Retail: Is your food safety management system healthy?

Food Safety Management System

Food safety management system

When a facility has a functioning Food Safety Management System (FSMS), team members perform better, and customers will receive a consistent message when visiting.

In Maryland a HACCP plan is required for every moderate and high priority facility when they start up.  Often, they become forgotten until a health inspector asks to review it.  A HACCP plan should not be looked at as “just another requirement”.  A well written HACCP plan should be part of your overall food safety management system and should be part of your day to day operations.  However,  HACCP is only the beginning of your full Food Safety Management System.

What is a FSMS?

The short answer is;  Team members understanding,  consistently following and documenting the processes and procedures you have in place to minimize the risk of contamination of food.

Let’s take a more in-depth look at what your system would look like.


The first step in creating your Food Safety Management System is to have a commitment to food safety.   No matter what your brands message is your team needs to understand that without food safety you cannot provide a consistent message to your customers.  This starts from the top down.  When team members think the “bottom line” and sales is all you care about food safety will not be a priority.  Unfortunately, the two go hand in hand.


Next establish your Standard Operating Procedures (SOP’s).  This would include; your purchasing program that ensures your food is from a safe source, personal hygiene program, employee illness, cleaning and sanitizing program, how your facility avoids cross contamination, and establishing time and temperature controls to avoid bacterial growth.  The person writing the SOP’s need to have a good understanding of food safety and the current practices and procedures of the facility.  This is the core of preventing contamination to food.

Hazard Analysis

After your SOP’s are established you must look at every menu item and determine where a biological hazard could occur.  These are called critical control points.  In a Maryland retail food facility this would be steps in the process like cooking, cooling, reheating and hot holding.   Again, the person doing the hazard analysis must have a good understanding of food safety risks.  There are special considerations when the facility does certain practices like; using time as a public health control, cooks using sous vide, does any reduced oxygen packaging, uses additives or preservatives, cures food like bacon, displays seafood, squeezes juice or offers live shellfish in a display like a lobster tank.

Food Process Charts

Using data from the Hazard Analysis, create the food process charts.  The Department of Health and Mental Hygiene offers four methods of creating charts.  I prefer to use method #2.  I feel that it is the easiest for food handlers to understand and follow along.   For every CCP identified in the Hazard Analysis you must list the critical limit, how monitoring will take place, what corrective action you should take if there is a deviation in the critical limit and how will you verify the monitoring took place.


Congratulations!  You now have a HACCP plan.  Now we need to make sure that team members are on the same page.  That is where training come in.   Training should be job specific and ongoing.  Divide your facility into stations, for instance, prep, expo, servers, warewashing, etc.   Review your SOP’s and make sure you include all necessary points in the training.    Remember, everyone in your facility should be trained in personal hygiene and employee illness.  Training can be computer based, group, one on one or a combination.  I believe the best training starts with computer-based or group training and then one on one with a qualified team member providing the training.  During training, be sure to correct the team member when doing something incorrectly. This can be done gently and politely but now is not the time to worry about hurt feelings.

Monitoring and Verification

Our system would not be complete without making sure that it is working.  We do this through monitoring the critical limits established in the food charts and monitoring team members to ensure that all SOP’s are being followed as well.  Monitoring is an action, for instance, it could be a visual observation or actually taking a temperature reading of cooked food.   Verification occurs when monitoring is documented through charts and logs.  The team member performing the task documents the result.  Managers must review these logs and documents to ensure the system is working the way it should.

For instance, if a team member had to cook the chicken longer than the procedure states they would document this as a corrective action.  Managers then review the corrective action documents and can then investigate why the corrective action had to be taken.  Perhaps, they deep fryer is not working correctly, or the team member placed too much chicken at one time in the basket.  Management can make corrections by either repairing equipment or retraining the team member.


When you make menu, equipment or structural changes the entire system needs to be reevaluated.  Maryland requires your HACCP be revised every 5 years or when significant changes have taken place.

You think the last place you ate made you sick? Here is what to do.

Social media can be an excellent source to share information.  But when bad information is shared it can unfairly harm a business’s reputation.

