Food Safety and Sanitation
in Correctional Food Service
Debbie Graham
We’ve all heard on the news of “hundreds sickened from food,” “food recalled due to contamination,” and “ongoing investigations of illnesses from an unknown food source.” Most likely you know someone who has been sickened by food, or perhaps you’ve had a personal experience—one which you are not likely to forget.
The CDC estimates each year “roughly 1 in 6 Americans gets sick, 128,000 are hospitalized, and 3,000 die of foodborne diseases” (CDC, 2018). According to the CDC’s National Outbreak Reporting System (NORS), from 2017 to 2020 in prisons and jails alone, there were 46 outbreaks of foodborne disease resulting in 2,544 illnesses, 147 hospitalizations, and 5 deaths. The highest number of outbreaks (14) occurred in 2019; however, the highest number of illnesses (971) and hospitalizations (138) occurred in 2018 as a result of 13 outbreaks. All five deaths occurred in the year 2018 (CDC, 2022).
What is a foodborne illness outbreak? A foodborne illness outbreak is “an incident in which two or more persons experience a similar illness resulting from the ingestion of a common food” (CDC, 2015).
In most cases, illness from food is related to issues concerning food safety. Serving safe food should be the primary goal of any food service operation for wellness reasons and to avoid legal and liability issues—regardless of how many meals per day are produced and served.
In this article, I review food safety practices and sanitation measures to assist facilities food service operations in meeting the goal of producing and serving food that is safe for consumption.
Food Safety and Causes of Unsafe Food
The USDA defines food safety as “the condition and practices that preserve the quality of food to prevent contamination and food-borne illnesses” (USDA, 2019). In the U.S., food safety is usually regulated by a local
health department, who provides periodic inspections of food establishments for adherence to food safety standards. Most local health departments follow the standards and guidelines of the Food and Drug Administration’s (FDA) Food Code.
Food safety requires proper handling “from the farm to the table” (known as the “flow of food”). This flow encompasses production, processing, distribution, preparation, and serving. Hazards to food safety can be biological (microorganisms or toxins), chemical (including cleaners, sanitizers, lubricants), or physical (including metal, broken glass, hair, etc.).
Practices that can render food unsafe include, but are not limited to:
• poor personal hygiene
• improper storage practices
• inadequate cooking of food
• improper cooling of food
• improper reheating of food
• holding and storing food at improper temperatures
• cross-contamination and contaminated equipment
• purchasing food from unsafe sources
• inadequate sanitation practices
Hazards to food safety and practices that render food unsafe can occur anywhere along the flow of food and can be caused by employees, deliveries, equipment, and supplies. Failure to avoid hazards to food safety and minimize unsafe practices can substantially increase a facility’s susceptibility to a foodborne illness outbreak.
Handwashing Procedure for Food Service Establishments
Food employees shall clean their hands and exposed portions of their arms, including surrogate prosthetic devices for hands or arms for at least 20 seconds, using a cleaning compound in a handwashing sink (FDA Food Code 2017).
1. Wet hands and arms under clean water at least 100 F.
2. Apply sufficient soap to create a lather.
3. Rub hands and arms vigorously for at least 10 to 15 seconds.
4. Clean underneath fingernails and between fingers.
5. Rinse thoroughly under clean, running water.
6. Dry hands and arms with a single-use paper towel or hand dryer.
7. Use a single-use paper towel to touch surfaces, such as the sink faucet or restroom door.
Personal Hygiene
Proper personal hygiene is one of the most important factors for food safety. Hand hygiene should be recognized as a first-line defense. Employees must wash their hands properly and at appropriate times when working in a food service establishment.
Requirements for hand hygiene are outlined in the FDA Food Code 2017, Section 2-301.11-16 (Personal Cleanliness, Hands and Arms). Importantly, handwashing is permitted only in a “handwashing sink,” and is not permitted in sinks used for food preparation, ware-washing, or service sinks (such as in janitorial closets). Hand sanitizers are permitted only immediately after proper handwashing has occurred. They must meet certain criteria—and cannot be used in place of handwashing.
