John A. Marcello: the Educational Foundation of the National Restaurant Association.
John Marcello's background experience combines both an industry and a regulatory food safety perspective. After 10 years assisting his father in the operation of a full-service restaurant, Mr. Marcello spent 15 years as a registered sanitarian, and later, as a training officer with the DuPage Co. Health Department in Illinois. Currently, as Manager of Technical Education for the Educational Foundation of the National Restaurant Association, Mr. Marcello assists industry officials and government agencies in the development and implementation of risk-related food safety educational programs.
He participated in the FDA/NOAA Retail Store and Foodservice Seafood pilot programs as well as several projects facilitating the HACCP-based approach to food safety in which he taught the Educational Foundation's SERVSAFE [R] "Managing a Food Safety System" workshop.
From his extensive background in the foodservice industry, Mr. Marcello offers an enlightening perspective on HACCP and the future of food safety programs.
HACCP is hot! It is being discussed coast to coast and represented as the future of food protection. What is HACCP?
This could be the most difficult question you ask me throughout this entire interview. I know it's a strange response to a simple request, but it reflects the underlying challenge facing food safety professionals. While there appears to be consensus on the seven principles that serve as the foundation for HACCP-based systems, there are many interpretations as to their practical application, especially for the foodservice industry.
If you met separately with 100 food safety professionals, you would likely obtain 100 different views on how the principles of HACCP should be applied, monitored, and verified within foodservice operations.
HACCP is as much a thought process as it is a food safety management system. The basic objectives of HACCP identify and monitor critical food safety procedures and practices within any type of food operation. It incorporates principles of total quality management and employee empowerment into the development of a food safety program. Front-line employees are active participants in the development and implementation of day-to-day food safety procedures and practices.
We know that you don't personally care for the term, "HACCP." Why?
In the early to mid-70s, an increasing number of food scientists looked toward HACCP as providing a "systems" approach to food protection. The approach had been used in engineering designs as early as the 1930s--long before Pillsbury adopted the system for NASA's food protection program.
From the very outset, HACCP has been established as a credible, reliable approach to food safety because it is science-based. Unfortunately, increasing emphasis and resources are being directed toward applying HACCP throughout the industry, rather than facilitating the thought process behind this "management system." Attempts to standardize the approach result in defining HACCP in terms of flow charts and recordkeeping rather than encouraging behavior that controls the factors that contribute to foodborne illness.
HACCP is an industry food safety management system. The HACCP system should be modified, when necessary, to make it compatible and practical with operational procedures but not compromise food safety.
What would you rather call the program?
I personally like the term "food safety management system." Development of a management system that monitors and verities critical operational food safety procedures is the ultimate objective of HACCP. Let's take a realistic look at HACCP and its role in a food protection system. HACCP will not solve all food safety problems. It is a process to be initiated--not a program to be implemented.
Health departments have budget constraints. Industry has cost pressures. If you would, please talk about the cost and benefit associated with HACCP. Will HACCP be more effective for less cost?
A cost/benefit analysis of HACCP must be based on the objective of a food safety program. Too often food program objectives are defined in broad-based, all-encompassing statements such as reduction in the reported cases of foodborne illness or reduction in costs associated with foodborne disease outbreaks. Cost and benefits associated with HACCP can not be accurately assessed in terms of these objectives. There are too many uncontrollable variables besides the implementation of a HACCP system that must be considered.
For industry, HACCP provides a systematic approach to setting "deliverable food safety objectives." You've heard me use this phrase a couple of times during this interview. HACCP is a continuous improvement process. It provides greater reliability and accountability for assessing that critical food safety procedures related to food product time temperature relationships, personal hygiene, and cross contamination prevention are being carried out by front-line employees. Industry is implementing this approach not only to ensure a greater degree of control over food safety, but also to establish a structure for evaluating a key component of business operations.
How would you make the environmental health professionals proponents of those who are regulated?
The HACCP system provides an excellent opportunity for the foodservice industry and the regulatory community to form an alliance that will increase our mutual effectiveness in reaching food safety objectives, reduce program costs, and improve our images. The components of a properly designed and executed HACCP system are entirely consistent with a collaborative approach to food safety.
My background has provided the opportunity to gain both a regulatory and industry perspective on food safety. Regulatory and industry professionals have mutual food safety objectives, but we haven't always done a very good job communicating or working cooperatively with each other. Poor communication leads to misunderstandings that tend to build in intensity. Eventually this leads to mistrust.
A regulatory food program must meet the needs of its customers which include the general public, foodservice operators, and field sanitarians responsible for delivering the product. Employee human resource skills are just as important to the delivery of an effective food program as is a solid knowledge of the technical aspects of food safety.