I often see posts where someone claims that they became sick or got food poisoning from a restaurant.   The problem is most often you did not get sick from the last thing you ate.  It just may have been your bodies “tipping point” of when the vomiting and or diarrhea starts.

Take a look at this chart, it lists the top 6 pathogens as identified by the CDC1.  I have included estimated number of cases, transmission, incubation period, duration and symptoms.  Although this is just a quick overview of these pathogens it will help you see that each pathogen is different from each other.  Remember there are approximately 40 pathogens that can cause illness in humans.


Pathogen Mean estimated number of cases each year. How do humans typically get sick. Onset or incubation period before symptoms appear Duration of your illness Symptoms
Norovirus 20 million Ready to eat foods or by drinking contaminated beverages.  Touching a surface and putting your hand in your mouth could also be a source.  Only a few cells are necessary to cause illness. 12-48 hours 1-3 days Diarrhea, vomiting, nausea, stomach pains.  Sometimes fever and body aches
Campylobacter 1.3 million Most illnesses likely occur due to eating raw or undercooked poultry, or to eating something that touched it. Some are due to contaminated water, contact with animals, or drinking raw (unpasteurized) milk.

Only a small number of cells is needed to cause illness.  A single drop of poultry juice can contain enough cells!

2-5 days 1 week Diarrhea (often bloody), fever, cramping, nausea, vomiting
Salmonella 1.2 million Can be found in many foods, including sprouts and other vegetables, eggs, chicken, pork, fruits, and even processed foods, such as nut butters, frozen pot pies, chicken nuggets, and stuffed chicken entrees. 12-72 hours 4-7 days Diarrhea, fever, cramps
Clostridium Perfringens 1 million Beef, poultry, gravies, and dried or pre-cooked foods.  Especially those left out for too long during cooling. 6-24 hours 24 hours Diarrhea, cramping, usually there is no fever or vomiting
Shigella 500,000 Found in human feces, so any contact with feces from a person that had shigella can become contaminated very easily, even weeks after they are better.  This transmission could happen when changing a sick baby’s diaper, during sex or eating foods that person touched without proper hand-washing.   It only takes a small number of cells to cause illness. 1-2 days 5-7 days Diarrhea, fever, stomach cramping
Staphylococcus Aureus (Staph) 300,000 Ready to eat foods that require refrigeration that have been handled by someone that is a carrier of Staph.  25% of healthy adults are carriers in their nose or infected cuts.  Contaminated food is left at unsafe temperatures for too long.  Cooking will typically kill the bacteria but sometimes a toxin is formed and those cannot be destroyed. 30 minutes – 6 hours 1 day Nausea, vomiting, cramps, most have diarrhea but not always.

As you look at the data, you see that the only pathogen that causes illness right after eating is Staph.  There are 300,000 estimated cases a year.  That is still a large number of people getting sick from improper handling of food, but statistically you are more likely to be ill from another pathogen.

What does this mean?

Do NOT immediately blame the last place you ate and publicly shame them.   I am in no way dismissing your illness and how bad you felt.  But making false accusations can be very harmful to someone already in a grueling business.

What should you do?

First and foremost, take care of yourself.  If you experience symptoms of foodborne illness, such as diarrhea or vomiting, drink plenty of fluids to prevent dehydration.

Then report the illness, doing so helps alert the health department of a possible outbreak.

They will likely do an investigation including asking you what your exact symptoms are and what foods you ate in at least the last 7 days.  They may also ask you go to the doctors to be tested.  A doctor is the only sure way that your illness can be diagnosed.

If you don’t feel it is necessary to make a report here is the recommendations from the CDC2 of when you should seek medical attention:

  • High fever (temperature over 101.5°F, measured orally)
  • Blood in stools
  • Frequent vomiting that prevents keeping liquids down (which can lead to dehydration)
  • Signs of dehydration, including a marked decrease in urination, a very dry mouth and throat, or feeling dizzy when standing up.
  • Diarrhea that lasts more than 3 days

But remember, unless you have the illness diagnosed, understand the incubation period, think of what you ate that is typically associated with that illness during that time period and make a report, please do not blame a restaurant for your illness.  Remember, the illness could have come from your own home.  Be informed. Be smart.