Some health departments permit bare hand contact with food, after proper handwashing, while others require that gloves be worn while working with food. It is advisable to avoid bare-hand contact, even if your health department allows it.
Always wash hands properly before putting on gloves to avoid contaminating the gloves, as well as after removing gloves. Change gloves as often as necessary—definitely when they become soiled or torn—and when changing tasks.
Food Preparation
Biological hazards, especially bacteria, are of great risk to food safety. Conditions that support the growth of bacteria are food, acidity, time, temperature, oxygen, and moisture—often referred by the acronym FAT TOM.
Many foods require time and temperature control to remain safe and are referred to as TCS (Time and Temperature Control for Safety) foods. The temperature
range between 41°F and 135°F is known as the “temperature danger zone.” This is the range in which bacteria can grow rapidly.
Time and temperature control must be practiced throughout the flow of food and is easily regulated with proper food safety practices. This includes thawing, cooking, cooling, reheating, holding prepared foods in storage or for service, and serving. Cold foods must be held at 41°F or below, and hot foods at 135°F or above. Frozen foods must be kept frozen solid. The freezer temperature should be 0°F or below; the optimum temperature is -10°F. In addition, required cooking temperatures and cooling methods must be followed.
Cross-contamination is the transfer of microorganisms or harmful substances from one food or surface to another.
Cooking line.
Thawing. There are four acceptable methods for thawing food by the FDA Food Code:
• Refrigerated at 41°F or less
• Submerged under running water of 70°F or below, providing ready-to-eat food does not rise above 41°F or thawed portion(s) of animal foods are not above 41°F for more than 4 hours
• Microwaved, providing that food is immediately cooked without interruption
• As part of the cooking process
Cooking. Proper cooking can reduce the number of pathogens in food. This means that a required minimum internal temperature must be reached and held for a specific amount of time for certain foods. The temperature and time requirements differ depending on the type of food. For example, ground beef should be cooked to a minimum internal temperature of 155°F for 17 seconds. However, poultry is cooked properly when it reaches an internal temperature of 165°F.
Utilize a calibrated and sanitized thermometer, placing the probe into the thickest part of the food to measure the internal temperature. Do not use surface temperature thermometers, such as infrared thermometers to measure the internal temperature of food.
Purchasing Food from Unsafe Sources
Always purchase food and supplies from reputable suppliers. The safety of food and supplies depends not only on the food and supply items themselves but also on your supplier’s purchasing, storage, and delivery practices. Purchases should come from suppliers with clean facilities, clean delivery trucks or vehicles, and quality products.
When your facility receives a food and supply delivery, use the following checklist:
• Inspect deliveries carefully before accepting products.
• Assure there are no signs of damage, thawing, or out-of-date products.
• Ensure frozen and refrigerated products are delivered via trucks with proper temperature control.
• Check frozen products carefully for signs of thawing.
• Examine the center box of the pallet to ensure it is frozen, not just the outer boxes on the pallet.
Cooling. To avoid the potential for pathogen growth, foods must be cooled properly within a specified period of time. Per the FDA Food Code 2017, TCS foods must be cooled from 135°F to 41°F within 6 hours or less with the requirement that cooling from 135°F to 70°F occurs within the first 2 hours. Never place large amounts of hot food directly into a cooler. The hot food can raise the temperature of the cooler, thus potentially jeopardizing any food items in the cooler.
In addition, coolers are not meant to cool large quantities of hot food within the required timeframes. Food cools faster if pieces and portions are reduced to smaller sizes. Use an ice water bath to start the cooling process. Blast chillers are excellent fast chilling equipment for certain foods, as are tumble chillers for cooked foods that have been bagged or boiled in the bag.
Reheating. In some facilities, food items are cooked, cooled, and then reheated for service. Cooked food items that are reheated for hot holding must reach an internal temperature of at least 165°F for 15 seconds within 2 hours. Commercially packaged ready-to-eat foods can be heated to a minimum of 135°F. Hot food items held for service from a steamtable must be held at a temperature of 135°F or above at all times.
