It's the scenario every FSD dreads. Some of your customers are ill and they're blaming your food. The local media is at the door with their cameras and microphones demanding answers. Your boss is on the phone with the same questions, because the media are after him too.
Next up? The lawyers.
Your first thought? "Is it too late for a career change?" A foodborne illness crisis can strike any foodservice establishment at any time, regardless of how well it's run. It may not be your fault, but the buck stops at your door.
In fact, with food safety getting so much play in the popular media, the likelihood for a problem—or the accusation that you have a problem—has grown.
In the past, the average consumer with an upset stomach, a touch of intestinal distress or a mild fever would as often as not pass it off as "the flu."
"Today, people are much more apt to start thinking of where they ate last," says Ruby Puckett, president of FMS Consultants in Gainesville, Florida, and a former foodser-vice director in the healthcare segment. "It's something they've learned from TV reports."
And in a litigious society where it seems every daily mishap must have an identified villain who can be made to pay compensation, foodservice departments are vulnerable to even vague charges alleging food contamination.
Unless they are prepared. "In the future, unless you have a plan, know how you're going to respond, do some proactive work and make sure you have the right people out there telling the right story, you'll have problems with lawsuits," warns Charnette Norton, vice president, Romano Gatland consulting group.
Preparation means three things: 1) having procedures in place that reduce the chances of something happening in the first place, 2) having a plan of action that reduces the damage if something does occur, and 3) having a plan that allows an operation to recover quickly after an incident report, whether the foodservice is shown to be at fault or not.
How serious are the consequences of an outbreak traced to your operation? Just ask the commercial hamburger chain Jack in the Box, whose 1993 experience with hamburger meat tainted with E Coli 0157:H7 resulted in four deaths and has become perhaps the most notorious in recent foodservice history. The company survived thanks to some textbook crisis management follow-through by company executives, but not before the whole episode cost the chain some $150 million.
Naturally, a commercial enterprise has potentially more to lose than the typical onsite operation. An incident at one chain unit can potentially affect sales at every one of its other units—even those a continent away—while onsite incidents remain localized. An outbreak such as the Jack in the Box incident at, say, a college cafeteria in New York is not likely to keep students from eating at their cafeterias in California or Ohio—or even in other New York colleges.
On the other hand, given the way news travels in this internet-powered world, any incident at an institution might well prompt questions from your customers—and perhaps even the local media—about your food and the safety of your operation, and you should always be ready to answer these. Some incident a thousand miles away could be the inspiration for your local TV I-Team in an otherwise slow week. If you have a well-run kitchen, however, it is a good opportunity to toot your own horn.
But if you do have an actual incident, you can expect lost sales, diminished reputations, reprimands and even lawsuits and outright dismissals. Your institution (never mind your foodservice operation) can face loss of business and a public relations nightmare. "Regulatory agencies are not hesitant about putting out press releases," says Vanessa Rugo, crisis counsel with the Boston-based crisis communications firm Clarke & Co. "The news just gets out there in all kinds of ways you can't possibly imagine." Given that prospect, an ounce of prevention could be worth tons of cure.
What Can Go Wrong
The traps lying in wait to cause a foodborne illness incident are many, and prevention is complicated by the frequent turnover experienced by many onsite operations. Poor employee hygiene is a constant concern for managers, and it's complicated by hectic production schedules and chronic understaffing that leave employees hurried and more apt to cut corners on things like washing their hands, changing gloves or getting new utensils when switching tasks.
"We've got all kinds of safeguards in place for our sup-pliers and controls within the unit, but there's always that question of the employee coming in through the back door and what they are bringing into the kitchen," laments Tony Petrucci, director of quality assurance and risk management for business services at Aramark. A former health department manager, Petrucci has an expanded perspective. "Washing hands and changing gloves are my biggest pet peeves," he says. "Having been on the other side of the fence, that is where I saw the most contamination occur."
Take a recent incident in Florida, in which hundreds of guests at a hotel banquet got sick from lettuce that had been contaminated when it was washed in the same sink that raw chicken had soaked earlier. The employee handling the chicken was too busy (and perhaps not trained) to sanitize the basin after he was finished, and the employee prepping the lettuce didn't know (or didn't care) that the chicken had been there earlier.
Likely to happen in your operation? Perhaps not, but the anecdote illustrates how easily contamination can occur in the hectic confines of a production kitchen when there are too many tasks, too little time and too few hands, never mind clean ones.
