It’s almost Norovirus season!

Norovirus is the number one pathogen that causes foodborne illness in this country!  It is responsible for an estimated 20 million cases of each year.

Statistically more cases occur during the months of November – April.  No one really knows why other than possibly because we experience closer contact during the colder months.  But the facts are the facts and you should want to protect yourself, your customers and your family from getting sick.

Norovirus is often called the “stomach flu” but it is a virus.   You only need to consume a small number of cells to make you sick.  About 10-12 cells is all it takes.

Where does it come from? Human fecal matter.  That is right.  When you become sick from Norovirus you most likely consumed someone’s poop.  There is a possibility if you were near someone vomiting or cleaned up vomit or diarrhea you could have breathed it in.

Did you know that in retail food service facilities only about 30% of food handlers wash hands properly?  WHAT!

To make matters worse, Norovirus can survive on surfaces for up to 2 weeks and become a source of cross contamination.  When someone is sick with Norovirus and they feel better, it can still be in their fecal matter for as much as 2 weeks.   We are not talking about stuff you can see.  These are microscopic cells that cluster together.  When we consume it, we will most likely get sick!

What can you do to protect yourself and the food you serve?

  • Do not eat anything that was touched by unwashed hands and do not touch surfaces and put your hand in your mouth or other objects like pens.
  • Wash hands using soap, vigorously scrub all areas of the hands and exposed portion of the arm, rinse soap off and dry hands using a single use paper towel or air dryer. Use a paper towel to turn water off so you do not recontaminate hands.
  • Do not ever work when you have any diarrhea or vomiting.
  • Wash hands whenever they could have become contaminated. Like touching money, door handles, chairs, phones, before and after you touch a raw protein, after using the restroom and after entering the kitchen.
  • Do not touch ready to eat food like breads or ice without proper handwashing.
  • If someone in your home is sick, do not allow them in the kitchen. Throw out any food they may have touched. I know of a case where someone was eating out of a box of crackers, was later diagnosed with Norovirus and then a week after the person was better someone ate some of the crackers from the box and they became ill with Norovirus.  The contaminated cracker was the most likely source of the contamination.
  • Make sure you provide paper towels in the bathroom, even at home.
  • Clean and sanitize.
    • In your home, the CDC recommends “After you vomit or have diarrhea, immediately clean up the entire area using a bleach-based household cleaner as directed on the product label. If no such cleaning product is available, you can use a solution made with 5 tablespoons to 1.5 cups of household bleach per 1 gallon of water.” As a reminder if using on a food contact surface clean with detergent after the solution has dried.   The high concentration of chlorine can be toxic if consumed.
    • When cleaning and sanitizing surfaces in a retail food service facility you may want to use a disinfectant, however, remember if it is a food contact surface you must clean, rinse and sanitize before using them.

No one is immune from Norovirus, it can cause illness and even death.  Washing hands is the most important thing you can do to protect the food you and others consume.

As always, if you have a question, just ask!

Be food safe,

Sue Farace, CP-FS

Why do some restaurants succeed while most struggle ?

There are many factors that lead to the success of a restaurant.  You have heard the saying; location, location, location, but if the food is inconsistent and service subpar it will be hard to have long term success even in the best location.  You must have a combination of a good physical location that matches the food you are serving, an inviting and clean interior, consistent food quality, great customer service, a good marketing strategy that matches your brand and the funding to start and operate your new venture.

Often very hard working, ambitious people fail because they only focus on one or two aspects of what will create success.    One of the very first and most important tasks you need to tackle is your menu.  You may fine tune it as the process moves forward but you should have a good idea of what you type of foods you will be serving and the price point for each.  You must write a mission statement describing what your brand is about.  This should be two or three sentences.  If a friend asked what type of restaurant you are opening, this is what you would say.  Here is an example;

XYZ is a sit-down casual dining eatery that specializes in high quality made in house charcuterie, cheese and wine locally acquired and imported from around the world and artesian breads made in house fresh daily.  Sandwiches, soups and boards served in an artesian style of table service.  There is a small market area where customers can buy the offerings to take home.

