Active Managerial Control, Food Safety Culture and HACCP

Active Managerial Control and Public Health Interventions

Active managerial control is the purposeful, proactive incorporation of operating procedures into an establishment to control the primary risk factors for foodborne illness. Rather than waiting for a regulatory inspection to identify errors, managers anticipate hazards throughout the flow of food. The Centers for Disease Control and Prevention (CDC) identifies the five most common risk factors as purchasing food from unsafe sources, failing to cook food adequately, holding food at incorrect temperatures, using contaminated equipment, and practicing poor personal hygiene. A manager implements active managerial control by identifying operational risks, monitoring critical food handling tasks, taking immediate corrective actions, and continuously training staff.

The Food and Drug Administration (FDA) defines public health interventions as broad control measures designed to protect public health. These interventions target the CDC risk factors and include demonstration of knowledge, staff health controls, controlling hands as a vehicle of contamination, time-temperature parameters, and consumer advisories. Under the FDA Food Code, the person in charge can demonstrate food safety knowledge through compliance with the Code, correct answers to the regulator's questions, or accredited Food Protection Manager certification. The Code generally requires a certified manager to be the person in charge unless an exemption applies.

Staff health controls require managers to ensure employees are informed in a verifiable manner of their duty to report specified illness symptoms, diagnoses, and exposures, and to apply required restrictions or exclusions. A written reporting policy is a useful way to accomplish this, though it is not universally required. Controlling hands includes enforcing handwashing procedures and preventing bare-hand contact with ready-to-eat foods unless specific regulatory allowances are met. Time-temperature parameters require procedures for cooking, cooling, reheating, and holding time/temperature control for safety (TCS) foods. Finally, when serving raw or undercooked animal foods, managers must provide a written consumer advisory, both a disclosure and a reminder, on a menu, label, placard, or other effective written means.

State and local regulatory authorities may enforce different editions of the FDA Food Code. These local jurisdictions can establish varying rules for manager certification, food handler training, and bare-hand contact with ready-to-eat foods. For this reason, managers must never assume one jurisdiction's regulations apply universally.