What are the obstacles to rallying environmental health professionals to HACCP and how are they being overcome?
I assume you want me to focus on the cost and benefits related to regulatory support for HACCP, so I'll base my comments on my 15 years of experience working for a local health department.
The FDA has released the "new" food code. The challenge of the new code for regulatory professionals is to implement their food programs based on the principles of HACCP. Many local health jurisdictions have incorporated objectives within their food programs that are based on risk assessment and focus on critical factors contributing to foodborne illness. Regulatory professionals are beginning to evaluate the effectiveness of their food programs on criteria based on reducing the number of critical factors documented during the inspection process. This emphasis on critical foodborne disease factors will support industry's efforts to develop management systems focused on food safety priorities.
What legitimate issues do opponents of HACCP have?
Opponents of HACCP have expressed concerns that the system is too labor intensive, mired in paperwork, and too cost-prohibitive to implement at the foodservice and retail levels. What should be minor concerns escalate in intensity the more one views HACCP as a program rather than a management process.
How do you respond to those issues?
A process approach breaks down the HACCP system into a series of tasks. As each task is achieved it is incorporated into standard operating procedures that become the building blocks in the development of a management system.
If time/temperature abuse, poor personal hygiene, and cross contamination are the leading causes of foodborne illness, then control of these practices in the process and preparation of foods should provide a baseline for developing priorities for a food safety management system.
What will it take or what will have to happen, in your opinion, before HACCP becomes more widely used than the traditional food establishment inspection?
Too often expectations are based on an "all or nothing" approach to the application of HACCP. The perception that the principles of HACCP can not be practiced without a fully developed system, flow charts, and appropriate recordkeeping is an obstacle to wider application.
The success of any food safety management system depends on clearly stated, simple "deliverable objectives." All aspects of an organization must be assessed including facilities and equipment and economic resources. Employee capabilities are an important management consideration, and food safety training for all their employees should be a first priority.
What is the most significant factor, in your opinion, impacting the use of HACCP in foodservice operations?
Diversity within the industry. Varieties in types of operations, menus, culture, language, food safety knowledge, and resources interact synergistically to create a complex environment that will totally frustrate a standardized approach to HACCP.
HACCP is an industry-driven management system and must be flexible enough to meet specific operational needs.
There are seasoned food protection professionals in the regulatory community who fear HACCP amounts to letting "the fox watch the henhouse." This is a real concern that can not be readily discounted. How do you respond to these considerations?
We would not be doing this interview if there wasn't some real concerns on how we communicate the effectiveness of the nation's food safety system to the press and the public. More regulatory inspections will not increase food safety. Food safety is an industry responsibility that extends well beyond the inspection process and requires the implementation of management systems. The regulatory role in this process is to monitor and verify that these food safety systems are operating effectively and to take appropriate action when they are not.
One key concept to HACCP involves empowering front-line employees. Yet according to your own statistics, front-line employees turnover rate is 200%. How can empowerment work?
Last September a survey of the American workforce appeared in the Chicago Tribune which showed that the most significant determinant in the acceptance of one's last job is having responsibility over their work. Without employee involvement in the HACCP process, there will be no commitment. Front-line employees must be given the knowledge, skills, and responsibility for monitoring and verifying food safety within an operation.
Management should provide employees with a clear understanding that food safety is an essential component for achieving organizational goals. Management can demonstrate their commitment to HACCP by providing an opportunity for all employees to receive food safety training, authorizing them to take corrective action when they see food safety criteria are not being met.
How does one hold such a transient workforce accountable, particularly with respect to prevention of a foodborne illness outbreak?
Responsibility for verifying and monitoring food safety should be written into employee job descriptions and be an important part of performance evaluations. Employees food safety responsibilities should be directly related to their work and based on a task analysis.
What do you feel represents our most serious food protection concerns for the future?
The ability of all the stakeholders in food safety to work together to achieve mutual objectives. The entire food system, from point of harvest to the consumer, must be viewed as an interrelated network. Food management systems, based on consistent application of the principles of HACCP, will need to be implemented at all levels of production. These management systems must be driven by food safety criteria, based on the best available science, and be compatible with the operational capabilities of all segments of the industry.
Will we be prepared to confront them?
We are moving from a food inspection system to a food management system. This will be an evolutionary process requiring national organizations committed to food safety to demonstrate leadership through developing alliances that will create an infrastructure for communication, decision-making, and education.
All food safety professionals are participating in a fascinating phenomena!
Thank you, Mr. Marcello, for your time and insight.
Thank you for the opportunity.
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|Publication:||Journal of Environmental Health|
|Date:||Jul 1, 1994|
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