Solving the Survey Puzzlefor F371

Solving the Survey Puzzlefor F371

Sara Gosnell, RD, CDSara Gosnell, RD, CD

ObjectivesObjectives

Describe the relationship between the regulation and the interpretive guidance

Describe how to use the investigative protocol

Describe and apply components of the investigative protocol

Identify areas of noncompliance with the sanitary conditions regulation

Appropriately categorize the scope and severity of noncompliance

Describe the relationship between the regulation and the interpretive guidance

Describe how to use the investigative protocol

Describe and apply components of the investigative protocol

Identify areas of noncompliance with the sanitary conditions regulation

Appropriately categorize the scope and severity of noncompliance

F371 RevisionsF371 Revisions

F370 merged into F371Regulatory language was kept the

sameRevisions now provide:

13 new definitionsEducationExplanationsExamples for surveyors to reference

F370 merged into F371Regulatory language was kept the

sameRevisions now provide:

13 new definitionsEducationExplanationsExamples for surveyors to reference

Defined by Federal Regulation

Defined by Federal Regulation

The facility must 483.35(i) (1) Procure food from

sources approved or considered satisfactory by Federal, Stated, or local authorities

483.35(i) (2) Store, prepare, distribute and serve food under sanitary conditions

The facility must 483.35(i) (1) Procure food from

sources approved or considered satisfactory by Federal, Stated, or local authorities

483.35(i) (2) Store, prepare, distribute and serve food under sanitary conditions

IntentIntent

Facility obtains food for resident consumption from sources approved or considered satisfactory by federal, state, or local authorities

Follows proper sanitation and food handling practices to prevent the outbreak of foodborne illness; beginning with the vendor through the facility’s food handling processes.

Facility obtains food for resident consumption from sources approved or considered satisfactory by federal, state, or local authorities

Follows proper sanitation and food handling practices to prevent the outbreak of foodborne illness; beginning with the vendor through the facility’s food handling processes.

DefinitionsDefinitions

Cross contamination

Danger zone Dry storage Food

contamination Food preparation Food

service/distribution Foodborne illness

Cross contamination

Danger zone Dry storage Food

contamination Food preparation Food

service/distribution Foodborne illness

Highly susceptible population

Pathogen PHF Ready-to-eat food Storage Toxins

Highly susceptible population

Pathogen PHF Ready-to-eat food Storage Toxins

Cross ContaminationCross Contamination

The transfer of harmful substances or disease-causing microorganisms to food by hands, food contact surfaces, sponges, cloth towels, or utensils that are not cleaned after touching raw food, and then touch ready-to-eat foods. This may also occur if raw food touches or drips onto cooked or ready-to-eat food.

The transfer of harmful substances or disease-causing microorganisms to food by hands, food contact surfaces, sponges, cloth towels, or utensils that are not cleaned after touching raw food, and then touch ready-to-eat foods. This may also occur if raw food touches or drips onto cooked or ready-to-eat food.

Danger ZoneDanger Zone

Used for PHF Temps between 41°-135° F* that allow

rapid growth of pathogenic microorganisms that can cause foodborne illness

>4 hours during preparation >6 hours for items cooked and cooled

*the temps are based on the food code which are the most stringent

Used for PHF Temps between 41°-135° F* that allow

rapid growth of pathogenic microorganisms that can cause foodborne illness

>4 hours during preparation >6 hours for items cooked and cooled

*the temps are based on the food code which are the most stringent

Dry StorageDry Storage

Storing and maintaining dry foods (e.g., canned goods, flour, sugar) and supplies (disposable dishware, napkins, and kitchen cleaning supplies) Examples: ensuring paper goods are open

from the right end and plastic bags of silverware are sealed and not left open

Storing and maintaining dry foods (e.g., canned goods, flour, sugar) and supplies (disposable dishware, napkins, and kitchen cleaning supplies) Examples: ensuring paper goods are open

from the right end and plastic bags of silverware are sealed and not left open

StorageStorage

The retention of food (before and after prep) and associated dry goods Example: NOT keeping scoops in flour or

sugar bins even if the handle is up

The retention of food (before and after prep) and associated dry goods Example: NOT keeping scoops in flour or

sugar bins even if the handle is up

Food ContaminationFood Contamination

The unintended presence of potentially harmful substances, including but not limited to microorganisms, chemicals or physical objects in food. Example: fake fingernail in food

