The Impact of Switching to Risk-Factor Inspections at High-Risk Establishments in Hennepin County, Minnesota
Zamzam Abdirahman
Environmentalist at Hennepin County Environmental Health Department
Abstract
Following guidelines from the Minnesota Food Code and Hennepin County Environmental Health Department conducts approximately 6,300 retail institution food inspections per year. Previous studies tell us that the reduction of risk factors contributes to the reduction of foodborne illnesses. The objective of the study was to determine if there is a relationship between risk-factor inspections conducted during COVID-19 pandemic and routine inspections conducted prior to COVID-19 pandemic. A total of 672 inspection reports were analyzed to determine whether a priority 1 violation occurred between June 2019 and August 2019 (pre-pandemic) and between June 2021 and August 2021 (during the pandemic). Risk-factor inspections focused on evaluating violations 1 to 29 on the Hennepin County inspection report, while routine inspections evaluated all violation types, 1 to 60. In 2019, 321 priority 1 violations were reported and of those, 41% were related to the violation category of time/temperature control. The common violation category observed at a small facility was time/temperature control for safety foods (TCS). Seventy-three percent (73%) of the total inspections of small facilities had a follow-up inspection in 2019. In 2021, 205 priority 1 violations were reported, and of those, 41% were related to the violation category of time/temperature control. The common violation category observed at small facilities was time/temperature control for safety foods. Fifty percent (50%) of the total inspections had a follow-up inspection in 2021. In conclusion, focusing on a risk-factor approach for inspections did not influence the number of Priority 1 violations observed.
Key words: Risk-factor inspection, Hennepin County, Priority 1 violation
The Impact of Switching to Risk-Factor Inspections at High-Risk Establishments in Hennepin County, Minnesota
Background
The National Restaurant Association estimates that more than 200 million United States consumers visited a sit-down restaurant in 2018 (National Restaurant Association, 2018). In Hennepin County, MN, restaurant inspections are one of a number of measures intended to enhance food safety and potentially reduce foodborne illness through compliance with the Minnesota Food Code, and Hennepin County Ordinances. Food establishments are licensed and inspected by city, county, or state health departments, on a routine basis. Licenses are issued and categorized by the food safety risk associated with the establishment. High risk food establishments practice complex food handling techniques such as: cooking and/or cooling potentially hazardous foods; serving any raw or undercooked food products; and conducting any specialized processes. Priority 1 violations are defined by the Minnesota Food Code as “a provision in this Code whose application contributes directly to the elimination, prevention, or reduction to an acceptable level of hazards associated with foodborne illness or injury, and there is no other provision that more directly controls the hazard” (Minnesota Food Code, 2019). Priority 1 violations also include an item with a quantifiable measure to show control of hazards such as cooking, reheating, cooling, and handwashing. Routine inspections for high-risk facilities are conducted once every 12 months and are unannounced.
The Hennepin County Environmental Health Department utilizes the Minnesota Food Code, which was adopted in March 2019, and established categories for risk factors that were the focus of this study: hygiene practice and supervision; food receiving and protection; microbial destruction; equipment and utensils; plumbing and refuse; vermin and toxins; and grounds for emergency closures. The risk factor categories overlap with the FDA Model Food Code’s key public health interventions. Due to the COVID-19 pandemic, routine inspections were adjusted to ensure the safety of inspectors and restaurant owners/patrons. Before the COVID-19 pandemic, routine inspections included evaluating all potential risk-factor factors as well as non-risk-factor factors, which include floors, walls, and ceilings. The Hennepin County Environmental Health Department adjusted its inspection protocol in April 2019, by focusing on establishments listed as high-risk, and addressing the five key public health interventions established by the FDA Model Food Code. The risk factors examined were previously stated. The objective of this study was to determine if there is a relationship between risk-factor inspections conducted during COVID-19 pandemic and routine inspections conducted prior to COVID-19 pandemic.
Problem Statement
The impact on violations of moving from regular inspections to risk-factor inspections of high-risk food establishments during the COVID-19 pandemic in Hennepin County, MN is unknown.
Research Questions
What was the percentage of high-risk violations observed June 2019 to August 2019 (pre-pandemic) and June 2021 to August 2021 (during the pandemic)?
What were the predominant types of high-risk violations observed prior to and during the pandemic?
What violations were observed in establishments categorized as small compared to those categorized as large?
What was the rate of follow-up inspection after routine inspections vs. risk-factor inspections?
