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| Keeping Seniors Safe in the primary reason to establish a Frontlne Defense |
HACCP
Process
In the HACCP (Hazard Analysis Critical Control Point) process there are seven (7) Principles of the
management system to deploy corrective measures at critical control points, ensuring
food or beverages are not compromised during the food processing chain. Under normal conditions the lack of
understanding any part of the 7 processes or the absence of any of the 3 basic corrective
measures may translate in a “Deficient” HACCP Process, or The Potential for Un-Sanitary
Conditions.
For the bases of this article, “There Is More to a
Deficiency Free Survey than a Clean Kitchen”,
I offer the manager’s perspective of the inspection, survey team,
managers and supervisors, as well as how your frontline staff should interact during
the survey process. The objective is not
to develop a Frontline Team that performs, but one that employ’s critical
thinking, with the ability to react to critical
control issues, taking corrective measures when necessary, executing standard
food safety principles with understanding, not just because inspectors are at your facility. I also want to add the perspective that I employ when a survey team is in our facility; "they are guest of our residents, performing the critical steps necessary to insure they have quality of life during a very difficult time in there life". They are not here to "get us", but to validate we have these processes in place.
Guidelines
To Ensure Senior Population Have Safer Food Conditions
The Center for
Medicare & Medicaid Services (CMS) adopted HACCP Guidelines for "Food
Sanitary Conditions" and the protocols surveyors use to investigate the
nations over 15,000+ Nursing Homes, ensuring an already at-risk senior
population, enjoy quality food and service, at a time when they are already at
risk. These guideline are not just
about passing or failing to meet agencies regulations (Tag 371), but the survey
teams observations, interviewing and reviewing of present and past records to
determine "what procedures or processes maybe deficient" of food safety
sanitary conditions, creating not just actual, but the potential for harm.
These conditions can be directly translated into a level of care or lack of quality
of life for residents receiving care in that facility.
Quality of Care Directly Affects Quality
of Life
These
regulations have been written with HACCP Principles in mind, “identifying the potential
hazards” before they affect residents. It
is possible a food service operation can have in place policies, and procedures
but these processes not meet CMS “Food Sanitary Condition threshold. Take for example, shelled or frozen eggs, or
fresh, not frozen chicken parts. These
items are acceptable to purchase and use in commercial food service operations,
but CMS guidelines take into consideration the potential for harm that these
products have if not handled properly at various critical control points. These items bring critical conditions that can
be directly translated into a level of care or quality of life issues for the
senior population. Having non-pasteurized
eggs, in your facility will result in a tag under these guidelines!
Study
of Nursing Facility Deficiencies Influence Change In Inspections
A
study conducted by University of California, "Nursing Facilities,
Staffing, Residents and Facility Deficiencies, 2005 Through 2010"
conducted by Charlene Harrington relieved 40% percent of the nation’s 15,000+ LTD
Facilities failed to meet F-Tag 371. As a result of this study,
several recommendations of how to enforce and reduce deficiencies were made.
Another study by "The American Health Care Association"
associated developed in conjunction with a review of deficiencies identified at
CFR 483.15(a) during the six month period of August 2002 through February 2003.
The Quality Council members chose five areas of potential non-compliance for
review and developed a Best Practice Guide for caregivers and providers.
The term "Deficiency
Free is not just about passing or failing, but quality of life we afford
our residence. This study
further helped develop interpretive guidance, to train survey team members
how and what to look for or “Best Practices” through observation,
interview,
and record
review, insuring compliance. With regard to the
revised guidelines and investigative protocols for F-Tag (F371) Sanitary
Conditions, there have been significant changes in not just methodology of
determining safe food handing, but CMS stepping up educating of survey
teams on interpretation of regulations.
In
addition to completion of the CMS 804; Form: Kitchen/Food Service
Observation, also evaluate the ability of your Dining Services Team to prepare,
present and offer residents an enhanced dining experience. So for the most part, facilities put a lot of
effort in passing the clean test, but that is only the foundation of the food service
observation.
Initial Observation also includes:
• The availability
of food in relation to the number of residents; and
• Whether food
being prepared is consistent with the written, planned menu.
• Meals that are
not consistent in quality (such as color and texture of vegetables or meats,
the preparation and presentation of mechanically altered foods)
• Complaints
regarding taste or texture of food and foods with an “off” or bad odor; or
residents being at nutritional risk, including high prevalence of residents
with unintended weight loss.
Direct observations to the tray line and
kitchen to determine:
•
If
recipes
are available and consistent with the menu and followed by employees;
•
If
appropriate
equipment is available and used to prepare and serve foods;
•
If the food
is being held for more than 30 minutes prior to food service, e.g., in
the steam table, oven, refrigerator rather than freezer for frozen foods, etc.;
and
•
If
cooked
leftovers used during food preparation were stored and used within the
appropriate time frames, and reheated to at least 165 degrees F.
- Conduct observations of food preparation and quality of meals.
Dining Observations:
• To determine if
each resident is provided with nourishing, palatable, attractive meals that
meet the resident’s daily nutritional and special dietary needs;
• To
determine if each resident is provided services to maintain or improve eating
skills; and
• To
determine if the dining experience enhances the resident’s quality of life and
is supportive of the resident’s needs, including food service and staff support
during dining.
There Is More To A "Deficiency Free Survey" Than A
Clean Kitchen
- Part 1 of 3
Part 1 of 3 Part Series- GuidelinesTo Ensure Senior Population Have Safer Food Conditions
Part 2 of 3 Part Series- Dining Service Team OnlyAs Strong as Weakest Link
Part 3 of 3 Part Series- Survey Process As Experienced
By Dining Services Manager
Additional information:
HACCP Seven
Principles to prevent Biological,
Chemical and Physical Hazards
1)Conduct
a Hazard Analysis, 2) Identify the Critical Control Points, 3) Establish
Critical Limits, 4) Monitor CCP, 5)
Establish Corrective Action, 6) Verification, and 7) Record keeping
Also
see supporting references 0n World Wide Web... (PDF Documents)
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