The unintended presence of potentially harmful substances, including but not limited to microorganisms, chemicals or physical objects in food. Example: fake fingernail in food

Food PreparationFood Preparation

The series for operational processes involved in getting foods ready for serving, such as: washing, thawing, mixing ingredients, cutting, slicing, diluting, concentrates, cooking, pureeing, cooling and reheating. Example: not washing fruit; rinsing a knife,

not washing it and using it again

The series for operational processes involved in getting foods ready for serving, such as: washing, thawing, mixing ingredients, cutting, slicing, diluting, concentrates, cooking, pureeing, cooling and reheating. Example: not washing fruit; rinsing a knife,

not washing it and using it again

Foodborne IllnessFoodborne Illness

Illness caused by the ingestion of contaminated food or beverages

►Foodborne outbreak2 or more unrelated people that ate a

similar meal

Illness caused by the ingestion of contaminated food or beverages

►Foodborne outbreak2 or more unrelated people that ate a

similar meal

Food Service/DistributionFood Service/Distribution

The processes of getting food to the residentHolding foods hot on the steam table

or under refrigeration for cold temp control

Dispensing food portions for individual residents

Family style and dining room serviceDelivering trays to residents’ rooms

or units

The processes of getting food to the residentHolding foods hot on the steam table

or under refrigeration for cold temp control

Dispensing food portions for individual residents

Family style and dining room serviceDelivering trays to residents’ rooms

or units

Highly Susceptible Population

Highly Susceptible Population

Persons who are more likely than the general population to experience foodborne illness because of their susceptibility to becoming ill if they ingest microorganisms or toxins (e.g., immunocompromised, chronic disease and advanced age)

Persons who are more likely than the general population to experience foodborne illness because of their susceptibility to becoming ill if they ingest microorganisms or toxins (e.g., immunocompromised, chronic disease and advanced age)

PathogenPathogen

An organism capable of causing a disease (e.g., pathogenic bacteria or viruses)Norovirus

An organism capable of causing a disease (e.g., pathogenic bacteria or viruses)Norovirus

Potentially Hazardous Food (PHF or TCS)

Potentially Hazardous Food (PHF or TCS)

Food that requires time-temp control for safety to limit the growth of pathogens or toxin formation

TCS- time/temp control for safety٭

Food that requires time-temp control for safety to limit the growth of pathogens or toxinformation

TCS- time/temp control for safety٭

Ready-to-Eat FoodReady-to-Eat Food

Food that is edible with little or no prep to achieve food safetyIncludes foods requiring minimal

preparation for palatability or culinary purposes, such as mixing with other ingredients (e.g., tuna, chicken or egg salad)

Examples include deli items and raw fruits and vegetables

Food that is edible with little or no prep to achieve food safetyIncludes foods requiring minimal

preparation for palatability or culinary purposes, such as mixing with other ingredients (e.g., tuna, chicken or egg salad)

Examples include deli items and raw fruits and vegetables

ToxinsToxins

Poisonous substances that are produced by living cells or organisms (e.g., pathogenic bacteria) that cause foodborne illness when ingested

Poisonous substances that are produced by living cells or organisms (e.g., pathogenic bacteria) that cause foodborne illness when ingested

OverviewOverview

The risk for foodborne illness (FBI) Importance of effective food safety

systems Identify hazards and critical

control points (CCPs)Operational steps to eliminate

hazards

The risk for foodborne illness (FBI) Importance of effective food safety

systems Identify hazards and critical

control points (CCPs)Operational steps to eliminate

hazards

Types of Food ContaminationTypes of Food Contamination

Biological

Chemical

Physical

Biological

Chemical

Physical

Biological Contamination Biological Contamination

Biological ContaminationBiological Contamination

Most common types of disease producing organisms

BacteriaVirusesToxinsSporesParasites

Most common types of disease producing organisms

BacteriaVirusesToxinsSporesParasites

Factors Influencing Bacterial Growth

Factors Influencing Bacterial Growth

Food

Acidity

Time

Temp

Oxygen

Moisture

Food

Acidity

Time

Temp

Oxygen

Moisture

Chemical ContaminationChemical Contamination

Monitor to ensure spray cleaners are not within proximity to food prep area to prevent food from being sprayed

Ensure bottles are properly labeled Soap should not be stored in an unlabeled

styrofoam container Powder cleaners could be mistaken for a cooking

product

Monitor to ensure spray cleaners are not within proximity to food prep area to prevent food from being sprayed