And as onsite operators put more emphasis on advanced production and cook-to-inventory strategies in order to meet increasing demand with fewer resources, there is greater pressure on maintaining proper cooling, holding and rethermalization temperatures.
"Our grandmothers cooked everything to death and they killed all the bugs, but today we want everything fresh," says Norton. "That increases the risk factor in every kitchen."
And here's a comforting thought: if some of your customers do get sick from something they ate at your food-service operation, it may not even be your fault...but try proving it. The frequent incidence of recalls from manufacturing plants in the last few years highlights how easy it can be for food to become potentially contaminated long before it reaches your storeroom. Manufacturers—and distributors—struggle with the same issues of employee health and hygiene and proper procedures you do.
Fortunately, "improved detection technology today has made it easier to trace pathogens back to their sources than in the past," offers Rugo. That may get you off the hook, but it's hardly an easy thing to do.
"Its very difficult to point fingers because you have working relations with these people," Rugo advises. "If you alienate them, you may not be able to replace their services and products at the same quality, price or service levels—and you may get a tough name in the industry that will make all future relationships more difficult."
And then there are your customers. They can get themselves in trouble and then blame you. How can you account for the goof who gets cream soup to go at 11:30 a.m., leaves it on his desk until 3 p.m., eats it and then lodges a complaint that it made him throw up all night?
A major crisis? No. Annoying? Certainly. Especially because every such incident has to be investigated, chewing up valuable staff time.
Fortunately, there are a number of things you as a manager can do to reduce the likelihood that an incident will occur (the goof factor aside), as well as to mitigate the impact of any that do. One of the most efficient is the adoption of HACCP (Hazard Analysis of Critical Control Points) principles.
"If you have a crisis management plan, you probably have a HACCP plan," says Norton. "If you get into litigation, and you have a HACCP plan, it still may not mean it's not your fault and you'll get off completely, but because you did your due diligence, the amount of the settlement will be reduced considerably."
"We believe HACCP is the best system available to prevent foodborne illness," agrees Jim Doherty, national director of quality assurance and regulatory compliance for Sodexho Marriott Services. At Sodexho Marriott, the commitment to the system is so thorough that "every recipe has HACCP built into it during its development," Doherty claims.
At the unit level, HACCP's focus on the critical control points during the production cycle undergirds everything that is done. "We believe HACCP has to be an integral part of the food safety culture to work effectively," Doherty says.
The prevention, monitoring and documentation principles at the root of a HACCP program are exactly what you need to incorporate in order to mitigate the circumstances that can lead to a foodborne illness incident at your operation.
"In today's world of litigation, it documents that you have made a good-faith effort to make sure that you're not going to have a foodborne illness," Norton explains. "There is that paper trail. The lawyers who specialize in this kind of litigation just love it when someone has no HACCP plan at all because they know that they've really got them."
Basically, HACCP involves assessing the potential dangers in every facet of your operation, identifying the critical control points where hazards are most likely to occur, and then setting up procedures that reduce the risks inherent in these critical control points. This analysis has to encompass the whole operation. Here are some basic questions to start with as you begin your review.
- the menu —what items are most likely to pose health risks if not handled properly? Dairy, egg and protein-based dishes should receive the greatest attention.
- hygiene —is the hand-wash system you have in place not only adequate but convenient enough so that busy employees are not tempted to skip this important task from time to time?
- kitchen procedures —time/temperature abuse and cross-contamination during the prep and cooking processes are perhaps the two leading causes of food contamination. Are cooked and uncooked foods handled at the same station? Where are perishables held before use? Are there enough kitchen tools available so that employees don't feel tempted to cross-use the same implement without proper washing and sanitizing? Are waste receptacles handy and properly sealed? Are cooked foods held in temperature-controlled environments? How easy is it to clean prep areas?
- storage —are storage areas dry and pest-free? Is there adequate shelving, and of the proper types? Are there proper product rotation procedures in place and are they followed? l servery —are foods kept at the proper temperature (and is the holding equipment properly calibrated?) and are they adequately covered to prevent contamination from airborne pathogens? Are hairnets, gloves and aprons always available and used?
- cleanup —uneaten food and soiled servingware provide prime bacterial breeding grounds. Are scraps promptly disposed of? Are prep and serving areas both cleaned and sanitized? Is unused servingware removed and washed if it has been sitting out?