I have a clear vision of what this facility will look like and what type of area it should be located.  It would be perfectly located in a walking area of a town, possibly where tourists frequent or near a theatrical venue.  At this time, we also should think about the equipment we would need to produce the menu items.  This is critical before signing a lease.  You must have the space to fit the equipment necessary and provide a kitchen that can prevent cross contamination.   One last thing before signing lease, make sure you have sufficient funding to build out the facility and operating capital to get started.

When the location is secure, you will need to contact an architect and plan out the facility layout.  You will need to submit drawings, the menu and in Maryland a HACCP plan to the local planning department.   There is much involved here and beyond the scope of this article, but we can help you wade through all the requirements.

When the plans are approved and construction is underway, you will have a lot of decisions to make.  From selecting finishes that match your branding, hiring upper management, securing contracts with food suppliers, pest management, refuse management, POS and credit processing, janitorial supplies, and the list goes on.

Before the facility opens the doors there is much to do.  Training the staff is critical. Not only should there be a certified manager on duty, you must train each and every team member.  Training should be job specific and ongoing.  When the facility is open, the person in charge (PIC) must be active and making sure that everyone is following procedures.

Finally, social media is an important aspect of any food service business.  Prospective customers will check customer review services like Yelp, Facebook and Google.   Any complaints must be addressed in a professional way.  Advertising should match your brand and be varied.  Some common mistakes are posting “stock” photos of food, incorrect information, getting into online arguments with customers and not addressing customer questions online.  The person handling your marketing can be a qualified in-house person or by hiring a marketing consultant.    The key is to be consistent with the brand established.

If you are thinking of starting a food facility, congratulations, it will be one of the most exciting times in your life.  We are here to offer our professional advice and walk through the process with you.  We have experience from conception through continuing operations.   We work with contractors and planning, menu planning, writing your HACCP plan, creating your food safety plan and training.  Do not hesitate to contact us at 410-687-1015.


About us;  Sue Farace, CP-FS has been in food service since 1997, before that she worked in the construction industry for 13 years.  She has owned several restaurants.  She provides training, HACCP plans and consulting and inspection services for over 10 years in Baltimore Metro Area.

Disclaimer: The information provided is intended to provide basic information that can increase your chance of being successful and does not guarantee success. Opening a restaurant is a risky venture. 


Employee Illness in retail food facilities

Why is it important to have a written policy and effective training for employee illness?

The cost of an outbreak is reported to be between $6,330 and $2.6 million dollars depending on type of retail facility and the severity of the illness. 3 An outbreak is classified as 2 or more people.  However, most illnesses related to foodborne illness go unreported and facilities are never implicated.  The thought of “We will most likely not be caught” should not be your policy on preventing foodborne illness.

 64% of outbreaks are from retail restaurants, 48% of those are from sit-down type facilities.1   58% of outbreaks 2 are from at least one employee being ill.  Only 47% of facilities implicated in outbreaks had a written policy on employee illness.

A study4 conducted that interviewed 491 workers from 391 randomly selected restaurants revealed some very important information about employee and management behaviors as it relates to employee illness.   59% of the employees surveyed reported working a shift while ill.  Out of those 59%, 63% of managers were aware of the illness!  81% of the time it was the employee that notified the manager, yet the employee was still allowed to work.  The reasons for continuing to work was;

  • 43% No paid sick leave or sick leave policy
  • 32% Understaffed or no one to cover shift
  • 30% Symptoms did not feel bad or not contagious and
  • 30% Felt obligated or strong work ethic.

Some indicated more than one reason.   This indicates that employees, not managers, were making decisions about when to work.  To make matter worse, of the ill employees that continued to work less than one third washed hands more frequently.

An FDA study published in 2004 found food establishments were frequently out of compliance with the Food Code requirements for proper and adequate handwashing. In the study, the percent of food establishments observed to be out of compliance with handwashing requirements ranged from 34% in hospitals and a whopping 73% in full-service establishments.