Ensure bottles are properly labeled Soap should not be stored in an unlabeled

styrofoam container Powder cleaners could be mistaken for a cooking

product

Physical ContaminationPhysical Contamination

Foreign objects in foodHairFingernailsMetal shavingsJewelry

Do NOT use:a glass as an ice scooperA steel scouring pad to clean

Foreign objects in foodHairFingernailsMetal shavingsJewelry

Do NOT use:a glass as an ice scooperA steel scouring pad to clean

Other Factors Involved in Foodborne Illness

Other Factors Involved in Foodborne Illness

Poor personal hygiene Inadequate cooking and improper

holdingContaminated equipmentUnsafe food sources

Poor personal hygiene Inadequate cooking and improper

holdingContaminated equipmentUnsafe food sources

Prevention of Foodborne Illness

Prevention of Foodborne Illness

Food handling and preparation

Employee health

Hand washing, gloves, antimicrobial gel

Food handling and preparation

Employee health

Hand washing, gloves, antimicrobial gel

Employee IllnessEmployee Illness

An employee will be restricted from working with food if they are experiencing symptoms of:

Fever Cough/sore throat Diarrhea Open wound, not

bandaged/covered

An employee will be restricted from working with food if they are experiencing symptoms of:

Fever Cough/sore throat Diarrhea Open wound, not

bandaged/covered

Safe Food StorageSafe Food Storage

FIFO!!Dry food storage should be

maintained in a clean and dry areaSafe refrigerator practices

Monitoring tempsProper handling/cooling of hot foodsSeparation of raw, cooked and ready-to-

eat foods

FIFO!!Dry food storage should be

maintained in a clean and dry areaSafe refrigerator practices

Monitoring tempsProper handling/cooling of hot foodsSeparation of raw, cooked and ready-to-

eat foods

Safe Food PreparationSafe Food Preparation

Cross contaminationThawingFinal cook tempsModified consistencyCoolingReheating food

NO pooled eggs unless pasteurized

Cross contaminationThawingFinal cook tempsModified consistencyCoolingReheating food

NO pooled eggs unless pasteurized

Thawing Foods ProperlyThawing Foods Properly

1. Under cold water, < 70°F, agitating enough to get off ice

2. In the cooler3. Microwaving; food needs cooked

immediately following4. Cook from frozen state

1. Under cold water, < 70°F, agitating enough to get off ice

2. In the cooler3. Microwaving; food needs cooked

immediately following4. Cook from frozen state

Final Cook TemperaturesFinal Cook Temperatures

PoultryStuffed Foods

165° F

Ground Meat 155° F

FishEggs (unpasteurized)

Pork

145° F

Proper Cooling TechniquesProper Cooling Techniques

TechniquesShallow pans for smaller quantitiesIce bathFrequent stirringCooling paddles

135° F ► 70° F ► within 2 hours 70 ° F ► 41° F ► within 4 hoursTotal time not to exceed 6 hours٭

TechniquesShallow pans for smaller quantitiesIce bathFrequent stirringCooling paddles

135 F °70 ►F ° within 2 hours ► 70F ° 41 ► F °within 4 hours ►Total time not to exceed 6 hours٭

Proper Reheating Procedures

Proper Reheating Procedures

Required internal temp = 165°F for 15 seconds minimum Only for foods properly cooled Can only reheat a food item once!

Facility-made pureed foodcannot be ٭reheated

Required internal temp = 165°F for 15seconds minimum Only for foods properly cooled !Can only reheat a food item once

Facility-made pureed food cannot be٭reheated

Equipment and Utensil Cleaning and Sanitization

Equipment and Utensil Cleaning and Sanitization

Machine wash and sanitizeManual wash and sanitizeCleaning fixed equipment

√ Test strips should be at each station and used!!

Machine wash and sanitizeManual wash and sanitizeCleaning fixed equipment

√ Test strips should be at each station and used!!