  1. gov/foodborneburden/pdfs/scallan-estimated-illnesses-foodborne-pathogens.pdf
  2. gov/foodsafety/symptoms.html

Time as a control for food safety.

Do you use time as a control?

Are you wondering what that means?

Here are some examples of when my clients have successfully used time as a control on TCS foods;

  • Breading mixes that are in almost constant use. You may be breading items like fish or chicken every 15-30 minutes and refrigerating the breading isn’t practical.
  • Catering or displays of food.
  • A cold holding station does not maintain 41°F or below during peak times.
  • Cooked pizza displayed and being sold by the slice but 135°F is not being maintained.

These are just a few times when you may need to use time rather than temperature to control the safety of your food. Remember from the food safety training class you learned that food left in the temperature danger zone (41°F – 135°F) for more than 4 hours is discarded. This is because bacteria can grow to levels that can make the customer sick after this time period.

So, using this principle we can use time as a control, rather than temperature. This is sometimes called “time as a public health control”.

The following information is for Maryland retail food facilities, remember that your county/city may have different regulations and you should always follow those rules.  The basic rules that you will need to follow are:

  • You must obtain written permission from the local health department. This means it MUST be in your HACCP plan as a critical control point for that food product.
  • You must have verification procedures in place. Either have a log or time stamp the product container with the time it was removed from temperature control and the time it must be discarded.
  • There needs to be procedures in place to make sure the food is discarded at or before the 4 hours.

As you can see there may be valid times when using time as a control could be very beneficial.

If you have any specific questions about this topic or any other questions about food safety, please contact our office at 410-687-1015 and we will be happy to help.

The code this is based on is listed in COMAR Use of time-only with potentially hazardous foods. The above information is advisory in nature only.

Washing your chicken is dangerous

Did you know that there is no federal regulation that for zero tolerance of Salmonella and Campylobacter on the chicken you purchase?Raw Chicken

That is right, your chicken could and probably is swimming in potentially harmful bacteria.  There is an initiative to reduce the amounts that are present but feds are not considering a zero tolerance policy at this time.

So how can you prevent these bacteria from wreaking havoc on your customers or family? 

Avoid cross contamination

  • Do not wash your chicken in a sink.  There is no need to wash chicken. You only increase the chance of spreading these pathogens all over your kitchen especially if you use a spray hose.
  • If you must rinse chicken place in bowl, filled with water, gently place chicken in bowl. Agitate and drain off water.

Wash your hands

  • Hand-washing after handling raw chicken with warm or hot water, plenty of soap and vigorous scrubbing will reduce the risk that you transfer pathogens to other surfaces in your kitchen.

Clean and sanitize

  • Using a good detergent wash areas that the chicken has touched.
  • Rinse with clean water and then sanitize using an effective solution.

Avoid Temperature abuse

  • Cook chicken to an internal temperature of 165°F and you will destroy those harmful bacteria. Don’t forget to promptly refrigerate foods after cooking to avoid other pathogens from causing problems.

Food Safety Tip: Thawing TCS (aka Potentially Hazardous Food)

There are 4 common methods of thawing food.  You can place in the refrigerator, in the microwave but you must cook the food immediately after, and as part of the cooking process, or under running water


When you are thawing foods under running water you need to follow these simple rules to protect the food from time and temperature abuse;
1. Submerse the product in a pan or bowl. Do not ever place directly in a sink.
2. Have water running over product that has enough flow to constantly change the water in the bowl and agitate loose particles off the food.
3. Water should NEVER exceed 70°F.
4. Do not attempt to thaw items that will take a long time like a whole chicken. Anytime food is 41°F* or above for more than 4 hours it needs to be discarded. For instance, if the surface of the chicken is above and the inside is still frozen you would need to discard.

*Note, when thawing ROP food the temperature must remain under 38°F.





When thawing fish that are stamped with “Keep Frozen – Remove from packaging then thaw under refrigeration” there is a risk of clostridium botulinum, a very serious and potentially deadly bacteria. It is important that proper thawing take place. FDA Food Code 3-501.13(E) states that: REDUCED OXYGEN PACKAGED FISH that bears a label
indicating that it is to be kept frozen until time of use shall be
removed from the reduced oxygen environment:
(1) Prior to its thawing under refrigeration as specified in
(A) of this section; or
(2) Prior to, or Immediately upon completion of, its thawing
using procedures specified in (B) [discussed above] of this section.