Always cook or heat food to the appropriate temperature before placing it on a steam table. Never use a steam table to heat food. Cold foods held for service from a cold table must be held at a temperature of 41° or below at all times. Always ensure food is cooled properly before placing it on a cold table. Never use a cold table to cool food.
Storing. Proper storage practices help to keep food safe and avoid spoilage. Store food at least six inches off the floor in storage areas designated for food storage. Never store food in janitorial closets, chemical storage areas, restrooms, mechanical rooms, or stairwells. Always store ready-to-eat foods above foods that require cooking, such as meats.
Food items should be marked with the receive date upon delivery. Opened or prepared food items must be covered and dated before they are placed in storage, such as in the refrigerator. Rotate stock using the First In, First Out (FIFO) inventory method, which means utilizing food items with the oldest receive date first.
Cross-Contamination and Contaminated Equipment
Cross-contamination is the transfer of microorganisms or harmful substances from one food or surface to another. It most often occurs from people, food, or equipment to food, and this can occur any time during the flow of food.
People. Food service workers can transfer microorganisms from their body or clothing to food or surfaces. Therefore, these workers must wash their hands properly and often, including before and after each task while working with food—after eating, drinking, smoking, using the restroom, or when changing from one task to another (i.e., from preparing raw foods to preparing ready-to-eat foods).
Employees should not work with food when they are ill or have open cuts or sores. Some illnesses, such as vomiting, require that an employee be excluded from the food service establishment until the employee is symptom-free for 24 hours or has a doctor’s note to return. Refer to your local health department for information concerning ill employees.
Food. To ensure that food items do not contaminate other foods, store all food items properly. In a cooler, store ready-to-eat foods above raw meats, and store poultry on the lowest shelf. Be careful not to add contaminated or raw foods to already cooked or ready-to-eat foods. Cover or wrap ready-to-eat foods or leftovers to avoid contamination from other foods.
Equipment. Surfaces and equipment can harbor large amounts of microorganisms that can be transferred to food, especially if the surface or equipment has not been washed, rinsed, and sanitized properly. In addition, it is advisable to use different cutting boards for raw foods such as meats versus ready-to-eat foods such as produce. Always wash, rinse, and sanitize cutting boards properly between uses.
All food contact surfaces must be washed, rinsed, and sanitized:
• before and after each use,
• when changing tasks or food products, and
• at least once every four hours when in continuous use.
For thermal sanitizing, ensure the proper temperature of the hot water for the task. For chemical sanitizing, ensure the concentration is in accordance with the chemical product label for the task. If wiping cloths are used, they need to be stored in a sanitizer solution between uses.
Assistance from Your Chemical Supplier
Your chemical supplier can assist with the most appropriate and approved chemicals for the tasks required. Engage the chemical supplier in a review of:
• your kitchen operations,
• the types of food being stored,
• type of foods being prepared,
• preparation methods,
• types of equipment being used,
• areas requiring cleaning,
• areas requiring cleaning and sanitizing, and
• cleaning equipment and methods (i.e., dishwasher and/or 3-compartment sink, etc.).
Sanitation Practices
The safety of food in your facility is highly dependent on appropriate sanitation practices, which can increase or decrease the possibility of food contamination and the incidence of a foodborne illness outbreak. Strong sanitation practices, adhered to consistently as part of the overall food safety program, will assist with assuring that food is safe for consumption.
Cleaning is required in all areas of the food service establishment. In addition to cleaning, sanitization is required for all food contact surfaces. Per the FDA Food Code 2017, sanitization means: “The application of cumulative heat or chemicals on cleaned food-contact surfaces that, when evaluated for efficacy, is sufficient to yield a reduction of 5 logs, which is equal to a 99.999% reduction, of representative disease microorganisms of public health importance” (FDA, 2017).
