New Food Rules Frequently Asked Questions
Updated: September 24, 2008
Category: Standardization Online Courses
Q: What online courses are required for standardization?
A: For the first standardization begun after September, 2005, two courses are required before the standardization training is considered completed: Public Health Principles (course number FDA 36) and Microbiology (course numbers MIC 01 through MIC 16 ).
For the next standardization, which can be up to three years later, the additional two courses are HACCP (course numbers FDA 16 through FDA 18) and Epidemiology (course numbers FI01 through FI06).
Q: What if I go ahead and finish all four courses now? Will I have to repeat two of them when I get re-standardized three years from now?
A: No, as long as you have documentation that the courses have been completed. There is no expiration date on the courses. However, the recommendation from the Central Office is to take all the online courses as soon as possible since you will already have your login name and password established and be familiar with how the program works.
Q: What if I complete the inspections with the Survey Officer but don’t complete the online courses?
A: The standardization training is not complete and a certificate denoting completion will not be issued.
Q: Where are the online courses found?
A: At www.fda.gov/ora/training/orau/state/intro.htm. These are web-based courses for “ORA U” which is the Office of Regulatory Affairs University for FDA. There’s a course for Retail Food. We fall under the link for State, Local, and Tribal Regulators.
Q: I get a message saying Shockwave Flash Player is required. What do I do?
A: Shockwave is a program commonly used for web animation; the Shockwave Flash Player is a free application that runs the animation. The web pages in the ORA-U courses use Shockwave animation frequently. Some health department computers do not have Shockwave Flash Player preinstalled. It must be installed by someone with administrative rights for your health department computer. You can ask your county Computer Systems Center contact to call in a work order to CSC to install Shockwave Flash Player.
Q: There are six courses listed. Am I supposed to take all six?
A: The only ones required for the standardization training are the four listed in Question 1 above. The other two courses are Communication Skills (course number EHS 02) and Prevailing Statues, Regulations, and Ordinances (course numbers FDA 35, FDA 38, and FDA 39). These courses will provide good information for any Public Health Environmentalist and are recommended to be completed for general training purposes, but are not required for the retail food standardization program.
Category: Bonus points and accredited programs
Q: Is the health department's 12 hour food sanitation course sufficient to count for the bonus points?
A: No. The only allowable courses (or more exactly, the tests conducted after attending the course) are those for an "accredited program." The only accredited programs are ServSafe, Thompson Prometric (old Experior), and National Registry for Food Safety Professionals.
Q: Why isn't the health department's own training program recognized as an "accredited program"?
A: Because the test to verify the trainee's knowledge level must itself be certified as valid and non-biased. This is done by the nationally recognized testing agency ANSI. This is an expensive process. Keep in mind that it is actually the test that must be recognized by ANSI. A trainee could attend a health department course and then take one of the accredited program tests and as long as they pass, would be acceptable for the bonus points provision. But the course and test are normally sold as a package, there wouldn't be any monetary savings to become accredited this way. In fact, it would probably cost more.
Q: How do we find out which tests or courses are "accredited"?
A: ANSI Accreditation Services Website.
Q: How does a course or test become accredited?
A: Apply to ANSI.
Q: When will food manager training become mandatory statewide?
A: January 01, 2010.
Category: Alabama Grease Law
Q: Referencing the Alabama "Grease Law", we have some people wanting to collect waste grease from restaurants to use in their own biodiesel manufacturing operations. Is collecting the grease for biodiesel manufacturing an approved disposal method, as required by the law?
A: No, as the proposal is usually presented to us, but it possibly could be approved. The issue is that the law requires all waste grease to be hauled by an approved hauler. Unless the person wanting to collect the grease has a waste grease haulers license, permit, or is registered, they cannot legally collect and haul the grease even if the intent is to use it personally to manufacture biodiesel.
Q: Which agency issues the waste grease hauler's permit?
A: The contact for the grease hauler and renderer registration is the Alabama Department of Agriculture and Industries (ADAI), Meat Division: Dr. Robert Barlow is in Montgomery at 1445 Federal Drive (office phone (334) 240-7210).
Q: So if someone wants to collect grease from a restaurant to make biodiesel and needs to be licensed/permitted to haul the grease, should I call the ADAI for the person?