In my experience providing third party inspections, when I observed improper handwashing and explained the proper process, many had little to no understanding of how and when they should wash hands or they stated they didn’t have time.

This creates a perfect storm for transferring pathogens from hands of an ill employee to the surface of food.

What illnesses and medical conditions should management and employees be aware of?

There are certain illnesses, exposure to certain illnesses, or even infections that employees must report to management or the Person in Charge (PIC). The PIC must know what the next action should be.  This could be restricting the employee from working around exposed food, excluding the employee from facility and possibly reporting the diagnosis, illness or exposure to the authorities.   There are certain pathogens that employees must be made aware of.  These are called the Big 6.  They are;

  • Norovirus,
  • Hepatitis A virus,
  • Shigella spp.,
  • Shiga toxin-producing Escherichia coli,
  • Typhoid fever (caused by Salmonella Typhi) or
  • Salmonella (nontyphoidal).

Employees also should be made aware that they need to report excessive sneezing, coughing, general nasal discharge, skin cuts, lesions or infections and a sore throat with a fever. Vomiting and or Diarrhea, regardless of frequency.  Jaundice that is less than 7 days old must be reported as well.  Management and Employees should also understand the risks associated with Staphylococcus Aureus.

The person in charge should be most concerned with the following symptoms of foodborne illness;

  • Vomiting
  • Diarrhea
  • Jaundice (yellow skin or eyes)
  • Sore throat with fever
  • Infected cuts and burns with pus on hands and wrists

How are pathogens transferred to food and surfaces?

Transmission can happen in a variety of ways.  Hand to food contact, Hand to surface to food, surface to hand to food.   Water and oils in fecal matter can assist in the transfer of pathogens found in the feces.

How can the PIC prevent the spread of illness causing pathogens from ill employees?

  • Provide employee illness training to all staff members.
  • Be observant and inquire if employees appear to be ill.
  • Management must be informed of the specific circumstances that must be reported and when employees should be restricted from working around exposed food and when they should be excluded from facility.Details are available in the FDA food code subpart 2-201.11-13.
  • PIC must provide on-going and job specific training to all staff. Training should include;How easily pathogens like Norovirus can be transmitted, proper handwashing, proper glove use, and a reminder of all illnesses that must be reported.
  • Food handlers should be trained to not use bare hands to touch Ready to Eat (RTE) foods.
  • Provide a culture where reporting illness and missing shifts does not threaten employee hours or job security.
  • Create a culture of good hand care and reward staff for good practices.
  • Provide adequate supplies for proper hand care and tools for touching RTE foods.

Employee responsibilities and preventions

  • Reporting illnesses as required
  • Always, wash hands when required and using proper methods.
  • Report workers that are not reporting illness to PIC or are not properly washing hands.

It is important that the PIC be knowledgeable about employee illness, reporting, exclusion, and restricting of employees.  This is discussed briefly in the Food Manager Protection training (ServSafe).  Trained staff members must make sure the all staff are trained in employee illness as well.  If you would like assistance creating an employee illness training for your staff, please contact us.  We can provide decision trees, employee agreement forms and other training tools.


  2. NORS and NEARS system, CDC
  4. Carpenter, L. R., A. L. Green, D. M. Norton, R. Frick, M. TobinD’Angelo, D. W. Reimann, H. Blade, D.C. Nicholas, J. S. Egan, K. Everstine, L. G. Brown and B. Le. 2013 Food worker experience with and beliefs about working while ill. J. Food Prot. 76:2146-2154.

Monitoring Food Temperatures

Monitoring refrigeration units.

Have you ever had a unit break down in the middle of the day?  How about a unit that just can’t seem to maintain food temperatures below 41°F?

Both present potential risks to food safety.  Proper monitoring of your units can avoid the costly choice of throwing food away that has become unsafe.