Food Service and Distribution

Food Service and Distribution

Tray line, alternative meal preparation and service are

Food distributionSnacksSpecial eventsTransported foods IceRefrigeration

Tray line, alternative meal preparation and service are

Food distributionSnacksSpecial eventsTransported foods IceRefrigeration

Wiping ClothsWiping Cloths

Service area wiping cloths are cleaned and dried, or

Place in a chemical sanitizing solution of appropriate concentration

√ test strips need used periodically as sanitizer strength decreases over time

Service area wiping cloths are cleaned and dried, or

Place in a chemical sanitizing solution of appropriate concentration

√ test strips need used periodically as sanitizer strength decreases over time

Surveying Facilities That Receive Food Prepared by Off-

site Kitchens

Surveying Facilities That Receive Food Prepared by Off-

site Kitchens

When a nursing home receives food services from an off-site location, the surveyor must assess whether the facility is compliant with 42 CFR 483.35 (i)

Your facility should have on hand a copy of the ٭-most recent sanitation inspection from the offsite location

When a nursing home receives food ,services from an off-site location the surveyor must assess whether the facility is compliant with 42 CFR(i) 483.35

Your facility should have on hand a copy of the٭most recent sanitation inspection from the off-site location

Culture Change ProvisionsCulture Change Provisions

Family members, or other resident guests, who bring in food for the resident’s consumption are not regulated under this federal tag.

● many state regs address this

Dietary is responsible for foods cooked by recreation department, and should be trained accordingly

A cake from the bakery is ok, but bake sales to the residents should not be done

Families/guests can bring food in for the individual but it should not be set out for others

Family members, or other resident guests, who bring in food for the resident’s consumption are not regulated under this federal tag.

● many state regs address this

Dietary is responsible for foods cooked by recreation department, and should be trained accordingly

A cake from the bakery is ok, but bake sales to the residents should not be done

Families/guests can bring food in for the individual but it should not be set out for others

Pathogenic Microorganisms and Strategies for Their

Control

Pathogenic Microorganisms and Strategies for Their

ControlCommonly identified ingestible

items associated with illness-producing organisms

Primary agents of concern (hazards) are organisms associated with the food source

PHF/TCS primary control strategies to minimize potential for foodborne illness outbreak

Commonly identified ingestible items associated with illness-producing organisms

Primary agents of concern (hazards) are organisms associated with the food source

PHF/TCS primary control strategies to minimize potential for foodborne illness outbreak

Investigative Protocol Sanitary Conditions

Investigative Protocol Sanitary Conditions

Use this protocol to investigate compliance

at F371 (483.35 (i) (1) and (2))

Use this protocol to investigate compliance

at F371 (483.35 (i) (1) and (2))

ObjectivesObjectives

1. To determine if the facility procured food from approved sources

2. To determine if the facility stores, prepares, distributes and serves food in a sanitary manner to prevent FBI

3. To determine if the facility has systems (e.g., policies, procedures, training, and monitoring) in place to prevent the spread of FBI and compromising of food safety

4. To determine if the facility utilizes safe food handling from the time the food is received from the vendor and throughout the food handling processes in the facility

1. To determine if the facility procured food from approved sources

2. To determine if the facility stores, prepares, distributes and serves food in a sanitary manner to prevent FBI

3. To determine if the facility has systems (e.g., policies, procedures, training, and monitoring) in place to prevent the spread of FBI and compromising of food safety

4. To determine if the facility utilizes safe food handling from the time the food is received from the vendor and throughout the food handling processes in the facility

Investigative Protocol Procedure During Survey

Investigative Protocol Procedure During Survey

Observations InterviewsRecord reviewsReview of facility practices

Observations InterviewsRecord reviewsReview of facility practices

ObservationObservation

Surveyors will observe food procurement Service of food during meals Service after meal Storage of food

Surveyors will observe food procurement Service of food during meals Service after meal Storage of food

Observation of Food Procurement Procedures

Observation of Food Procurement Procedures

Observe when, where and how food is procuredInvoices (to verify sources)Vendor recordsSource verificationTemps upon arrivalVisually observe items

Are boxes wet?

Observe when, where and how food is procuredInvoices (to verify sources)Vendor recordsSource verificationTemps upon arrivalVisually observe items

Are boxes wet?

Observation of Food Preparation Procedures

Observation of Food Preparation Procedures

Food handling practices Food labeling and dates Hand washing Handling of potential cross

contamination foods Acceptable cooking and cooling temps

Food handling practices Food labeling and dates Hand washing Handling of potential cross

contamination foods Acceptable cooking and cooling temps

Observation of Trayline Service

Observation of Trayline Service

Observe staff measuring the temp of all hot and cold menu items at all points of service Cold food should be ≤ 41° F Hot foods should be ≥ 135° F

ensure staff are taking temps from the middle ٭of the food item

Observe staff measuring the temp of all hot and cold menu items atall points of service Cold food should beF 41° ≥ Hot foods should be ≥ 135° F

ensure staff are taking temps from the middle ٭of the food item

Observation of Dish Room Procedures

Observation of Dish Room Procedures

Observe whether staff are properly operating dish machine and evaluate sanitization processes

Check for proper equipment and supplies to evaluate dish machine operation

Observe the 3 step process of manual pot and pan washing What sanitizer do you use with what test

strip?