Sanitization
Sanitization can be achieved thermally (using hot water or steam at a specified temperature and contact time) or chemically (using approved chemicals for food service at a specified concentration and contact time). The type of surface or equipment may determine the type of sanitization method to be used. For example, dishwashers can be set up for hot water or chemical sanitizing at the time of purchase.
The key concepts of effective sanitation practices in the food service environment are knowing:
• what to clean,
• what requires both cleaning and sanitizing,
• what soils will be encountered,
• what chemicals are needed to complete the required tasks, and
• what steps are needed to complete the cleaning and sanitizing requirements.
It is important to take the time to appropriately and methodically assess the kitchen areas and to determine what needs cleaning and what requires cleaning and sanitizing. For food equipment, determine the type of cleaning to be used for each type of equipment. Some equipment must be cleaned and sanitized in place, as it cannot be disassembled. Other equipment can be partially or completely disassembled for cleaning and sanitizing. Determine for each type of equipment what method of sanitization is to be used, and if it needs to be thermal or chemical.
To effectively clean and sanitize, multiple types of chemicals and application methods may be required. For surfaces that only require cleaning (non-food contact surfaces), cleaners are sufficient. However, for food contact surfaces, a food service-approved
chemical sanitizer will be needed for chemical sanitization. Different foods create different types and amounts of soil and grease. The clean-ability of the surface on which there are soils can affect your cleaning and sanitizing effectiveness. In addition, water temperature and pH can affect the efficacy of a chemical.
Dishwashing Practices
Special attention needs to be given to your dishwashing practices. The proper use of a three-compartment sink is essential to ensuring that kitchen wares are washed, rinsed, and sanitized properly. Equally important is the proper operation of dishwashing and tray-washing machines. It is a best practice to use an automatic chemical dispensing system for a three-compartment sink as well as a dishwashing or tray-washing machine. An automatic dispensing system will eliminate the need to dilute chemicals manually, where many mistakes in calculating appropriate concentrations are made.
In addition, the following actions need to be performed:
• Assure all staff completing the ware-washing tasks are properly trained on the use of the equipment, proper water temperatures, and chemical concentrations.
• Ensure that staff is adhering to time and temperature requirements.
• Frequently test chemical concentration levels in the sanitizing compartment by using appropriate concentration test strips.
• Always allow kitchen wares to air dry.
• Do not store wet items on top of each other, such as pans. This is referred to as “wet nesting,” and can be a hotbed for the growth of bacteria.
What is a HACCP Plan?
One way active managerial control can be applied is through a Hazard Analysis Critical Control Points (HACCP) Plan. However, a HACCP Plan is not required to practice active managerial control.
The FDA defines HACCP as: “A management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product” (FDA, 2018).
Guidelines on HACCP development and implementation are available in textbooks and on the internet. Training on what HACCP is and what it entails should be completed before attempting to develop and implement a HACCP Plan.
Ensuring a Safe Food Service Operation
A management system for food safety, often referred to as active managerial control, specific to the facility’s food service operations should be written and implemented. Active managerial control is a proactive, rather than a reactive, system for food safety. To succeed, management and staff must take an active role in ensuring food safety through:
• forward-thinking;
• identifying risks;
• addressing how to avoid, reduce, or eliminate those risks;
• monitoring food safety measures;
• ensuring corrective actions are implemented;
• ensuring staff are trained properly; and
• re-evaluating the system periodically to ensure it is working as needed.
Active managerial control should include procedures, practices, measures, monitoring, and corrective actions for all phases of the food service operations and the flow of food.
To practice active managerial control, take the time to:
• Write detailed food safety and sanitation procedures for all aspects of your operation (i.e., receiving, storing, cooking, cleaning, sanitizing, etc.) with step-by-step instructions on how to accomplish tasks clear enough that employees can follow the instructions and complete the tasks correctly.
• Develop procedures for operational processes, such as cooking. Create recipe cards and documents with a list of ingredients and quantities, exact steps to follow, including required temperatures that must be reached, and exact cooling steps or holding requirements if the recipe is not prepared for immediate service.
