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Do You Have Active Managerial Control?

For many years, the food establishment inspection process has centered on the inspector citing violations and the operator correcting the violations while the inspector was still in the establishment. Repeat violations are handled through follow-up inspections and other enforcement actions. This type of inspection and enforcement system emphasizes reaction to the inspector rather than prevention of the violation. Operators may immediately correct a violation, but often do not put the necessary preventive procedures in place to keep the violation from happening again. This preventive food safety management system is called “active managerial control” (AMC). Through a continuous system of monitoring and verification, AMC focuses on preventing a food safety risk rather than reacting when an inspector points out the uncontrolled food safety risk.

Inspections today are designed to assess the degree of active managerial control that a person in charge (PIC) has over the recognized foodborne illness risk factors: 1) Unsafe Food Source; 2) Time and Temperature Abuse; 3) Inadequate Cook Temperature; 4) Contaminated Equipment; and 5) Poor Personal Hygiene.

The four key components of Active Managerial Control are:

  1. Policy Statements (preferably written). Policy statements set expectation for employees. The policy for proper cold holding, for example, might be that all Temperature Controlled for Safety (TCS) foods will be kept refrigerated below 41°F; or the policy might be that all refrigerators will have ambient air temperatures of 41°F or less.
  2. Training. All staff should be trained on the policies. All food preparation staff should be trained that TCS food should be 41°F or less and refrigerators must keep 41°F or less, if part of the cold holding policy. The person in charge should not be the only person who is aware of and responsible for following the policies.
  3. Monitoring (a method for verifying that employees follow specific policies). A temperature log for checking temperatures of TCS foods throughout the day is one means of monitoring a cold holding policy, for example.
  4. Corrective Action (what to do if the verification shows that a policy isn’t met). The corrective action should be part of the policy statement. For example, does the cold holding policy tell staff what to do if the TCS food is out of temperature on the temperature log?

In your food establishment, what degree of active managerial control do you have over the foodborne illness risk factors? Each of the four AMC components above should be applied to each of the foodborne illness risk factors. Some risk factors require many levels of control; some just a few. Annex 4 of the 2009 FDA Model Food Code explains in more detail other aspects of active managerial control.

Active managerial control may be a new approach to food safety in your operation. Going forward, you will hear the term “active managerial control” used more frequently by health department inspection staff. Inspectors may ask you to explain your active managerial control as it relates to cold holding of TCS foods or a safe food source, for example. With active managerial control in place, you become the inspector on a daily basis and ensure that you are serving safe, quality food to your customers.

Read more in the full edition of the October 2014 newsletter. | Español PDF icon

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