Observe whether staff are properly operating dish machine and evaluate sanitization processes

Check for proper equipment and supplies to evaluate dish machine operation

Observe the 3 step process of manual pot and pan washing What sanitizer do you use with what test

strip?

Observation of Service After Meals

Observation of Service After Meals

Observe store dishes, utensils, pots/pans, and equipment for evidence of soiling Can the lowerator be splashed by dirty

water?

Evaluate whether proper hand washing is occurring between handling soiled and clean dishes to prevent cross contamination of the clean dishes

Observe store dishes, utensils, pots/pans, and equipment for evidence of soiling Can the lowerator be splashed by dirty

water?

Evaluate whether proper hand washing is occurring between handling soiled and clean dishes to prevent cross contamination of the clean dishes

Observation of Food Storage

Observation of Food Storage

Look for evidence of pests, rodents and droppings and other sources of contamination

Observe whether foods are labeled and dated Observe whether foods are stored off of the

floor Check for canned goods that have a

compromised seal Observe whether staff access bulk foods

without touching the food

Look for evidence of pests, rodents and droppings and other sources of contamination

Observe whether foods are labeled and dated Observe whether foods are stored off of the

floor Check for canned goods that have a

compromised seal Observe whether staff access bulk foods

without touching the food

Interview ProtocolInterview Protocol

Surveyor will interview multiple staff regarding the policies and procedures for procurement, preparation and service of food to the residents Staff need to be able to answer these

questions, as well as, possibly perform the task if asked correctly

Surveyor will interview multiple staff regarding the policies and procedures for procurement, preparation and service of food to the residents Staff need to be able to answer these

questions, as well as, possibly perform the task if asked correctly

Record Reviewal ProtocolRecord Reviewal Protocol

Resident records Dietary/kitchen policies and

procedures Maintenance records, such as

work orders and manufacturer's specifications, related to equipment used to store, prepare and serve food

Facility infection control records

Resident records Dietary/kitchen policies and

procedures Maintenance records, such as

work orders and manufacturer's specifications, related to equipment used to store, prepare and serve food

Facility infection control records

Determination of Compliance for F 371

Determination of Compliance for F 371

Did the facility:1. Procure food from approved sources?2. Properly store, prepare, distribute and serve

foods for residents’ consumption?

Important to review food temps in resident council, or ٭٭٭ food committee, monthly to ensure temps are palatable atpoint of service to the residents. After point of

service, it becomes a palatability issue, rather than a.temp issue

:Did the facility.1 ?Procure food from approved sources.2 Properly store, prepare, distribute and serve

?foods for residents’ consumption

Important to review food temps in resident council, or٭٭٭food committee, monthly to ensure temps are palatable at point of service to the residents. After point of service, it becomes a palatability issue, rather than a temp issue.

Criteria for Compliance with F371

Criteria for Compliance with F371

Procures, stores, handles, prepares, distributes and serves food to minimize the risk of FBI

Maintains PHF/TCS foods at safe temps, cools food rapidly, and prevents contamination during storage

Cook food to the appropriate temp and hold PHF/TCS foods cold or hot

Utilizes proper hand washing and personal hygiene practices to prevent food contamination

Maintains equipment and food contact surfaces to prevent food contamination

Procures, stores, handles, prepares, distributes and serves food to minimize the risk of FBI

Maintains PHF/TCS foods at safe temps, cools food rapidly, and prevents contamination during storage

Cook food to the appropriate temp and hold PHF/TCS foods cold or hot

Utilizes proper hand washing and personal hygiene practices to prevent food contamination

Maintains equipment and food contact surfaces to prevent food contamination

Noncompliance with F371Noncompliance with F371

May include, but is not limited to, one of more of the following, failure to: Procure, store, handle, prepare distribute and

serve food in accordance with the standards summarized in the guidance

Maintain PHF/TCS foods at safe temps, at or below 41°F (for cold foods) or at or below 135°F (for hot foods.