What is required by Code of Maryland Regulations (COMAR)?  Section pertains to storage, service and transport of foods in retail establishments in Maryland.  Today we will focus on monitoring cold food storage only.

The internal temperature of the food must be maintained to avoid pathogenic bacteria and other microorganisms that could cause spoilage.  Most food must be held at 41°F or below except; shell eggs can be stored at 45°F or less, certain reduced oxygen packaged foods like crab meat should be stored at 38°F or less.

The temperature measuring device has 2°F markings, accurate within +- 2°F, calibrated at least annually, is easily readable, and located in the warmest area of unit where food is stored.

Anytime Temperature Control for Safety (TCS) foods or as COMAR calls them, Potentially Hazardous Food (PHF) goes above the required temperature for more than 4 hours the product must be discarded.

This is a summary of the regulations, for complete information read the regulation.

How often are you required to monitor foods?

Surprisingly, there is no regulation that states how often you must monitor foods.  You do need to make sure temperatures are maintained.  So that would infer that you should monitor every 4 hours so you can take the corrective action of throwing the food away.

How often do I recommend you monitor food temperatures?

I recommend that you monitor and record your refrigeration and cooler temperatures every 2 hours.  This will provide you with a verifiable temperature that can be used in case the unit experiences a problem.  The following are two similar examples with different outcomes

Example 1: You monitored the temperature at 12 PM and at 4 PM you discovered the product temperature to be at 57°F.  The only corrective action you can take is to discard the food.

Example 2: You monitored and recorded the temperature at 12 PM and then again at 2 PM.  At that time you discover the food temperature to be at 52°F.  You could move the food to another unit, perhaps a freezer and quick chill the product.  Check the temperature again at 4 PM to verify it is at 41°F or below.  If it is, you just saved your inventory!  The reason is because you had a verifiable temperature at 12 PM and could verify the food was not out of temperature for more than 4 hours.

Important to remember in example 2 is that the temperature was verifiable.  Had it not been recorded you would have needed to discard the food.  The code specifically states that food must be discarded if “The food has exceeded 41°F or more for more than 4 hours; or the time the food has been out of temperature is not verifiable”

How should you monitor temperatures?

You could take the internal temperature of each food in your unit but that would be time consuming and possibly increase the risk of cross contamination.  Monitoring is typically accomplished by having a thermometer in the warmest part of the unit.  I do not recommend using the digital readout on the outside of the unit.  If you notice the lead is typically in one of the coldest parts of the unit, not the warmest.  Try this experiment.  During peak times check what the reader says and then check the internal thermometer and the internal temperature of the food.  Most of the times there will be a difference in these temperatures.  In my experience sometimes 7°F or more.

Remember the thermometer used for monitoring needs to be accurate +-2°F and have markings every 2°.   COMAR requires it be calibrated at least annually however, if it is dropped or undergoes any kind of abuse it should be checked for accuracy.    One simple way to check the stand-up or hanging type is place several in the same unit and make sure they are all the same. Confirm temperature by checking the internal temperature of food that has been in the unit.  It should be with in a degree or two.

If you have any questions about monitoring your temperatures and corrective actions please contact us, we are here to help.

PFA’s in compostable carry out containers

The internet is blowing up about Chipotle and their bowls.  Guess they are an easy target since they have had some mis-steps in the last few years.  However, I feel like they deserve a little pass on this one.

Let me explain.  I did a little research and read the article by Joe Fassler.  He is The New Food Economy’s features editor. He was the one that initiated Notre Dame Chemist Graham Peaslee to test the containers of 14 different locations from 8 different restaurants in NY city.   What they found was that in all of the different samples there was high levels of Florine.  The presence of Florine indicates the bowls were treated with PFA’s.  PFA’s can be linked to a long list of health problems including cancer.