A crucial component in the HACCP equation, and in your crisis contingency planning, is the detailed monitoring and record keeping at each critical control point.
If a crisis does occur, one of your best defenses will be the thoroughness of your recordkeeping, which can prove that your operation was always following accepted safety guidelines in the handling and preparation of the food you serve (for a thorough discussion of recordkeeping strategies, see the book reviewed below).
You also have a responsibility to see that your staff and managers are trained in the proper handling and preparation of food, the proper use of equipment, sanitation processes (cleanup, scrap disposal, etc.) and personal hygiene. Written policies should be readily available for all these areas.
Implementing accepted industry practices for the safe handling and serving of food is also critical. Make sure that all the tools necessary for following through (safety equipment, cleaning supplies, etc.) are always readily available.
Purchasing is another area where you can minimize potential problems down the line. Deal only with reputable vendors and suppliers whose product quality and internal procedures have a proven track record.
Preparing for the Unthinkable
To paraphrase Rudyard Kipling, if you are able to keep your head about you while others are losing theirs, you must have a pretty solid contingency plan in place. The essence of a good plan is one that spells out roles for everyone so that all needful tasks are completed, everyone knows what to do and efforts aren't duplicated.
The contingency plan should account for the following: 1) getting reliable information on what happened, 2) dealing with the immediate problem, 3) communicating your operation's professional handling of the situation to key audiences, 4) tracing the cause of what happened and 5) reaching a conclusion.
Getting to the bottom of what actually occurred during an alleged foodborne crisis incident requires careful pre-planning because when one does occur, emotions will run high, pressure to come up with something will be intense and facts will often be hard to come by, unlike rumors, which will be epidemic.
What you will need to find out is what happened, to whom, when and where. For this step, having a pre-prepared Record of Complaint form such as the one developed by Puckett (p. 64), is very helpful because it documents all the pertinent facts. Together with your ongoing production and food handling records, it will be a powerful tool for sorting out what actually happened.
While you are sorting through the rumors, you will at the same time have to deal with several audiences, the most important probably being the person or persons affected and their families. Whatever your opinion of the validity of the claim, you cannot afford to appear anything less than concerned for their well-being (after all, they are sick, perhaps seriously so).
Other critical audiences are your other customers, your superiors at your institution and anyone else who might be affected by a crisis, and the media (see sidebar on p. 37). They will all need to know that you are on top of the situation and have taken all reasonable precautions both to ascertain the facts and to minimize any potential harm.
The worst thing you can do is to say anything you will have to retract later. Credibility is your greatest asset and as long as you convey the impression that you are acting responsibly you will tend to get the benefit of the doubt. No one will blame you if you don't have all the facts immediately. A pre-prepared "holding statement" that acknowledges the seriousness of an incident and conveys your determination to get to the bottom of it is a good thing to have as part of your contingency plan.
"One of the most important things is that you have to create the impression that health and safety are your top priori-ties," counsels Rugo.
Tracing the cause of an illness incident is like detective work. You have to interview the principals (the victim if possible, as well as your employees who were on duty at the time and others who may have eaten the same food at the same time), secure "evidence" (samples of the suspected food item, if available) and review records (sales data, production documentation, etc.). Document all your steps.
The large contract management companies have detailed and elaborate procedures in place to handle any potential incidents. Petrucci is the point man for Aramark's units in business dining, corrections, vending and commissary operations while counterparts handle other segments like schools. Should an incident be reported, Petrucci would be contacted. After a formal assessment of the situation, he alerts the appropriate parties (insurance carrier, legal department, media relations) and oversees the investigation into what happened. The unit manager cooperates with all this of course, but the heavy lift-ing—especially dealing with the media, if necessary—is done by the professionals. "All communications from the press should go through our PR department," Petrucci stresses. FM NOTE: Ruby Puckett's "Foodborne Illness Record of Complainant" form can be found on page 64.
When A Complaint Is Lodged
Here is an example of a policy for dealing with a foodborne illness complaint in a healthcare setting. It is reproduced from the book HACCP: The Future Challenge, p. 24.
Graciously accept the complaint. Secure all pertinent data, such as name, address, date, time, meal, contents of meal, when and where the food was purchased/served, if food was eaten when purchased, or refrigerated, when symptoms occurred; the names of any others who ate the same food; whether medical attention was sought, and if so the name of the physician.
