Don’t Overlook the Human Factor

In its September 2020 issue, School Nutrition published “Three Former Health Inspectors Walk Into a School Kitchen…” building off of a 2019 Annual National Conference (ANC) presentation by three current school nutrition operators who once worked in the public health department: Dan Ellnor, Assistant Director, School & Community Nutrition Services, Jefferson County (Ky.) Public Schools; Jessica Shelly, MBA, RHS, RS, SNS, Director of Student Dining Services; and Shonia Hall, RSP, SNS, Director, School Nutrition Services, Oklahoma City Public Schools. (A video of their presentation is available on SNA’s online Training Zone,, click on #ANC19 Videos, for viewing and CEU credit for a modest fee.) In both the presentation and their exclusive interviews with SN, the trio of sanitarians emphasized an important perspective to keep in mind: Health inspectors and foodservice staff are human.

“Every health inspector is just a little different,” notes Shelly. “I know from comparison that my health department has a different expectation than literally the department in the city next door. And even in my own city’s department, I do a big gulp when I see which city inspector is going to which school. Because even though we try to be perfect, we try to be standardized, everyone has their own idiosyncrasies. My people do—and so do the health inspectors.”

The single best thing you can do, Shelly and her colleagues advise, is to communicate. “Nothing told me more that someone was invested in their program, invested in making sure the food they were serving was as safe as possible was if someone was asking me questions. I love the to tell the ‘why,’ because I know that’s going to be more impactful,” explains Shelly.

In fact, all three former inspectors encourage managers to shadow the public health rep during the inspection and work to make corrections on the spot. “That shows initiative,” says Shelly. “Someone who is saying, ‘Thanks for pointing this out. Let me fix this. Let me retrain my employees,’ that shows me that they are doing their due diligence.” Hall echoes this impression: “It tells me, as a health inspector, that the operator takes food safety as seriously as I do. And I’m going to give them credit for that. I would mark on the inspection ‘CDI,” which means ‘corrected during inspection.’ And those are good; I’ll write CDIs all day!” Ellnor also agrees: “Because that means I, as the inspector, don’t have to do a follow-up, even if you got a critical violation—and that means less work for me.” Shelly sums it up: “And then we all win.”

In addition, to CDI, there are a few other key terms to understand in your health inspection. You are “written up” for areas where you are not in compliance with the standards of the Food Code, explains Hall. These vary, but the most important is a “Priority” or “Critical” violation, depending on your state and local regulations. These are areas that can be directly linked with an “FBI”—foodborne illness. These typically require an immediate correction, she says, citing as an example, discarding milk that has been held at 50F degrees. Most priority/critical violations in schools are from equipment or facility infrastructure failures, not human error, says Ellnor. There are also “Priority Foundation Violations,” which Hall describes as “actions, procedures or equipment that control risks factors to a FBI. An example of this would be discovering that you have a cooler down. If you don’t have another cooler to move product to, then you could be ‘closed’ until that cooler has been repaired.”

States and local municipalities have variations on how the inspection for compliance is written and reported to the public. In Kentucky, says Ellnor, “We get grades: A, B, C, etc. And at the local level, just one critical violation means nothing higher than a C. But you have three days to correct that critical violation—which then can bump you to a B.”

Ellnor also wants to emphasize the importance of recognizing that food safety practices are conducted by humans—and human behavior has to be taken into account throughout the process. “We can train and retrain and get so frustrated when an employee still makes the same errors over and over,” he notes. “What can you do? You can write them up. You can yell at them. You can move them to a different area of the kitchen. But eventually, you’re probably going to have to dismiss them. And you invested all this time and energy and now you have to start all over again.” Instead, Ellnor advises mangers and supervisors to look at how to change a process to fit the human. Maybe it’s as simple as making a fresh box of gloves more easily accessible for the employee who keeps failing to change them between tasks.

The code has a lot of “gray areas,” he concedes, so taking a black-and-white approach can cause problems. “Look at the intent of different areas of the code and keep that in mind as you design your processes. It all flows from a risk-management assessment. What are the most risky things that typically cause foodborne illness? Those get the higher priority. A cracked floor will cost you just one point, but using a wooden butcher block table will be a priority/critical violation, because it carries the greater risk.”

With COVID, there are a lot of new processes and changed behaviors now required. Be sure to be consistent in how you enforce compliance, advises Ellnor. You can’t cite Johnny for something that you’re letting Sue slide on. That’s more important now than ever.”

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