The article that Mr Fassler wrote is long and in excellent detail, so I am not going to rehash his article in my words.  You can read it here:

However, here are a few takeaways I learned;

  • Of the 8 different locations Chipotle was the second highest offender of levels of Florine. Dig had the highest levels.  Sweet Green was the lowest.  Odd that Chipotle and Sweet Green were called out specifically.
  • Although more testing and information about the bowls would need to be obtained, based on the Florine levels the bowls are most likely within FDA guidelines for PFA’s.
  • PFA’s can be transferred from one surface to another.
  • PFA’s allow the plant-based bowls to be used with greasy, wet and hot foods.
  • PFA’s are not biodegradable and will live on forever.
  • All the bowls were certified as “compostable” by certifying company BPI.
  • BPI is changing standards and of Jan 1, 2020. Any bowls treated with PFA’s will no longer pass certification as compostable.
  • When bowls are composted the compost can then be affected. Transferring the PFA’s to food supply during planting and growing.
  • When bowls are thrown in the landfill the PFA’s can leach into water and even after water treatment the PFA’s could be found in our drinking water.
  • PFA’s can be found in many other non-food sources especially fire-resistant carpeting.

My biggest concern is not with the restaurants using theses bowls but with the manufacturers that make them.  They knew they were adding PFA’s, they new that they are not biodegradable.  How was it that they were certified compostable and marketed as such?  There is no other alternative to the clam shells or Styrofoam on the market at this time.  What is a carry out to do when the public and now some cities demand not using Styrofoam ?



Monitoring cold and hot holding temperatures

How often do you check your cold hold and hot hold temperatures?

In food service we must be careful to maintain proper temperatures on temperature control for safety foods (TCS), sometimes referred to potentially hazardous foods (PHF’s).  Temperature control will control the growth of pathogenic bacteria and other microorganisms that could cause spoilage.


Remember, most cold TCS food must be maintained at a temperature of 41°F or below.  Some reduced oxygen packaged food and pasteurized crab meat must be held at 38°F or below.  Hot foods must be maintained at a temperature of 135°F or above for no more that 4 hours.


Monitoring of these temperatures is critical.  How often you monitor depends on what you would want possible corrective actions to be.   If you choose to monitor every 4 hours and you discover the temperature of cold food to be above 41°F or hot food being held below 135° F, the only corrective action will be to discard.  However, if you monitor every 2 hours you may have sufficient time to take a corrective action that will save your food.

Corrective Action

For cold food you can remove from unit that is not maintaining temperature, quick chill in a different unit or freezer and get temperature down to 41°F or below.  Hot food that is below 135°F can be quickly reheated to 165°F or above and your 4 hours starts over.

There is a BUT!  This only works if the original temperature reading is verifiable.  That means it must have been recorded on the product package or in a log book.  The saying goes, “if you didn’t document, you didn’t do it”.

Here is an example:  You placed some chicken soup on hot hold at 12 PM.  You record temperature and place a sticker on the holding pot.  The temperature was recorded at 155°F.  At 3 PM a customer complains the soup is cold, you check the temperature and discover the soup is at 100°F.  You quickly place soup in a stock pot and reheat.  You just saved the soup.  But had the temperature not been recorded at 12 PM you could not have taken this corrective action and would have had to discard the soup. 

Another example:  At 10 AM you check the temperature of you walk in by looking at the thermometer hanging in the warmest part of the unit.  It is 38°F, perfect.   Around 1:30 PM an employee mentions that the unit feels a little warm.  You check and the temperature is 57 °F!  Oh no!  But since you didn’t write the temperature down it is not verifiable and the TCS food in the walk-in should be discarded.   

Same example but this time you recorded the temperature, you check the unit at 12 PM and discovered the unit was 48°F.  You immediately call for service, remove TCS food, place in other units for a quick chill, check the temperature of the food at 4PM and it is all 41°F or below and you just saved a lot of money by taking the time to check your cold units every two hours and recording the temperature.


Can your beverage make you sick?

Have you ever noticed your bartender doing some unsafe practices when making your drink and thought, “It’s cool the alcohol will kill it!”.

You may be onto something when it comes to bacteria.  Certain amounts of alcohol can kill the bad stuff in our gut!  But wait, there is something you should know.