A: No. ADPH will give the contact information from the question above, any contacts from that point is up to the interested parties. When the prospective grease hauler has documentation that he/she has been approved by the ADAI, a copy of the documentation should be placed in the food establishment’s file at the county health department. Until this documentation is in our files, the grease cannot be legally collected by this person. The food establishment allowing them to do so will jeopardize the establishment’s Food Permit under the law.
Q: How do I get a copy of the Grease Law?
A: It’s part of the Code of Alabama 1975, located at sections 22-27-70 through 22-27-73 and updated as sections 22-27-90 through 22-27-94.
Category: Food Rules, 2005 Food Code
Q: What establishments have been issued an approved alternative for bare hand contact with ready-to-eat food?
A: To date, only Burger King. Burger King is the only chain that has requested to be considered for an approved alternative and submitted a written plan to address food safety concerns.
Q: Referencing the chlorine level/water temp/water pH chart for chlorine sanitization on page 127, should we require the establishments to test for water pH the same as the test for chlorine concentration?
A: Routinely, no.
The chart gives the water pH to correspond to a minimum water temperature and minimum chlorine level effectiveness. That is, if someone wants to sanitize in 55F water, they would have to use a minimum chlorine level of 100 ppm regardless of the water pH. The only chlorine/temp combination where this is an issue is if someone is using 50 ppm chlorine minimum in high (>8.0) pH water. In that case, the minimum water temperature must be 100F. Otherwise, 75F is sufficient.
Since most municipalities adjust for the water pH, this is probably a non-issue. It's probably unnecessary, but if we want to verify the water pH, we can contact the municipal water office. They should have pH testing for the water; their test would apply to anyone on the system.
For establishments on a private water source, we can do a one-time pH test for verification if we want to. If the usual minimum chlorine sanitization level is set at 100ppm, or the sanitization rinse water temp is 100F +, then it won't matter.
Q: Since the inspection report Item 15 makes it a critical item violation to use dirty non-cooking food contact equipment, and Item 17 makes it a non-critical violation to use dirty cooking equipment, how do we mark equipment that might sometimes be heated and sometimes not? For example, a stainless steel pan on a hot bar at 140F today might have been used on the cold salad bar as non-heated equipment yesterday - is today's observation that the heated pan is dirty a critical or non-critical violation?
A: In this scenario, it's a critical violation. The pan is used for storage and display of food, not cooking. The only provision for the observation of dirty food contact equipment being non-critical is when the equipment is designed for, and is used for, the actual cooking process.
Q: Is the inside of a reach-in cooler being dirty now a critical item because it's considered by definition a food contact surface?
A: No. This is a change in definition/considerations from the old rules. The inside of a reach-in cooler used for storing only packaged food is a non-food contact surface.
Q: Is the inside of an ice machine being dirty now a critical item because it's a food contact surface?
A: Yes. The inside of an ice machine is in direct contact with an unpackaged ready-to-eat food (ice).
Q: What is considered a “sufficient capacity” for a ventilation system?
A: Basically, one that will do the required job of removing greasy fumes without causing contamination of food, food contact surfaces, equipment, or utensils. For standard commercial establishments, an air balance test can be required if the capacity is questionable. We sometimes run into small establishments using residential style ranges, in particular day care centers. For those situations, when the only cooking is done on a residential style range, the recommended review should consist of:
State or local fire marshal office (as applicable) shall approve the use of the type of hood. If the fire marshal approves the use of a residential hood for a residential range, the Health Dept. may allow use of the hood provided:
a. Written documentation is provided of the fire marshal’s inspection and approval.
b. Make-up air intake and exhaust vents are required. These require operable fans in the ventilation system. There shall be no food or equipment contamination issues.
c. The hood must be easily cleanable, including no open seams.
d. Intake and exhaust vents must have removable filters which are durable and cleanable.
e. The hood and ventilation equipment shall be designed to prevent grease or condensation from draining or dripping onto food, equipment or food-related items on the range.
f. The hood shall be installed in a manner to prevent any difficult to clean places where grease, dust or dirt may accumulate.
g. Exhaust vents should be vented to the outside of the building rather than just into the loft or attic.