• Develop cleaning and sanitizing schedules to accompany the Sanitation Standard Operating Procedures (SSOPs) to ensure that tasks are completed as required (i.e., daily, weekly). SSOPs include:
— an effective date
— title of the SSOP
— description of the task (i.e., cleaning preparation tables)
— frequency of the task
— chemicals and supplies needed
— exactcleaning and sanitizing steps
— records and documents to use for monitoring
• Implement a system of self-inspections to measure the effectiveness of the system of active managerial control. Document the inspections, violations found, corrective actions needed, the person(s) responsible, and completion of corrective actions.
Food Safety and COVID-19
The CDC and FDA have both reported that so far in the COVID-19 pandemic there is no evidence of COVID-19 transmission from food or food packaging or containers. It is, however, possible for viruses to survive on surfaces. Therefore, proper cleaning and sanitizing can assist in reducing the possibility of the transmission of any virus, not just COVID-19.
Ensure that chemicals used for disinfecting are food-service approved and on the EPA List N of chemicals approved for disinfection against COVID-19. Clean non-food contact surfaces, clean and sanitize food-contact surfaces, and frequently disinfect high-touch areas (such as light switches, door handles, etc.).
Conclusion
Food safety is critical and should never be taken lightly. Although all the information, standards, and requirements for food safety can be overwhelming, food safety really boils down to understanding how food can become unsafe and what to do or not do to prevent that from happening.
The correctional environment itself can present challenges to food safety. Often incarcerated persons are utilized as a part of the food service workforce, in most cases with no previous food service experience, and the turnover rate can be substantial. Yet, everyday meals must be prepared and served safely no matter what issues arise.
Steps to ensuring food safety include:
• Avoid practices that make food unsafe.
• Utilize the certified food manager programs recognized in your state.
• Follow food safety standards of your local health department and the FDA Food Code.
• Expect staff to follow food safety practices and correct and train them when they don’t.
• Inspect your operations continuously and use findings, both positive and negative, as training subjects and opportunities.
• Ensure that supervisors model good food safety practices at all times.
• Keep detailed and complete records and documentation.
Continuous attention to food safety details is imperative to a successful food service operation, and so is adequate training of the food service workforce. This article has covered many aspects of food safety, but there is always more knowledge to be gained. I encourage everyone working in food service to become familiar with and follow the standards and guidelines of your local health authority and the FDA Food Code.
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Debbie Graham is a Registered Environmental Health Specialist/Registered Sanitarian and a Registered Dietitian. She spent 32 years in county government, with more than 28 of those years in corrections, retiring as a Division Chief in Miami, Florida. She can be contacted at fsbcmdrdebbie@yahoo.com.
References
Centers for Disease Control and Prevention (CDC). (2015). Guide to confirming an etiology in foodborne disease outbreak. Retrieved from www.cdc.gov/foodsafety/outbreaks/investigating-outbreaks/confirming_diagnosis.html
Centers for Disease Control and Prevention (CDC). (2018). Burden of foodborne illness: Findings. Retrieved from www.cdc.gov/foodborneburden/2011-foodborne-estimates.html
Centers for Disease Control and Prevention (CDC). (2022). National outbreak reporting system dashboard. Atlanta, Georgia: U.S. Department of Health and Human Services, CDC. Retrieved from wwwn.cdc.gov/norsdashboard/
U.S. Department of Agriculture (USDA). (2019). What does food safety mean? Retrieved from https://ask.usda.gov/s/article/What-does-food-safety-mean
U.S. Food and Drug Administration (FDA). (2017). FDA food code 2017. College Park, Maryland: U.S. Department of Health and Human Services, FDA. Retrieved from www.fda.gov/food/fda-food-code/food-code-2017
U.S. Food and Drug Administration (FDA). (2018). Hazard analysis critical control point (HACCP). Retrieved from www.fda.gov/food/guidance-regulation-food-and-dietary-supplements/hazard-analysis-critical-control-point-haccp