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at Point-of-Service: Affect
=
sc Bid
Programs on Foodborne
IIIness Outcomes
ADVANCEMENT OF THE SCIENCE
Disclosing Inspection Results
of Characteristics of Food
Establishment Inspection
A b St ra ct The significant proportion of foodborne illnesses
attributed to restaurants highlights the importance of food establishment
inspections. The objectives of this cross-sectional study were to characterize
local inspection programs and evaluate the effects of programmatic
characteristics, such as active public disclosure of inspection results, on
select operational and foodborne illness outcomes. Between January 7
and April 6, 2020, an online 36-question survey was administered to 790
government-run food establishment inspection programs at state and
local levels. Of 149 survey respondents, 127 (85%) represented local food
establishment inspection agencies. Agencies that disclosed at the point-of-
service reported fewer mean numbers of re-inspections by 15%, foodborne
illness complaints by 38%, outbreaks by 55% (p = .03), and Salmonella
cases by 12% than agencies that disclosed online only. Agencies that used
some type of grading method for inspection results reported fewer mean
numbers of re-inspections by 37%, complaints by 22%, outbreaks by 61%,
and Salmonella cases by 25% than agencies that did not grade inspections.
Programmatic characteristics appear to be associated with foodborne illness
outcomes. These results warrant future research to improve the effectiveness
of food establishment inspection programs.
Introduction
Approximately 51% of each consumer dollar
dedicated to food spending in 2019 was spent
in the food service industry, specifically in
restaurants, compared with just 25% in 1955
(National Restaurant Association, 2020).
Coincidentally, there is growing evidence that
restaurants are an important source of spo-
radic and outbreak-associated foodborne dis-
8 Volume 83 ¢ Number 6
ease in the U.S. Jones & Angulo, 2006). In
2017, there were 841 foodborne illness out-
breaks resulting in 14,481 illnesses, 827 hos-
pitalizations, 20 deaths, and 14 food recalls
in the U.S., including Puerto Rico and Wash-
ington, DC (Centers for Disease Control and
Prevention [CDC], 2019).
Among the illnesses and outbreaks for
which a single location was identified, 44%
Thuy N. Kim, MPH, CFOI
Melanie J. Firestone, MPH, PhD
University of Minnesota
School of Public Health
Natasha DeJarnett, MPH, PhD
Laura Wildey, CP-FS
Jesse C. Bliss, MPH
David T. Dyjack, DrPH, CIH
National Environmental
Health Association
Jennifer Edwards, PhD
National Network of
Public Health Institutes
Harlan Stueven, MD
Dining Safety Alliance
Craig W. Hedberg, PhD
University of Minnesota
School of Public Health
and 64%, respectively, were attributed to
foods prepared in a restaurant setting (CDC,
2019). The rise in expenditure on foods
eaten away from the home and the sig-
nificant proportion of foodborne illnesses
attributed to restaurants have highlighted
the importance of food establishment
inspections, as they could flag the existence
of food safety hazards and mitigate their
public health impact.
Public disclosure of inspection results
from food establishments enables consum-
ers to make informed decisions about where
they choose to eat (Fung et al., 2007). Con-
sumer priority of hygienic food preparation
practices, in turn, incentivizes food estab-
lishments to improve hygiene practices—a
proxy for better sanitary conditions—within
their facility. Improved and maintained san-
itary conditions, theoretically, lead to fewer
foodborne illnesses. From a programmatic
standpoint, however, disclosure of inspec-
tion results can create more work for the
environmental health workforce tasked
with putting the information into a present-
able format. In a survey of the environmen-
tal health workforce, 76% of workers sur-
veyed indicated working in food safety and
protection programs; however, 17% of all
respondents performed public health duties
outside of environmental health, and of
those, 37% spent >50% of their time work-
ing in nonenvironmental health programs
(Gerding et al., 2019).