Methodology
This study sought to evaluate each establishment’s Priority 1 violations observed from March 2019 to March 2020 and from April 2020 to April 2021 from high-risk restaurants licensed and inspected by Hennepin County Environmental Health Department. To determine the relationship between routine inspections completed prior to COVID-19 and risk-factor inspections completed during COVID-19, reports of inspections conducted March 2019 to March 2020, and April 2020 to April 2021 were collected. Hennepin County’s Digital Health Department system (DHD) was used to collect the inspection reports performed. The following data were used from the inspection reports: facility name; facility ID number; size of the facility; inspection date; whether a follow-up was generated; if violations were corrected on site; the city of the facility; and the priority 1 violation observed.
However, a few issues occurred during the extraction of data from Hennepin County’s Digital Health Department. The data collection tab on DHD only allowed “critical violations” to be pulled. “Critical violations” is terminology from the 1998 Minnesota Food Code, so when the “critical violations” records were pulled, the data did not include violations that had been corrected on site. Establishments drawn from that data also included those that were categorized as high-risk, medium-risk, and low-risk establishments. There also were violations that were included in the data pull that were only available in the 1998 Minnesota Food Code, which could not be used in this data collection since it did not fit the parameters. The final issue observed during the initial data pull was that dates within the range selected were not the only dates pulled. Dates outside of the selected range were also included in the data pull due to issues with the system.
To combat the issues that occurred with the initial data collection, new parameters were set to continue the research. Since the data could not be pulled using the DHD software, each inspection was manually evaluated. To determine the relationship between routine inspections completed prior to COVID-19 and risk-factor inspections completed during COVID-19, reports of routine inspections conducted June 2019 to August 2019 and risk-factor inspections conducted between June 2021 and August 2021 were collected. Inspection reports were required to be within the time frame for high-risk establishments, as defined by the Hennepin County Environmental Health Department, and to contain priority 1 violations.
Inspection reports in draft or as part of plan review were not included in the data collection. Follow-up inspections were noted. The following data was collected from the inspection reports and analyzed: facility name; facility ID number; size of the facility; inspection date; whether a follow-up was generated; if violations were corrected on site; city of facility; and the priority 1 violation observed. For the size of the facility, Hennepin County Environmental Health Department has two categories for high-risk establishments: small or large. “High-food small facility” includes a full menu, less than 175 seats and/or less than 500 meals or equivalent portions served, whereas a “high-food large facility” includes a full menu, greater than 175 seats and/or greater than 500 meals or equivalent portions. This classification is determined during plan review.
Results
Between June 2019 and August 2019, 354 inspections at establishments categorized as high with a facility size of large and small were completed. Out of 354 inspections, 162 inspections were observed to have one or more priority 1 violations. Of the inspection reports collected, 321 total priority 1 violations were reported by Hennepin County Environmental Health inspectors. Approximately 41% of the priority 1 violations were related to the violation category of time/temperature control for TCS foods; 27% were related to protection from contamination category; and 11% were related to preventing contamination by hands category.
A similar evaluative approach was completed for inspections performed from June 2021 to August 2021, during the COVID-19 pandemic. Inspections were focused on the risk factors and did not include good retail practices. Between June 2021 and August 2021, 318 inspections at establishments categorized as high were completed. Out of 318 inspections, 116 facilities inspected were observed to have one or more priority 1 violations. From the 318 inspection reports collected, a total of 205 priority 1 violations were observed. The violation category of time/temperature control for food safety comprised 41% of the priority 1 violations; 31% were related to protection from contamination category; and 11% were related to employee health. Graph 1 visualizes the percentage of violations by category.
Graph 1
Percentage of Violations by Violation Category
Within time/temperature control for safety foods in 2019, 61% of the violations were related to with cold holding; 13% were no discard date for prepared foods violations; and 7% were hot holding violations. Observing the same factors for 2021, within time/temperature control for safety foods, 60% of those violations were related to cold holding; 13% were no discard date for prepared foods; and 12% were hot holding violations. The highest number of violations in 2019 was related to employee illness record, cold holding, back flow prevention, when to wash: food, bare hand contact, chlorine sanitizer, raw cross contamination and ready to eat foods, quaternary ammonium sanitizer, no discard date – prepared food and hot holding. The highest number of violations in 2021 were the same as the violations for 2019. Graph 2 visualizes the violation category type in comparison to violation count percentage.