Exception: during prep, cooking or cooling Ensure that PHF/TCS food plated for transport was

not out of temp control for more that 4 hours Store raw foods properly to reduce the risk of

contamination of cooked or ready-to-eat foods Ensure that foods are cooked to the appropriate

temp and cooled properly to prevent FBI

May include, but is not limited to, one of more of the following, failure to: Procure, store, handle, prepare distribute and

serve food in accordance with the standards summarized in the guidance

Maintain PHF/TCS foods at safe temps, at or below 41°F (for cold foods) or at or below 135°F (for hot foods.

Exception: during prep, cooking or cooling Ensure that PHF/TCS food plated for transport was

not out of temp control for more that 4 hours Store raw foods properly to reduce the risk of

contamination of cooked or ready-to-eat foods Ensure that foods are cooked to the appropriate

temp and cooled properly to prevent FBI

Severity DeterminationSeverity Determination

Harm/negative outcome(s) or potential for negative outcomes due to a failure of care and service

Degree of harm (actual or potential) related to noncompliance, and

Immediacy of correction required

Harm/negative outcome(s) or potential for negative outcomes due to a failure of care and service

Degree of harm (actual or potential) related to noncompliance, and

Immediacy of correction required

Determining Actual or Potential Harm

Determining Actual or Potential Harm

Actual or potential harm/negative outcomes for F371 include:Foodborne illnessIngestion or potential ingestion of

food that was not procured from approved sources, prepared, distributed or served under sanitary conditions

Actual or potential harm/negative outcomes for F371 include:Foodborne illnessIngestion or potential ingestion of

food that was not procured from approved sources, prepared, distributed or served under sanitary conditions

Determining Degree of Harm

Determining Degree of Harm

How the facility practices caused, resulted in , allowed, or contributed to harm (actual/potential)If harm has occurred, determine if the

harm is at the level of serious injury, impairment, death, compromise, or discomfort, and

If harm has not yet occurred, determine how likely the potential is for serious injury, impairment, death, compromise or discomfort to occur to the resident.

How the facility practices caused, resulted in , allowed, or contributed to harm (actual/potential)If harm has occurred, determine if the

harm is at the level of serious injury, impairment, death, compromise, or discomfort, and

If harm has not yet occurred, determine how likely the potential is for serious injury, impairment, death, compromise or discomfort to occur to the resident.

Severity Level 4 Deficiency Categorization

Severity Level 4 Deficiency Categorization

Immediate JeopardyTo Resident’s Health or Safety

Immediate JeopardyTo Resident’s Health or Safety

Level 4 Immediate Jeopardy

Level 4 Immediate Jeopardy

Has allowed/caused/resulted in, or is likely to cause serious injury, harm, impairment, or death to a resident; and

Requires immediate correction, as the facility either created the situation or allowed the situation to continue by failing to implement preventative or corrective measures.

Has allowed/caused/resulted in, or is likely to cause serious injury, harm, impairment, or death to a resident; and

Requires immediate correction, as the facility either created the situation or allowed the situation to continue by failing to implement preventative or corrective measures.

Level 4 DeficiencyLevel 4 Deficiency

Example #1 A roast thawing on a plate in the

refrigerator had bloody juices overflowing and dripping onto uncovered salad greens on the shelf below

The contaminated salad greens were not discarded and were used to make salad for the noon meal

Example #1 A roast thawing on a plate in the

refrigerator had bloody juices overflowing and dripping onto uncovered salad greens on the shelf below

The contaminated salad greens were not discarded and were used to make salad for the noon meal

Level 4 DeficiencyLevel 4 Deficiency

Example #2 The facility had a recent outbreak of

norovirus as a result of a food worker experiencing episodes of vomiting and diarrhea, and the facility allowed the staff to continue preparing food.

Observations and interviews indicate that there are other food service staff experiencing gastrointestinal illnesses who are still permitted to prepare food.

Example #2 The facility had a recent outbreak of

norovirus as a result of a food worker experiencing episodes of vomiting and diarrhea, and the facility allowed the staff to continue preparing food.

Observations and interviews indicate that there are other food service staff experiencing gastrointestinal illnesses who are still permitted to prepare food.

Severity Level 3 Deficiency Categorization

Severity Level 3 Deficiency Categorization

Actual Harm that is not immediate jeopardy

The negative outcome may include but may not be limited to clinical compromise, decline, or the resident’s inability to maintain and/or reach his/her highest practicable level of well-being.

Actual Harm that is not immediate jeopardy

The negative outcome may include but may not be limited to clinical compromise, decline, or the resident’s inability to maintain and/or reach his/her highest practicable level of well-being.

