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From: Food Quality & Safety magazine, October/November 2007

Ensure Food Safety Through Pre-employment Screening

Avoid having your employees become a liability in the workplace

by Jill Shuman

Ensuring safe food is an important public health priority for our nation. For years, regulatory and industry food safety programs have focused on reducing the incidence of foodborne illness. Despite these efforts, however, the 1996 report, “Reinventing Food Regulations: National Performance Review,” concluded that foodborne illness caused by harmful bacteria and other pathogenic microorganisms in meat, poultry, seafood, dairy products, and a host of other foods is a significant public health problem in the United States.

More than 11 years following the publication of that review, foodborne illness still remains a significant health problem. The food sector has experienced several types of significant adverse events over the past several years, including E. coli contamination of baby spinach in 2006 and a recall of products suspected to have caused botulism in 2007. The U.S. Centers for Disease Control and Prevention (CDC) estimate that 76 million people contract foodborne illnesses each year, both at home and while eating out. Each year, about 325,000 people are hospitalized—and an estimated 5,000 people die—because of food-acquired pathogens. With Americans now eating more than one-half of their meals outside of the home, foodborne illnesses and food safety have become very relevant concerns.

An area that has grown in importance following global terrorist attacks is intentional food contamination. It is possible for food products to be deliberately contaminated with a wide variety of chemical, biological, or radiological agents. But, despite the range of possible contaminating agents and the open vulnerability of many links in the food supply chain, there have been very few recorded cases of deliberate food contamination in the United States.

Contamination outbreaks are many times more likely to be caused by non-deliberate misuse of toxic cleaning or pest control agents, improper food storage, or poor personal hygiene practices. The industry would be grossly remiss, however, if it began to rely upon that historical safety, assuming it will continue into the future. In most cases, mortality (deaths) associated with unintentional contamination of the food supply is relatively low, but morbidity (illnesses) can be quite high. The selection of a more lethal agent in an intentional contamination could change high morbidity numbers to high mortality numbers.

While terrorism attacks on, and intentional contamination of, the food supply are grave concerns, the industry’s workforce itself may be its biggest threat. How can a food service operation ensure that its employees will not be a liability in the workplace?

Transient, Young Workforce

All sectors of the food industry invest both financial and human resources in preventing microbial pathogens, carcinogenic chemicals, and other harmful substances from entering their food products. While many invest in resources mandated through regulation, others choose an investment level that exceeds the regulated standard. Personnel are a key investment, representing a first-line defense against deliberate food tampering and unintentional contamination.

The post-harvest food industry accounts for 12% of the nation’s economic activity and employs between 10% and 18% of the American workforce. It consists of enormous subsectors, including processing, storage, transportation, retail, and food service—all of which have a broad geographic distribution. Statistics on just two of these subsectors serve to illustrate the magnitude of the sector as a whole.

The National Restaurant Association projects that the industry’s 925,000 domestic locations will achieve $537 billion in sales for 2007, serving over 70 billion “meal and snack occasions” for the year. The nation’s more than 34,000 supermarkets, 13,000 smaller food markets, 1,000 wholesale club stores, 13,000 convenience stores, and 28,000 gas station food outlets together generated $499.5 billion in 2006. Like the other segments that comprise the post-harvest food industry, these two subsector units also have broad geographic distribution.

The National Restaurant Association projects a workforce of 12.8 million restaurant workers in 2007. According to the U.S. Department of Labor’s Bureau of Labor Statistics, about a fourth of these employees are between the ages of 16 and 19 and work part time. Job openings are expected to be abundant through 2014 because many of these workers will transfer to other occupations or stop working altogether.

Benefits of Pre-screening

Because more businesses within the food industry are actively recruiting new hires to fill employment gaps, foreign workers for international assignments, and contingent workers for short-term projects, there is an increasing need for effective screening practices and policies, particularly for management level positions.

“Employers consistently face hiring risks, including applicant dishonesty, workplace violence, negligent hiring liability, turnover, theft, and fraud,” says Dean Suposs, general manager of ADP Screening and Selection Services, an integrated human resource service provider. “As evidenced by the increased use of pre-employment screening, employers are realizing the value in performing background checks as a way to help ensure a qualified, experienced workforce.”

Hiring managers can use these service providers to obtain background searches and can receive reports and track screening records via vendor Web interfaces. Providers are also offering quicker turnaround times and more accurate information, thanks to a combination of technological innovation and old-fashioned sleuthing.

Pre-screening can help flush out a troublesome employee before he or she is hired and can minimize potential problems within the kitchen or retail establishment. According to statistics provided by ADP for 2006, 50% of employment, education, and/or credential reference checks revealed a discrepancy between the information the applicant provided and that which the source reported. Seven percent of the information differences in reference verification checks returned with negative remarks from the source with regard to the applicant; 5% of applicants who went through the screening process turned up with a county, state, or federal criminal record.

Alternatives to Formal Pre-screening

Should all employees be pre-screened? According to some in the industry, pre-screening all food service employees is impractical and too expensive to consider—especially given the vast numbers hired. “We do not routinely screen employees, other than those being considered for our management program,” says Stephen Martinello, director of quality control and inspectional services for Legal Sea Foods, a Cambridge, Mass.-based fish restaurant and wholesaler. “Instead, we ask our hiring managers to ask applicants practical questions designed to elicit information about their past work history and their ability to communicate with coworkers.”