Graph 2
Percentage of Violation by Violation Description
The inspection reports collected during both time periods also were evaluated based on the size of the facility. In 2019, 243 violations were observed in a facility categorized as small, whereas 78 violations were observed in a facility categorized as large. In 2021, 148 violations were observed in a facility categorized as small, while 57 violations were observed in a facility categorized as large. In 2019, the common violation category observed at small facilities was time/temperature control for safety foods; protection from contamination; and preventing contamination by hands. In 2021, the common violation category observed at small facilities was time/temperature control for safety foods; protection from contamination; and employee health. The same violation categories in the same order are observed for both 2019 and 2021 for facilities listed as large.
Data on follow-up inspections and corrections made onsite also was collected and analyzed. A follow-up inspection is determined when here are outstanding priority 1 violations that need correction. Both onsite and off-site follow-up inspection reports were accounted for. Before the pandemic (June 2019 to August 2019), 124 follow-up inspections were completed out of the 354 high-risk routine inspections completed. During the pandemic (June 2021 to August 2021), 82 follow-up inspections were completed out of 318 risk-factor inspections completed. In comparison, 73% of the total inspections had a follow-up inspection in 2019, however, 50% of the total inspections completed in 2021 had a follow-up inspection. According to the data, in 2019, 67% of priority 1 violations observed were corrected on site. In 2021, 74% of priority 1 violations observed were corrected on site.
Conclusions
Hennepin County Environmental Health Department’s adoption of risk-factor inspections at high-risk establishments provided key results after analysis. For both routine inspections between June 2019 to August 2019 and risk-factor inspections between June 2021 to August 2021, less than half of the inspections completed had one or more priority 1 violation observed by a Hennepin County Environmental Health inspector. The percentage of inspections that observed priority 1 violations for routine inspections was 46%, in comparison to risk-factor inspections which found 36% with priority 1 violations.
The percentage of violation types observed between the two time periods for priority 1 violations were similar. For size of facility, the most common violation category observed for both small and large facilities for routine and risk-factor inspections was time/temperature control for safety food. There did not appear to be major differences in the rate of re-inspections for priority 1 violations between the time periods.
While the total number of inspections completed in 2021 was fewer than 2019, the violation count percentage for violation category and/or violation description were similar. In conclusion, inspections focusing on a risk-factor approach did not influence the number of priority 1 violations observed.
Recommendations
Focusing on a risk-factor approach for inspections did not influence the number of priority 1 violations observed, or the frequency of violations observed based on the violation category. Risk-factor approach focused on observing risk factors and public health interventions, and did not include good retail practices, whereas routine inspections focused on all violations regardless of priority type.
1. A recommendation for Hennepin County Environmental Health Department is to utilize risk-factor approach if workload exceeds employees and inspections need to be completed in a timely manner.
2. Another suggestion is to use a risk-factor approach during future pandemic times to limit exposure time in the establishment but allows inspectors to evaluate the main risk factors present.
A risk-factor approach may be utilized temporarily without compromising inspection quality.
Acknowledgments
The author wishes to acknowledge the cooperation received from Hennepin County Environmental Department staff who assisted in the data collection used in this study. In addition, the author thanks and acknowledges Kathy Fedder at IFPTI as a mentor. The author acknowledges everyone at International Food Protection Training Institute (IFPTI).
References
National Restaurant Association. (2021) State of Restaurant Industry Mid-Year Update. https://restaurant.org/research-and-media/research/research-reports/2021-state-of-the-restaurant-industry-mid-year-update/
Office of the Revisor of Statutes. (2019) Minnesota Food Code. 4626 U.S.C § 2-101.11 (2019). https://www.revisor.mn.gov/rules/4626/
U.S. Food and Drug Administration. (2017) Voluntary national retail food regulatory program standards November 2019. https://www.fda.gov/food/voluntary-national-retail-food-regulatory-program-standards/voluntary-national-retail-food-regulatory-program-standards-november-2019
Author Note
Zamzam Abdirahman, Environmentalist
Hennepin County Environmental Health Department
This research was conducted as part of the International Food Protection Training Institute’s Fellowship in Food Protection, Cohort X
Correspondence concerning this article should be addressed to:
Zamzam Abdirahman Hennepin County Environmental Health Department
1011 1st Street South Hopkins, MN
Zamzam.abdirahman@hennepin.us
Funding for the IFPTI Fellowship in Food Protection Program was made possible by the Association of Food and Drug Officials.