The best method to use would be remove the product from packaging when frozen and place in the refrigeration.  Alternatively, you can thaw under running water as discussed above but the product must be removed from the package the moment it is thawed.


FDA Code 3-501.13(A-E)

COMAR D (1-6)


Food Safety Tip Tuesday: Cold Holding in a refrigerator

Cold holding is an integral part of food safety. 

Holding food at incorrect temperatures is one on the top 5 reasons there was an outbreak in this county.



Depending on your jurisdiction you may not be required to log the temperature more than once or twice a day and often there are no requirements for logging.  I recommend that you check and log refrigeration equipment temperatures every 2 hours to ensure time to take a corrective action.   The inside thermometer is sufficient for logging however, you need to ensure the thermometer is accurate.  I recommend checking the internal temperature of a sampling of food at least once a week and comparing with the internal thermometer.  You should also do internal sampling anytime a thermometer is dropped to ensure proper calibration.

Verification through logging

Have staff record the internal temperature of all equipment in a daily log book and a shift manager should review recordings for possible problems. In my experience, as a third-party inspector, I often see log books that are completed with temperatures outside the critical limit with no action being taken.  This has cost business big money when all TCS foods must be discarded.

Corrective action

If you find that food is stored above 41° F and the time is less than 4 hours and verifiable, you can move the food to a freezer or walk-in for quick chilling.  You must check the temperature before the end of 4 hours to ensure the food has been returned to 41°F or below.  If it is still above 41°F you must discard.


Staff should be properly trained on how to take internal food temperatures and the proper location the hanging thermometer should be placed in the unit.   Hanging thermometers should be placed in the warmest part of the unit, which is usually just below mid-point on the and toward the front where the door opens.  When taking internal temperatures use a thermometer that has been calibrated.  Do not touch pan sides or bottom.

FDA food code 3-501.16(A)(2) and COMAR b(7) states that cold food be held at 41°F or below.

In Maryland, you must store pasteurized crab meat at 38°F or below. 

Always check with your local jurisdiction as recommendations / requirements may be different.

Is your facility allergy friendly?

Do you have an allergen program?

Do you “just know” what products you sell contain an allergen?

Without looking, what are the allergens in Hot Dogs, Crackers or Potato chips?

Now go look. Were you right?  Did you possibly miss allergens like milk in many hot dogs and crackers, soy in all three or peanut oil in some potato chips?

Here are some facts about allergies*:

  • It is estimated 9 million, or 4% of adults have food allergies,
  • 6 million, or 8% of children have food allergies.
  • Allergies increased 50% in children between the years of 1997 to 2011, with no explanation as to why.
  • Every 3 minutes someone is admitted to a hospital due to food allergies.

What causes the allergic reaction?

It is a bodies negative reaction to proteins in the food. Proteins are not destroyed during the cooking process and can remain on cooking equipment, deep fry oils, batter, breading and utensils.  It only takes a very small about of the protein to cause a reaction.

What are the major food allergens?

Although there are hundreds of foods that can cause a reaction in humans the FDA has determined that 8 foods account for 90% of the negative reactions.  These foods must be clearly identified on the labels of packaged foods.

  •                 Wheat
  •                 Milk
  •                 Dairy
  •                 Soy
  •                 Fish
  •                 Crustacean shellfish
  •                 Peanuts
  •                 Tree Nuts

What can you do to prevent your customer from having a negative reaction to food from your facility?

 Be proactive. Have a plan in place!  Sounds simple right?  Not so fast.  When I ask students what is your plan where you work.  Many respond by saying “they tell the chef” or “it is marked on the ticket the person has an allergy”.

That is not a plan!  A plan needs to look at every aspect of your facility from design to service.  If a food can not be assured safe then it should not be offered to a guest with an allergy.

Let’s talk about a better method of controlling the risk of allergens.