Although wine and spirits have long been used for their alcohol properties to kill bacteria on surfaces you would need to consume a high enough percentage of well over the average mixed drink of 10% alcohol to prevent bacteria from causing foodborne illness in your gut.  The most effective would be in the 80% range, which would be most spirits drank straight.  The bad news is the damage you would do to your gastrointestinal system could cause vomiting, diarrhea, and organ damage.  One study did find that drinking one glass a red wine a day can be good for your gut.  The specific properties of wine seem to be just right to keep the bad bacteria at bay while not destroying the good bacteria and not doing damage to your organs.

Looks like using alcohol to kill bacteria isn’t such a good idea. The news is no better when looking at the effect of alcohol on Norovirus.  Alcohol will not kill Norovirus.  That is right.  You heard it here.  Alcohol will not kill Norovirus.

In 2017, there was a total of 841 reported cases of illness from drinking beverages in a restaurant.  623 cases were from Norovirus.  Norovirus is a virus that only needs about 10-12 cells to make you sick. It grows in your gut, not on food.

Okay, I can hear you thinking, “841 cases that is it?   I will roll the dice!”.  The problem is that most illnesses do not get reported.  Think about it, do you report to the health department every time you get vomiting and diarrhea? NO! The actual number of cases is much higher.

So how can a beverage become contaminated with Norovirus or bacteria?  It can all go back to the bartender.

Bartenders handle money, touch surfaces other guest touch and, quite frankly, hardly ever wash their hands.

These surfaces can contain microscopic fecal matter from customers that do not wash hands after using the restroom.   That fecal matter can then be transferred to your drink!  YUCK!

Have you ever witnessed your bartender making any of these mistakes?

  • Picking up the glass from the rim and not side of cup, then you drink from the rim.
  • Placing things in the ice bin that are not ice, like opened beer, mixers, cups or hands.
  • Scooping the glass through the ice, this is a big risk of the glass or plastic cup chipping and causing physical harm.
  • Items falling in the ice bin. I once saw a customer toss a soiled napkin, missing the trash can it went into the ice bin, the bartender picked it out and went on their way to making a drink.
  • Handling garnishes like lemons, oranges, limes, melon and cucumbers with dirty hands. Tongs and muddler should be used!

Remember all this can spread those nasty feces and cause you to have vomiting and diarrhea.  So maybe it wasn’t the food you at the establishment after all…

Easter Time Egg Questions

Easter is almost here!  What a fun time coloring and decorating hard-boiled eggs with friends and family.

Easter Eggs

But have you ever wondered about how to safely handle your hard-boiled eggs? Below are some of the top questions I get asked during the ServSafe Manager Training.

How can eggs make you sick?

The pathogen of concern is Salmonella.  Salmonella (nontyphoidal) is the number 2 pathogen that causes foodborne illness in the US and the number 1 that causes hospitalization and death.  The CDC estimates over 1 million illnesses a year.  79,000 of those come from of Salmonella Enteritidis which comes directly from improperly handled eggs.  People that are infected will usually become ill 12-72 hours after consuming the bacteria.  Symptoms include diarrhea, fever, abdominal cramps and vomiting.  People with weakened immune systems are at a greater risk.

How does Salmonella affect a regular shell egg?

The bacteria is carried in the fecal matter of the hen.  It can be introduced to the egg shell when the hen is laying the egg.  The bacteria can enter through the porous shell of the egg.  The Salmonella Enteritidis can also be introduced to the egg before the shell is formed in the intestinal track of the hen.

Why are raw eggs in some countries not refrigerated?

The production process is different in the US from European countries, because of this the USDA requires producers to wash and sanitize the egg before selling.  This creates an environment where air and bacteria can more easily pass through the shell. Therefore, temperature control is required.

Do hard-boiled eggs need to be refrigerated? 