Level 3 DeficiencyLevel 3 Deficiency

Example #1 An outbreak of nausea and vomiting occurs

in the facility related to the inadequate sanitizing of dishes and utensils

Example #2 A milk episode of food poisoning occurred

because the facility had a special even tin which tuna, chicken, and potato salads served in bulk were not kept adequately chilled and were left out for eating after 5 hours

Example #1 An outbreak of nausea and vomiting occurs

in the facility related to the inadequate sanitizing of dishes and utensils

Example #2 A milk episode of food poisoning occurred

because the facility had a special even tin which tuna, chicken, and potato salads served in bulk were not kept adequately chilled and were left out for eating after 5 hours

Severity Level 2 Deficiency Categorization

Severity Level 2 Deficiency Categorization

No actual harm with potential for more than minimal harm that is not immediate jeopardy

No actual harm with potential for more than minimal harm that is not immediate jeopardy

Level 2 Deficiency Categorization

Level 2 Deficiency Categorization

Noncompliance tat results in a resident outcome of o more than minimal discomfort, and/or

Has the potential to compromise the resident’s ability to maintain or reach his or he highest practicable of well-being

Noncompliance tat results in a resident outcome of o more than minimal discomfort, and/or

Has the potential to compromise the resident’s ability to maintain or reach his or he highest practicable of well-being

Level 2 Deficiency Level 2 Deficiency

Example #1: food service workers sliced roast pork on

the meat slicer The meat slicer was not washed, rinsed and

sanitized after usage During the dietary service system

assessment, two days later, the surveyor observed the meat slicer soiled with dried meat underneath the blade

The facility failed to educate and train staff on how to clean and sanitize all kitchen equipment

Example #1: food service workers sliced roast pork on

the meat slicer The meat slicer was not washed, rinsed and

sanitized after usage During the dietary service system

assessment, two days later, the surveyor observed the meat slicer soiled with dried meat underneath the blade

The facility failed to educate and train staff on how to clean and sanitize all kitchen equipment

Level 2 DeficiencyLevel 2 Deficiency

Example #2:During the tour of the kitchen, two

food service workers were observed on the loading dock

One was smoking and the other employee was emptying trash

Upon returning to the kitchen, they proceeded to prepare food without washing their hands

Example #2:During the tour of the kitchen, two

food service workers were observed on the loading dock

One was smoking and the other employee was emptying trash

Upon returning to the kitchen, they proceeded to prepare food without washing their hands

Severity Level 1 Deficiency Categorization

Severity Level 1 Deficiency Categorization

No actual harm with potential for minimal harmNo actual harm with potential for minimal harm

Level 1 Deficiency Categorization

Level 1 Deficiency Categorization

The failure of the facility to procure, prepare, store, distribute and handle food under sanitary conditions places this highly susceptible population at risk for more than minimal harm.

Therefore, Severity Level 1 does not apply for this regulatory requirement.

The failure of the facility to procure, prepare, store, distribute and handle food under sanitary conditions places this highly susceptible population at risk for more than minimal harm.

Therefore, Severity Level 1 does not apply for this regulatory requirement.

Additional InvestigationAdditional Investigation

Potential tags from additional investigation F322- Nasogastric Tubes F325- Nutrition F353- Sufficient Staffing F361- Dietary Services- Staffing F362- Standard Sufficient Staffing 42 CFR 483.35 (h) Paid Feeding Assistant F441- Infection Control F444- Handwashing Techniques F456- Maintain All Essential Equipment F465- Other Environmental Conditions F469- Effective Pest control Program F540- Quality Assessment and Assurance

Potential tags from additional investigation F322- Nasogastric Tubes F325- Nutrition F353- Sufficient Staffing F361- Dietary Services- Staffing F362- Standard Sufficient Staffing 42 CFR 483.35 (h) Paid Feeding Assistant F441- Infection Control F444- Handwashing Techniques F456- Maintain All Essential Equipment F465- Other Environmental Conditions F469- Effective Pest control Program F540- Quality Assessment and Assurance

F371 and the Food Code Application

F371 and the Food Code Application

Know what the Federal Regs and your state have adopted in regards to a Food Code

Compare with F371, which uses the 2005 FDA Food Code

Know what the Federal Regs and your state have adopted in regards to a Food Code

Compare with F371, which uses the 2005 FDA Food Code

Implications for the Foodservice Supervisor

Implications for the Foodservice Supervisor

Must be more observant of staff practices and accountable for safe food handling

Be able to use the new surveyor “Investigative Protocol” to self-survey the kitchen

