A Systems-Based Food Safety Evaluation: An Experimental Approach
Higgins, Charles L., Hartfield, Barry S., Journal of Environmental Health
Traditionally, government food safety programs have used, as the basis for their work, an inspectional or code-based approach. This approach involves comparing a list of "dos and don'ts" to what is actually observed in any particular food service establishment. Many of these lists are derived from the various versions of the food safety model ordinances produced by the U.S. Public Health Service, starting with the 1935 version, "An Ordinance Regulating Food and Drink Establishments." Once inspectional observations are recorded, they become alleged violations of the applicable regulation. Educational (informative) and enforcement (coercive) methods are used in an attempt to eliminate or mitigate the list of violations.
Anecdotal evidence of dissatisfaction with this traditional approach is to be found in the hundreds of presentations, seminars, courses, and meetings that over the last 20 or more years have discussed the drawbacks of inspection and possible alternatives. A series of articles by Dr. Frank Bryan, formerly of the Centers for Disease Control (CDC), discussed the need for an inspection process that better identifies and focuses on the factors that cause foodborne outbreaks (Bryan, 1978). Dr. Bryan also wrote about a new concept, the hazard analysis and critical control point (HACCP) approach, which was developed for the space program by the Pillsbury Company and the U.S. Military's Natick Laboratories (Bryan, 1981).
In recent years, many agencies and jurisdictions, including the Food and Drug Administration (FDA) and the Food Safety and Inspection Service (FSIS) of the U.S. Department of Agriculture (USDA), have begun trying to apply HACCP principles to food safety inspections. The HACCP concept involves charting out the flow of foods in any operation, identifying the hazards associated with those flows, and looking for controls for certain critical steps. This approach, however, designed as it originally was for large processors, has proven difficult to use and sustain, both by small retail operations and by regulators.
The National Park Service (NPS) Public Health Program (PHP) is charged with acting as a consultant to the nation's parks system in matters of public health. PHP has used the same traditional approaches as other food safety programs, and at the core of this effort is the FDA model food code (FDA, 2001). Over the last two years, PHP has been exploring a concept that attempts to combine the conceptual aspects both of the HACCP methodology and of an older idea, General Systems Theory, first proposed in the 1940s by biologist Ludwig von Bertalanffy (Bertalanffy, 1968).
Bertalanffy's work stated that "the whole is more than the sum of its parts." Systems theory emphasizes the need to understand the underlying interactions of all of the forces that make up any system. He further stated that all systems have what are called natural "set points," essentially outcomes, predetermined by the nature of these underlying forces. Making changes within any complex system can prove difficult to impossible unless a great deal is known about these underlying forces. Furthermore--and perhaps just as important to food programs--unless the deeper systems factors are dealt with or changed, any system tends to "reset" to its original set point. Food inspectors who have cited violations often see them corrected only to find a few months later that the same problem is back again. While there is no known specific research on this issue, it is possible that this anecdotal "violation return" could result from a lack of dealing with underlying causes, and that the system gradually resets.
This paper proposes that food service operations can be viewed as systems, with inputs, process, outputs, and feedback. As systems, they should have the general characteristics of any system, including complex underlying factors that drive how things work and why, and natural set points (outcomes) determined by these systems forces (Figure 1). …