  • Designate a lead Allergen Manager (LAM).
  • The LAM should inspect all food that arrives at your facility checking labels for allergens.
  • Create a spreadsheet to assist LAM and chef in exploring all foods that enter facility that are commercially prepared. List the 8 allergens across the top and all ingredients that come in to the facility on the left.  Mark an “I” for ingredient in the corresponding box associated with the allergen listed on ingredient list.
  • Create a similar spreadsheet for each menu item.  LAM and Chef should work through entire menu identifying which dishes directly contain an allergen and which ones could be affected by cross contact.  Don’t forget about those sub-ingredients!
  • LAM and Chef should have a good working relationship and be in constant communication when practices or menu items change.
  • LAM needs to share this information with an AM (Allergy Manager) for each shift.
  • Shift AM should hold training sessions with all food handlers discussing proper techniques for avoiding cross contamination from receipt of food to service.  Also discuss proper cleaning and sanitizing of surfaces before starting to prepare a dish for a guest with an allergen and of course proper handwashing.
  • Shift AM should train wait staff that when a guest requests a substitution they should ask if it is for a personal taste preference, dietary restriction or an allergen.  If it is for an allergen staff should immediately call for the AM on duty to assist guest with the order.
  • Place a message on table placard or menu reminding guests “If a member of your party has a food allergy please let your server know.”

In Maryland it is required that you have a poster reminding staff of the 8 allergens.  This poster can be found at

For further assistance with developing a food allergy program in your facility please contact Sue Farace, CP-FS at 410-382-4325


Source: FARE

Better for you, Oatmeal Raisin Cookies

I wanted a healthy version of the classic oatmeal cookie. After searching the internet I could only find no sugar no flour cookies or the classic full of fat and sugar.  So, I came up with my own version.  The bananas, raisins and the little bit of sugar make them enjoyable even for this sweet tooth.  Hope you enjoy!

Preheat oven to 350°F

3 med ripe bananas

1/3 cup applesauce

¼ cup milk

1 t vanilla

1 t cinnamon

¼ t nutmeg

1 t baking soda

3 Tablespoons of coconut oil

¾ cup of flour

1/3 cup of sugar

3 cups Oats

½ cup raisins


Add all ingredients except flour, sugar, raisins & oats in mixing bowl. Mix thoroughly on medium speed.  Add remaining 4 ingredients.  Depending on the size of your bananas you may need to add more or less flour.  The mix will not be firm like a regular oatmeal cookie however you should be able to spoon out on pan.  Place on nonstick or lightly oiled cookie sheet.  Bake for 10-12 minutes.



Perfect Home-baked Sandwich Bread

This loaf has a soft crust and light texture making it a perfect loaf for sandwiches.   The dough is easy to work with due to the butterfat content and perfect for someone just starting out with bread dough.


1 package dry yeast

1/3 cup warm water

1/2 Tablespoon sugar

1/2 teaspoon salt

2 eggs, room temperature

1/2 stick unsalted butter, melted and room temperature.

appx 2 cups bread flour

appx 1 cup all purpose flour



In mixer bowl with flat beater add water, sugar and yeast.  Mix then allow set for 2-3 minutes.  Add melted butter, eggs, salt and one cup of the bread flour, mix until smooth.  Slowly add 1/2 cup of all purpose flour at a time and mix again until smooth.  Mix for 5 minutes. Dough should be smooth and elastic looking.  Change beater to dough hook.  Add flour 1/4 cup at a time alternating between bread flour and all purpose.  When dough forms a ball and cleans sides of bowl kneed for another 5 minutes. You can add flour a tablespoon at a time if needed.

Continue mixing until smooth looking.

Change beater to dough hook.  Add remaining flour alternating between bread flour and all purpose.  When dough forms a ball and cleans sides of bowl kneed for another 5 minutes. You can add flour a tablespoon at a time if needed.

Scrape down if dough starts "riding up" hook. Add just a sprinkle of flour.

Remove from bowl and form ball.  Place in lightly greased bowl and cover.  Allow to rise until doubled, approximately 1 hour.   Punch down and form into loaf.  This dough is very forgiving and can be used for rolls if desired.

Allow to rest for another 40 minutes or until doubled again.