Enlist the Consultant, or in-house, RD To help review the policies and procedures

concerning current industry standards for safe food handling

Develop and implement thorough orientation and ongoing inservices in food handling

Must be more observant of staff practices and accountable for safe food handling

Be able to use the new surveyor “Investigative Protocol” to self-survey the kitchen

Enlist the Consultant, or in-house, RD To help review the policies and procedures

concerning current industry standards for safe food handling

Develop and implement thorough orientation and ongoing inservices in food handling

Implications for the RDImplications for the RD

If you haven’t already, now is the time to Begin developing inservicesBecome certified in food safety

Determine if you will need more time in your facilities to ensure regulation compliance is maintained

If you haven’t already, now is the time to Begin developing inservicesBecome certified in food safety

Determine if you will need more time in your facilities to ensure regulation compliance is maintained

Implication for AdministrationImplication for Administration

As surveyors are trained on the revision of F371, the new Investigative Protocol for Sanitary Conditions, and the new Scope/Severity determinations NO Administrator will want a deficiency in “unsafe food handling”, especially NOT and Immediate Jeopardy

As surveyors are trained on the revision of F371, the new Investigative Protocol for Sanitary Conditions, and the new Scope/Severity determinations NO Administrator will want a deficiency in “unsafe food handling”, especially NOT and Immediate Jeopardy

Post TestPost Test

1. Glove use is not important when handling ready-to-eat foods

True False

2. Which of the following is not part of the revisions for F371

a. Definitions b. Educationc. Scope of practiced. Explanationse. Examples

1. Glove use is not important when handling ready-to-eat foods

True False

2. Which of the following is not part of the revisions for F371

a. Definitions b. Educationc. Scope of practiced. Explanationse. Examples

Post Test ContinuedPost Test Continued

3. During the Investigative Protocol, the surveyors are to have no contact with the staff, only with paper records.

True False

4. The Food Danger Zone is 40°F -140°F.

True False

3. During the Investigative Protocol, the surveyors are to have no contact with the staff, only with paper records.

True False

4. The Food Danger Zone is 40°F -140°F.

True False

Post Test ContinuedPost Test Continued

5. A surveyor observed an employee load dirty dishes in the dish machine, then walk to the clean end to unload them without washing his hands. What level of severity would the facility be tagged with?a. Level 1

b. Level 2c. Level 3d. Level 4

5. A surveyor observed an employee load dirty dishes in the dish machine, then walk to the clean end to unload them without washing his hands. What level of severity would the facility be tagged with?a. Level 1

b. Level 2c. Level 3d. Level 4

Post Test ContinuedPost Test Continued

6. It is important to have an RD involved in developing and implementing policies and procedures

True False

7. What is the time frame allowed to correct a Level 4 Severity, or Immediate Jeopardy?

a. Immediatelyb. 1 monthc. 3 monthsd. 6 months

6. It is important to have an RD involved in developing and implementing policies and procedures

True False

7. What is the time frame allowed to correct a Level 4 Severity, or Immediate Jeopardy?

a. Immediatelyb. 1 monthc. 3 monthsd. 6 months

Post Test ContinuedPost Test Continued

8. Which is not a potential for citation?a. A cloth being kept in sanitizer solutionb. A roast in the cooler labeled and dated

from the prior dayc. Temp of hot foods at point of service

being 135°Fd. A staff member delivering a tray with no

glovese. All of the above

8. Which is not a potential for citation?a. A cloth being kept in sanitizer solutionb. A roast in the cooler labeled and dated

from the prior dayc. Temp of hot foods at point of service

being 135°Fd. A staff member delivering a tray with no

glovese. All of the above

Post Test ContinuedPost Test Continued

9. If you receive food from an off-site facility, you do not need to be concerned with sanitation checks

True False

10. Which of the following is not part of the Investigative Protocol?

a. Observationsb. Interviewsc. Educationd. Record Reviewse. Review of Facility Practices

9. If you receive food from an off-site facility, you do not need to be concerned with sanitation checks

True False

10. Which of the following is not part of the Investigative Protocol?

a. Observationsb. Interviewsc. Educationd. Record Reviewse. Review of Facility Practices

AnswersAnswers

1. False2. C3. False4. False5. B6. True7. A8. E9. False10. C

1. False2. C3. False4. False5. B6. True7. A8. E9. False10. C