The Real Food Safety Test Happens Before the Inspection

Food Safety Month Is an Opportunity to Evaluate Your Operating System.

What separates an organization that has a food safety program from one whose operating system actually produces food-safe behavior consistently?

Across the thousands of locations Steritech works with, the difference is rarely a single policy, training program, or assessment. Strong performance is supported by an operating system that reinforces food safety through everyday decisions, manager expectations, and established ways of working.

FDA research offers evidence of that connection. In a 2017–2018 study encompassing 851 data collections at fast-food and full-service restaurants, the agency found that food safety management systems were the strongest predictor of compliance with food safety practices. Fast-food restaurants with well-developed systems averaged 1.5 out-of-compliance items, compared with 4.5 among those with nonexistent systems. Among full-service restaurants, the averages were 2.2 and 5.3, respectively.¹

“The strongest organizations do not ‘turn on’ food safety when an assessment is coming,” says Kim McDonald, CP-FS, Director – QSR, Technical Services at Steritech. “Expectations are built into normal operating routines, manager coaching, and everyday decision-making. That consistency often separates sustained performance from short-term improvement.”

That makes sustainable food safety performance as much an operating question as a compliance one. Policies establish what should happen, training establishes what employees should know, and assessments provide an important measure of performance, but the operating system determines how reliably all three translate into everyday behavior.

For executive teams, Food Safety Month provides an opportunity to examine that system: not simply whether the right programs exist, but whether the organization has made food safety resilient enough to perform consistently every day.

Would Your Food Safety System Work Before the Inspection?

Third-party assessments provide an essential independent view of how locations are performing and where attention is needed. The opportunity is to make sure the systems operating between those assessments are reinforcing the same standards every day.

Employee wellness provides a useful example. A 2023 CDC analysis of 800 foodborne illness outbreaks associated with retail food establishments found that, among outbreaks where investigators identified a contributing factor, approximately 40% had at least one factor associated with food contamination by an ill or infectious worker.²

Chris Connor, Director of Technical Services at Steritech, points to personal hygiene as one area executives should examine closely during Food Safety Month.

“Personal hygiene, specifically employee wellness and frequent, proper and effective handwashing,” Connor says. “More foodborne illnesses are attributed to sick employees and/or poor hand hygiene than anything else.”

The operational question, then, is whether policies around employee wellness and handwashing are supported by the conditions necessary to put them into practice consistently. That can include reinforcing expectations through manager coaching, making handwashing accessible during high-volume periods, and creating employee illness policies and staffing practices that support employees staying home when they are sick.

CDC research illustrates why those conditions deserve attention. In studies of food-worker handwashing practices, workers encountered an average of nine activities per hour when handwashing was recommended but washed their hands only two to three times per hour. Workers were more likely to wash their hands when they were not busy, when their restaurant provided food safety training, and when more than one handwashing sink was available, including one in their line of sight.³

For multi-location operators, the real lesson is to examine whether training, staffing, management practices, and the operating environment make consistent execution achievable throughout a normal shift, not simply to reinforce the handwashing standard.

Is the System Working, or Are Your Best People Making It Work?

Strong managers are an asset to any food safety program. They can also make it harder to see where strong performance is being produced by an individual and not by the organization around them.

The FDA’s 2017–2018 restaurant research found that restaurants with a Certified Food Protection Manager present had fewer primary data items out of compliance than those without one. Restaurants where the certified manager was also the person in charge at the time of data collection had significantly better-developed food safety management systems than restaurants without a certified manager present or employed.¹ CDC research has also found that restaurants with certified kitchen managers were less likely to have foodborne illness outbreaks.⁴

For a multi-location organization, that evidence reinforces the importance of capable location leadership while raising another consideration: how well does the organization preserve strong execution when leadership changes?

As McDonald explains, organizations should evaluate “how well food safety is embedded into everyday operations, not just how well locations perform during an assessment. Are the same expectations reinforced through daily routines, manager coaching, training, and follow-up when an assessment is not taking place?”

One way to strengthen that continuity is to identify practices that are producing strong performance at the location level and determine whether they are embedded in training, procedures, and manager expectations across the organization. When critical knowledge resides primarily with experienced individuals, leadership transitions can expose gaps that were previously difficult to see.

The goal is to give strong managers an operating system that preserves what works, reinforces expectations consistently, and makes strong execution easier to sustain when people, staffing, or operating conditions change, keeping them just as essential to the process.

Use Your Data to Test the System

Assessment data offers insight that individual location scores alone cannot capture. Across a large network, it can help leaders determine whether their operating system is producing consistent results and where a different response may be needed.

“I would also add the importance of using data to understand the ‘why,’ not just the score,” McDonald says. “Looking across locations, repeat issues, trends by standard, and changes over time can help determine whether gaps relate to knowledge, execution, equipment, process, leadership, or something else.”

That diagnosis changes the response. A knowledge gap may point toward training or coaching. A recurring equipment issue may require investment or maintenance changes. Wide variation among comparable locations may warrant a closer look at management practices or how procedures are being executed locally.

FDA’s 2017–2018 restaurant study reinforces the value of examining the system behind individual results. Establishments with better-developed food safety management systems consistently had fewer foodborne illness risk factors out of compliance across both fast-food and full-service restaurants.¹

For executive teams, the opportunity is to use the information already coming from assessments, locations, and corrective actions to test assumptions about the business. Comparing results across locations, standards, and time periods can help determine where performance is sustainable, where additional support may be needed, and where an isolated finding may point to an organization-wide opportunity.

Food Safety Month provides a natural checkpoint for that work. Inspections and assessments remain essential tools for independently evaluating performance. The organizations best positioned to succeed are the ones using what they learn from those evaluations to strengthen what happens every day between them.

The real food safety test happens before the inspection because that is when the operating system has to work on its own.

Sources

1. U.S. Food and Drug Administration. FDA Report on the Occurrence of Foodborne Illness Risk Factors in Fast-Food and Full-Service Restaurants, 2017–2018. June 2023.
FDA report

2. Moritz, Erin D., et al. “Foodborne Illness Outbreaks at Retail Food Establishments — National Environmental Assessment Reporting System, 25 State and Local Health Departments, 2017–2019.” MMWR Surveillance Summaries, Vol. 72, No. 6. Centers for Disease Control and Prevention, June 2, 2023.
CDC outbreak analysis

3. Centers for Disease Control and Prevention. “Food Worker Handwashing in Restaurants.” March 18, 2024. Summary of four scientific studies conducted by the Environmental Health Specialists Network (EHS-Net).
CDC handwashing research

4. Centers for Disease Control and Prevention. “Outbreaks and Certified Managers.” April 25, 2024. Environmental Health Specialists Network (EHS-Net).
CDC certified manager research

 

 

*Data presented is gathered by Steritech through its OnBrand360®