Take a food history from the complainant, if possible, of all meals and snacks eaten before and after the suspected meal.
Listen carefully to the complaint. Don't admit liability or offer medical advice. Don't diagnose or suggest symptoms. Don't introduce symptoms. Record only what the person said. Note the time the symptoms started. Remain polite and concerned.
Try to preserve a sample of the suspected food for later microbiological testing. Label and store (refrigerate or freeze). Remove from sales.
Evaluate the complaint. Is it only one person, or are there multiple complainants? Does it describe a legitimate illness? What is the attitude of the complainant?
Contact the appropriate people: the owner, general manager, hospital administrator, infection control and risk management, etc.
Contact the local health department (follow the regulations for the individual state). Deal positively with all regulatory agencies. Allow inspectors to inspect the property. Provide requested data. Be cooperative.
Review the information and start an internal investigation to include:
If only one or two customers complain, offer refunds or gift certificates. If more complaints are received, follow the established local health regulations
Arrange for medical services (in healthcare establishments with Nursing, Infection Control and Employee Health).
Have food tested by an outside laboratory that microbiologically tests food. Deal with the media positively. Provide accurate data. Answer only the questions they ask. Avoid jargon. Remain calm and professional. Tell the truth. Do not try to bluff or give out misinformation.
Continue to investigate. Take corrective action as appropriate.
Review outcome with all managers and staff. Change policies and procedures, and make corrections, as appropriate.
As appropriate, file for future reference.
Media Relations Dont's
If an incident is serious enough, you will probably have to deal with media coverage. Do it wrong and the damage to your and your institution's reputation could be far-reaching. Here are some tips from Vanessa Rugo, crisis counsel with the Boston-based crisis communications firm Clarke & Co.
Don't have multiple spokespeople. Determine a single spokesperson beforehand who will speak for the institution. Having multiple conduits of information will muddle the message and may result in contradictory pronouncements that destroy your credibility.
Don't minimize the situation, especially before all the facts are in. Blythely dismissing a potentially serious situation with an "it's all taken care of" or "it's no big deal" attitude only communicates that your institution is either clueless or uncaring.
Don't stonewall. If you honestly don't have information, say so and promise to deliver it once you do (and then follow through). But if you appear to be evading legitimate questions, you will not only invite more questions, but they will come packaged with a healthy dose of skepticism that will make your job even harder.
Don't go out there unprepared. Whoever speaks for the institution should either be a media relations professional or someone who has had some preparation in dealing with the media. Especially in a potentially incendiary situation like a food safety scare, the spokesperson is apt to get "loaded questions."
Don't expose the top executive until it's safe. While it is tempting to have the top person in your organization step out front in a crisis, Rugo counsels otherwise for most situations. She says it's better if the top person waits until there is "good news" to deliver later in the crisis ("we've traced the problem," "here is what we're doing to make sure nothing like this happens again," etc.)
At Sodexho Marriott Services, some leading-edge technology is being employed to audit compliance with food safety procedures across the company's thousands of managed units. The company's loss prevention managers use hand-held computers developed by mobile computing software vendor Steton Technology Group to gather data during the audit process. The data is then downloaded to a central clearinghouse where it can later be analyzed.
"The reports allow us to analyze trends and identify best practices and failure points," says Jim Doherty, national director of quality assurance and regulatory compliance. "It helps us address areas of concern quickly."
For the field auditors it means less time spent on paperwork and more time counseling food service units on how to improve quality and safety and ensure that units comply with the standards mandated by the company. And in case of an alleged incident in which a Sodexho Marriott operation's offerings might be called into question, the company has a verified audit trail it can produce to confirm that its procedures were followed.
FOR FURTHER READING...
HACCP: The Future Challenge, by Ruby Puckett and Charnette Norton, is a comprehensive guide to implementing and running an onsite foodservice operation according to Hazard Analysis of Critical Control Points (HACCP) principles. Although it is technically written for healthcare foodservice, operators in all onsite segments will find it immensely informative and useful. In addition to chapters on HACCP, other sections cover foodborne illnesses, prevention strategies and crisis management. The volume is brimming with charts, tables and sample forms for everything from a list of common kitchen pests (not including administrators or other top brass) and foods most frequently identified with foodborne disease, to a hazard flow chart, a recipe hazard evaluation form and a cleaning/sanitizing schedule. To purchase a copy, contact the University of Florida, Dept. of Independent Study, at (800) 327-4218