The CDC, USDA, Egg Board and FDA consumer guidelines all agree after an egg is hard-boiled the surface even more porous.  The recommendation is that eggs be refrigerated at 40°F or below for no more than 7 days.  The only source of information that is different is the FDA food code for retail food establishments.  Raw shell eggs can be stored at 45°F or below.  Water cooled eggs must be stored at 41°F or below and as stated in Annex 3 Public Health Reason / Administrative guidelines 3-501.14, air cooled eggs are no longer a TCS food.

“Hard-boiled eggs with shell intact may be cooled in ambient air and are not considered to be a time/temperature control for safety food after cooling. Hard-boiled eggs may be cooled in drinking water but are considered to be a time/temperature control for safety food after cooling because pathogens, which may be present in the water, may pass through the egg shell during cooling”

Should you eat eggs that have been used for hiding?

Yes and No.  As long as the egg has not been left at room temperature for more than 2 hours and the egg is washed off before placing back in refrigeration you should be safe.  However, it would be safer to use other items like plastic reusable eggs for hiding.

Additional Resources:

Baltimore City sewage and the Chesapeake Bay watershed

Chesapeake Bay BridgeRaw sewage is flowing into our streams and rivers and eventually to the Chesapeake Bay.  Where is this sewage coming from?  A key source is an antiquated storm water and sewage system for Baltimore City.  In 2002 the Maryland Department of the Environment (MDE) sued Baltimore City and an original consent degree to correct overflow of raw sewage was filed.  There was a 2016 deadline for Baltimore City to correct existing problems.  Although some progress was made, the deadline passed and there were still sever deficiencies.  A modified decree was approved October 6, 2017 that extended the time allowed to correct problems.  It is broken down in two Phases.  First phase must be completed by 2021 and second phase by 2030.

During the first phase 83% of the sanitary sewage overflows are to be corrected.  Baltimore City takes in over 250 million gallons of water a day and sometimes the system can not handle the load.  The happens especially during wet conditions.  To make matters worse, built into the system are intentional overflow structures.  They are called Sanitary Sewage Overflow (SSO)Structures.  They are “vents” for the system.   When the system was developed in the early 1900’s it was considered state of the art.  However, in today’s standards it is substandard way of handling excessive amounts of storm and sewage water.

Many of these SSO structures have been eliminated.  However, there are still 12 currently identified in the latest report1 from the city.

Here are some staggering numbers.  In the 4th quarter of 2018 over 9.7 million gallons of water containing sewage entered the watershed from sanitary sewer overflows.  However, the numbers from the SSO structures are alarming.  Over 56 Million gallons of water containing raw sewage entered the watershed! This typically occurs during heavy rains.

Discharged water can contain harmful pathogens that can cause illness. When humans come in contact with contaminated water they should thoroughly wash the area with soap and water.  When purchasing shellfish, make sure they are coming from an approved source. Pathogens like Norovirus or Hepatitis A can be in shellfish we consume. You can contract these viruses regardless if the shellfish is cooked. Always ask your seafood retailer to see the shell stock tags.  They show the area the shellfish were taken from.  If they do not have a shell stock tag – DO NOT PURCHASE.  It is required by health department law that the tag be with the product until it is sold.

Chemical toxins are a concern as well.  During heavy rains ground water that contains pesticides and other chemicals enters the storm water system then that water could be released from SSO structures at streams and rivers.  Pharmaceuticals that are flushed in toilets have been found in water from SSO.

Chemical toxins can accumulate in older fish and especially in bottom feeders affecting the health of humans.  The mustard in crabs caught in certain waters should be avoided.  View the Maryland Fish Consumption Advisory report located here:

Sewage and run off should concern everyone that enjoys the bay.  Whether it is for swimming, recreational or commercial fishing, or just enjoying the wonderful views and wildlife that it gives us.  Help support a healthy system by not flushing anything that could clog the pipes like feminine products or “flushable” wipes.  Do not put anything down as drain that could harm the system, including fats oils and grease (FOG), pharmaceuticals, old paint, chemicals or anything that you would not want in the bay.

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.