The value of actively disclosing inspec-
tion results to the public has been dem-
Vr... 1
Summary Statistics for Local Agency Respondents (n = 124)
a aaa Sa
Active disclosure 82 (66)
Active disclosure methods
Online 75 (91)
Point-of-service 24 (29)
Other 4 (5)
No active disclosure 42 (27)
Grading methods
Numerical score 53 (43)
Letter grade 20 (16)
Other 34 (27)
No grading 30 (24)
Inspection violation schemes (n =75)
P-PF-C 24 (32)
C/NC 21 (28)
RF-GRP* 23 (31)
P-PF-C 10 (43)
C/NC 4 (17)
Major/minor 3 (13)
Other 7 (9)
P-PF-C = Priority-Priority Foundations-Core; C/NC = Critical/Noncritical; RF-GRP = Risk Factor-Good Retail Practices.
*Of the 23 agencies that indicated using RF-GRP, 6 agencies used RF-GRP only. The other 17 agencies used RF-GRP in
combination with the other schemes listed below.
onstrated in several settings throughout
the U.S. The debate about the best mode
to convey inspection results to the public,
however, is still ongoing. A study of people
at the Minnesota State Fair found increased
interest in public access to inspection
results. Furthermore, fairgoers expressed
interest in disclosure methods of posting
online and at the point-of-service, that is, at
a food establishment (Firestone & Hedberg,
2020). For local inspection agencies that
disclose inspection results, the most com-
mon method is through online disclosure
only, typically accessed via departmental
websites. Drawbacks of this method include
difficulty in navigating these websites and
lengthy reports that are confusing to the
general public. Moreover, this method might
not be accessible to those who are most vul-
nerable to foodborne illness, such as older
adults (Fleetwood, 2019).
Disclosure at the point-of-service elimi-
nates a barrier to using inspection data
in the decision-making process, as this
approach does not require a person to have
online access to check a website for inspec-
tion results. With the introduction of pub-
lic disclosure by means of a color-coded
inspection sticker placed at or near restau-
rant entrances, Columbus Public Health
(Ohio), saw inspection scores improve by
1.14 points out of a possible 100 points
(Choi & Scharff, 2017). In New York City,
New York, implementation of public disclo-
sure at the point-of-service in the form of
letter grades was associated with improve-
ments in sanitary conditions (Wong et al.,
2015) and a 5.3% decrease in Salmonella
cases per year (Firestone & Hedberg, 2018).
Furthermore, in Los Angeles County, Cali-
fornia, public disclosure of letter grades at
the establishment led to a 13% decline in
hospitalizations due to foodborne illness
(Simon et al., 2005).
While the act of disclosure is important,
what information is disclosed and how the
public interprets it is also important. Famil-
iarity with the symbols used to represent
inspection results lends to easier interpreta-
tion by the general public. Grading practices
can include letter grading and/or numerical
grading, similar to most grading methods in
a school system (e.g., A, B, C grades or 100%,
90%, 80%) or other ordinal methods (e.g.,
stoplight colors, emoticons).
During inspections, a labeling system is
used to classify different types of violations
and convey severity of the violations. These
violation schemes often correlate with the
version of the Food and Drug Administration
(FDA) Food Code an agency has adopted and
can be used in combination at the agency's
discretion. For example, in Food Code ver-
sions before 2009, violations that were more
likely “to contribute to food contamination,
illness, or environmental health hazard” were
classified as critical. In 2009, FDA revised
the Food Code to distinguish critical items
as priority if the item includes a quantifiable
measure to show control (e.g., cooking), or
priority foundation if the item requires the
purposeful incorporation of specific actions
(e.g., training) (Food and Drug Administra-
tion [FDA], 2015). The categorization of risk
factor or good retail practices corresponds to
the organization of the FDA Food Establish-
ment Inspection Report.
Current inspection practices and methods
of disclosure vary widely across jurisdictions
in the U.S. and present unique challenges to
evaluating program effectiveness. The objec-
tives of this cross-sectional study were to 1)
characterize local inspection programs and
2) evaluate the effects of programmatic char-
acteristics, such as active public disclosure
methods, on select operational and food-
borne illness outcomes.