Bake in preheated oven at 375° F for about 30-40 minutes. For a thicker, chewier crust add a pan of water to bottom of oven to create steam. Allow to cool on rack.  

Slice and ENJOY!

Are you the cause of foodborne illness and not even know?

Have you ever had a foodborne illness outbreak at your facility? Most will answer NO!  But how do you really know?

The CDC estimates that 48 million people will be ill from a foodborne illness each year.  That is one in six Americans.


In 2013 there were a total of 818 outbreaks resulting in 13,360 illnesses.  Identified outbreaks a small percentage of total estimated cases of 48 million.   Of the total 818 outbreaks 433 of all outbreaks were a restaurant.  351 were from sit down dining locations as opposed to fast food.  The remainder of outbreaks occurred in the private home, catering /banquet facilities, institutions, nursing homes / hospital, churches, or other commercial locations.

Why are there so many outbreaks / illnesses that go unreported?  Part of the problem is many people do not equate having diarrhea or vomiting with having a foodborne illness.  I hear people all the time stating it is a bug going around or something they ate didn’t agree with them.  Many just don’t want to go through the trouble of contacting the local health department.  There are many more reported foodborne illness cases reported that do not become an outbreak statistic.  Maybe so far you have been lucky.  Reminder, it only takes 2 individuals with the same illness from the same time span and you find yourself part of an outbreak investigation!


According to the CDC, the cost of foodborne illness is estimated at $365 million in direct medical costs.  Costs that you will be expected to pay if found liable!  The loss of your reputation can often be attributed to suspected foodborne illness. It can also affect your bottom line as well in the form of increased insurance premiums, loss of sales and legal fees defending yourself in a court of law.

Executives like Eric and Ryan Jensen of Jensen Farms have been charged criminally liable for the outbreak associated with listeria tainted product.  In 2013 they entered a plea deal and in 2014 they began a six month home confinement sentence.  CEO, Stewart Parnell of Peanut Corporation of America is now serving a 28 year sentence for liability related to Salmonella tainted peanuts.  Brother Michael Parnell is serving 20 years and the plants quality assurance manager, Mary Wilkerson is serving 5 years.

The department of justice is currently looking at charges against Blue Bell Ice Cream for listeria tainted ice cream and Chipotle for recent  E.Coli and Norovirus outbreaks

These examples demonstrate the FDAs warnings that they will enforce criminal penalties.  If you are a person in charge, you must create a food safe culture in your organization and put policies and procedures in place to make sure staff are following the rules.



Regardless if you are a single location restaurant or part of a larger corporate entity you should have a good Food Safety Management system in place.

Corporations spend thousands and have binders filled with policies and procedures.  But that should not intimidate that small business owner.  They should also have plans in place to create a consistent and food safe culture.


A Personal Hygiene Program is paramount!  Having good personal hygiene is the best prevention against the number one single pathogen that causes foodborne illness, Norovirus.

A Food Safety Training Program is also critical.  Most likely someone in your facility has been properly trained in food safety.  But training should not stop there. Everyone in the facility, food handlers and non-foodhandlers need to understand how to protect the food and the customer.  Ongoing in house training is essential.

SOP’s should be written clearly.  They should not be a boiler plate of rules and regulations.  They should be the procedures you follow in your facility. Included in SOP’s would be supplier selection, proper cleaning and sanitizing, cross contamination prevention, employee health and hygiene and employee illness reporting.

HACCP Plans should be maintained and up to date.  It is advised to have your plan reviewed at least every 5 years. It is mandatory in Maryland that your plan accurately reflect your current menu and should be updated as menu items change.

Allergen Prevention is certainly an area that should not be ignored.  It is not advisable to rely on kitchen staff to know if a food contains an allergen.  I can help you set up an easy system that will take the stress off of the staff when a customer mentions they have an allergy.

Pest Control should be under the guidance of an authorized pest control operator.  A good PCO will assist you in the analysis of your facility and areas that need improvement.

Of course, each facility is going to have its own individual needs and plans need to be in place to address those needs.

SMF Training & Consulting can assist your organization in developing a comprehensive food safety management system.  Sue Farace, CP-FS can be reached at 410-382-4325 or by email at