one important way, they need to be on bottom shelf, but cannot be underneath raw meat as raw chicken can be. So when you store eggs, the best solution is to store them on a bottom shelf with items like cheese or milk above them. That way, you cover all the bases with various interpretations. Hard boiled eggs are treated like Ready to Eat food. Any other version other than raw eggs in the shell must be held at 41° or less.
COOLER CARE & MAINTAINING TEMPERATURE
Refrigeration is a massive expense for restaurants, both in the prices of the equipment and the prices of the repair service, here are a few tips to follow to troubleshoot, maintain, and manage this high dollar equipment.
1) Check the plug. Don't laugh, I bet all of you have called out a repair tech only to discover the cooler was not plugged in. Always check the plug.
2) Check the breaker, sometimes in Florida we get lightning, power surges can pop a breaker and kill your refrigeration.
3) Clean the coils. The coils on your coolers "breathe" 24/7 much like we do. When our lungs inhale too much dirt, dust, grease, we cough or sneeze to get rid of it. Since coolers don't, their coil lungs need to be cleaned manually. A long soft bristle brush and some soapy water will do the trick. Be careful not to bend the "fins" on the coils, they bend about as easily as aluminum foil.
4) Make sure fans are not obstructed. If your cooler has exposed fans like many drawer coolers do, it is possible a piece of film from a pan has come off and wrapped around one of the cooler fans, check this before you make that costly phone call. Also check for film in front of coils or maybe even a cleaning cloth. Anything obstructing the flow of air in the coolers will dramatically effect your temperatures.
5) Product levels. Especially for food in cooler tops, make sure to keep the level of product below the line in the pans, plastic pans will have a line, metal pans will be dimpled at the fill level. Keep the tops closed as much as possible, especially in the middle of the day, when it is hot outside and all your hot equipment is on. Cooler tops are like regular ice coolers, they cool very well when an item is "submerged" in the ice, not so well on top of the ice. In closed coolers, the air circulation keeps product much colder just like a windy cold day feels much colder than a windless cold day. Product has to be submerged in the cooler top to keep temp.
6) Don't insulate product from the cold. Portion controls like souffle cups, squeeze bottles, double inserts and the like create additional layers of air, metal or plastic between the product and the cold. If you have cheese in a souffle cup with a lid inside a pan, there are four layers of insulation between the cold and the product, air in the cup, the plastic of the cup, air in the pan and the material of the pan. Since there is no circulation, the product often never gets cold. In addition, portioning is usually done for the shift and the portions often go directly into the cooler top or pan before they can cool. My tips. For squeeze bottles, put ice inside the pan in which they are stored so the product is directly in contact with cold. For portion cups and souffles, put them on a sheet tray after you potion them, uncovered in the walk in until they are below 41°, then cover and store in the bottom of your line coolers. Put them up top a couple at a time as needed.
7) Line coolers are designed to hold temperature, not to lower it. Walk-ins, freezers and ice baths are for cooling. Any time an item is being prepped, portioned or worked with at room temperature, please put it back into the walk in, freezer or ice bath until it is down to temp. Many items out of temp on the line were never properly cooled in the first place. Anytime an item is heated and then cooled, it must be separated into smaller batches to be cooled properly. You have 2 hours to get the product below 70° and 4 hours after than to get the product to 41°.
8) Periodically check defrost timers. Defrost timers on coolers do not usually have a battery back up. If you lose power, your circuit breaker pops, or you unplug your coolers when you move them to clean, your defrost timers become less and less close to the actual time. Unplugging your coolers for just 5 minutes to clean each night will result in the timer being off more than an hour after just two weeks. Murphy's law says your coolers will go into defrost mode while they are uncovered in the middle of the day you have a health inspection. If you have a monthly maintenance company, they should be checking this, but ask them about it. Like doctors, many techs will check only the obvious. Each cooler is different and most manuals are available on the manufacturer's website. If you do this in house, please make sure the person in charge has a working knowledge of refrigeration. Often, timers are located inside coolers near fans and electricity.
Follow these few tips before you call a repair service and to prevent temperature issues. Do this each time you encounter a temp problem and you will pay for my services many times over each year. All of these solutions are low or no cost, only a re-engineering of existing processes. Find a key employee with career goals, show he/she what you want done, put that person in charge of driving these results. Tell them part of the job is to educate co-workers. As an operator, you have many conflicting demands on your time, turn a key member of your staff, or two, into bulldogs in this area.