Jeff Nelken, a forensic food safety consultant, agrees with that approach. “I always like to ask prospective applicants a question that addresses their ability to resolve conflict, something like, ‘How would you handle a coworker who is routinely late and never completes an assigned task?’ The applicant’s response can provide a sense of whether this person prefers a confrontational or a collaborative approach with coworkers. In my experience, collaborative-type workers are less likely to sabotage the workplace, because they don’t let their frustration get the better of them.”

At a minimum, federal law requires food service establishment operators to verify the employment eligibility of all new hires in accordance with the requirements of the Immigration and Nationality Act by completing the INS Employment Eligibility Verification Form (INS Form I-9). In addition, the U.S. Food and Drug Administration (FDA) has issued a series of norms designed to safeguard the food supply in all subsectors throughout the country. Some of the FDA’s guidance relates to pre-employment and includes:

  • Examining the background of all staff (including seasonal, temporary, contract, and volunteer staff, whether hired directly or through a recruitment firm) as appropriate to their position;
  • Considering candidates’ access to sensitive areas of the facility and the degree to which they will be supervised; and
  • Obtaining other relevant factors (i.e., verifying work references, addresses, and phone numbers).

Such screening procedures should be applied equally to all staff, regardless of race, national origin, religion, and citizenship or immigration status.

Appearance Does Matter

June Summers, an independent human resources consultant in the Boston area, suggests that food service hiring managers consider the following when a formalized screening program is not indicated.

One, note the applicant’s appearance. A potential employee who arrives for an interview on time, appropriately dressed, and neatly groomed is more likely to take his or her job seriously. The application itself can provide an indication of the pride an individual takes in himself. An application with several omissions of information may mean the employee is not willing to give complete information, is not willing to accept directions, or cannot read. It may also be an indication of the applicant’s honesty.

Review the applicant’s work history and make a note of any gaps between jobs or overlaps in jobs. These are areas to follow up on during an interview. Determine why these gaps occurred. Inconsistencies should be noted and followed up on during an interview.

Consider the frequency with which the applicant has changed jobs and the reasons behind the changes. Follow up during an interview to determine why these moves occurred. The answers to these questions may provide insight into the person’s ability to follow directions, accept constructive feedback, get along with others, work with the public, and be a team player.

Review the application for any “red flags” or information that does not seem to make sense. Pay attention to how the applicant listens during the interview. “Someone who cuts off your every sentence or is staring off into space may have difficulty paying attention on the job,” warns Summers.

Education a Preventive Tool

Minimizing the occurrence of foodborne illness risk factors in a food service or retail food operation does not happen by accident. Hiring is the first of many steps in ensuring that an employee is performing competently and in a manner that does not compromise the safety of the food service operation.

Employee education is the key to reducing the risk of deliberate or non-intentional contamination. “Human resource managers should work alongside food service managers to provide a staffing and education plan that prevents any sabotage of the food supply—be it the result of toxic chemicals and pesticides, uninvited visitors, human or rodent—security breaches, unsafe water supplies, or personal injury,” says Summers.

In his role as director of quality control, Marinello takes this concept one step further. “It is management’s responsibility to create an environment where sanitation and food safety are an ingrained part of the workplace culture. These principles should be as important to the operation as the quality of the food or customer service.

“Management should be evaluated on the quality of the training programs they provide to all—and especially to new employees,” he adds. “Employees will take their cue from their managers. Programs can range from a simple reinforcement of hand washing techniques to more complex activities that simulate a natural disaster or large-scale bacterial outbreak.”

Food Defense Plans

To ensure the safety of the food they provide, many food processors, distributors, and retail outlets have begun to implement “food defense plans” that require the implementation of control measures designed to reduce the risk of contamination from a number of different sources. Briefly, these plans provide intensive employee training around issues related to personnel security, physical security and storage, transportation security, security of incoming products and supplies, safety of water and ice, and implementation of the facility’s crisis management plan.

Nelken believes that one potentially dangerous paradigm involving the identification, disposal, and storage of toxic materials must be changed. “Most food service workers and their managers are not familiar with the cleaning and disposal practices of their pest management and cleaning contractors, because the contractors often arrive in the middle of the night,” he says. “Rat poison looks very much like flour. If the pest removal company comes in from 2 to 3 a.m. and mistakenly leaves rat poison out and open, an unsuspecting cook or pantry worker can easily mistake it for flour. In another case, a cleaning contractor was using the pot washing sink to rinse out the toxic chemicals used to clean the steam kettle.”

Nelken recommends that management review all co ntracts provided by outside cleaning and pest removal vendors to learn exactly how and where toxic chemicals, cleaners, and residues are stored and disposed. This information should then be incorporated into an educational program that can be distributed to employees across all shifts, preferably in as many languages as is feasible, he adds.

Even in a bountiful and inherently safe food system, there are challenges to overcome. Hiring a workforce that is motivated, well trained, and proud of its accomplishments is a first step in ensuring the ongoing safety of the food produced, served, and sold throughout the United States.

Shuman is a freelance writer specializing in topics relating to food, nutrition, and food safety. Reach her at jill@jillshuman.com.

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