Methods
An online 36-question survey was adminis-
tered via Qualtrics to 790 government-run
food establishment inspection programs at
state, county, city, district, and territorial lev-
els. Recipients were chosen based on avail-
ability of program inspection data online or
participation in FDAs Voluntary National
Retail Food Regulatory Program Standards
January/February 2021 e Journal of Environmental Health 9
ADVANCEMENT OF THE SCIENCE
TABLE 2
Mean, Standard Deviation, and Median Estimates for Outcomes by Disclosure Methods, Grading Methods,
and Inspection Violation Schemes
Average # of Re-
Average # of
Average # of
Average # of Salmonella
Inspections/Establishment/ Complaints/1,000 Outbreaks/1,000 Cases/100,000 Population
Year Establishments/Year Establishments/Year Served/Year
(m= 109) (nm = 100) (n= 101) (n= 48)
Mean (SD) Median Mean (SD) Median Mean (SD) Median Mean (SD) Median
Disclosure methods
Online 0.40 (0.55) 0.24 44.2 (49.6) 27.3 1.7 (2.4) 0.84 14.4 (7.2) 14.0
Point-of-service 0.35 (0.46) 0.17 30.3 (45.3) 22.2 0.9 (1.4) 0.25 12.9 (6.5) 14.0
None 0.53 (0.46) 0.50 31.3 (36.0) 18.5 7.0 (24) 0.00 9.9 (9.9) 6.7
Other* 0.36 (0.43) 0.17 74.5 (86.4) 42.7 3.7 (4.7) 2.39 - -
Grading methods
Numerical score 0.32 (0.37) 0.17 40.6 (54.6) 22.2 3.0 (10.7) 0.35 12.4 (6.8) 13.6
Letter grade 0.31 (0.48) 0.13 34.9 (41.7) 24.6 1.3 (1.6) 0.71 13.0 (7.0) 14.2
None 0.59 (0.64) 0.50 49.1 (49.2) 29.2 6.5 (25.0) 0.82 15.9 (12.2) 13.1
Other 0.46 (0.57) 0.27 36.4 (35.0) 27.6 1.9 (2.7) 0.95 12.0 (6.2) 12.7
Inspection violation schemes
P-PF-C 0.39 (0.45) 0.18 47.2 (53.3) 29.0 1.5 (1.7) 0.95 15.7 (7.4) 16.4
C/NC 0.38 (0.49) 0.25 48.7 (45.2) 42.7 1.1 (1.4) 0.85 12.7 (8.8) 13.1
RF-GRP 0.32 (0.39) 0.17 38.1 (51.1) 22.8 2.4 (2.2) 1.97 16.8 (8.1) eal
Other 0.29 (0.37) 0.19 57.9 (73.9)* 11.8% 0.77 (0.78)* 0.62* 10.9 (7.8)* 11.7*
P-PF-C = Priority-Priority Foundations-Core; C/NC = Critical/Noncritical; RF-GRP = Risk Factor-Good Retail Practices.
*Contains data from <5 respondents.
(Retail Program Standards). The Retail Pro-
gram Standards provide recommendations
aimed at facilitating inspections that are more
effective and implementing foodborne illness
prevention strategies. Enrollees in this pro-
gram intend to actively use these standards as
a tool to assess and improve their regulatory
programs (FDA, 2019).
We administered the survey in two rounds.
The first round consisted of 151 recipients
whose inspection data were publicly available
online, resulting in a 40% response rate (n =
60 respondents). The second round included
639 recipients who participated in the Retail
Program Standards, resulting in a response
rate of 19% (n = 122 respondents). Via the
survey, we obtained information on general
program characteristics such as size of popu-
lation served; number of routine inspections
conducted; number of licensed establish-
ments within the inspection jurisdiction; and
10
Volume 83 ¢ Number 6
operational characteristics such as public dis-
closure method, grading method, and FDA
Food Code version in use.
The time period for the survey was chosen to
match the availability of inspection data from
the agencies. Three geographically diverse
local inspection agencies piloted the survey
to ensure appropriateness and relevancy of
questions and answer choices. The data col-
lection period was January 7—April 6, 2020.
We paused data collection in April due to the
COVID-19 pandemic response taking prec-
edent at state and local health departments.
We categorized inspection agencies into
two main types, state and local. A state
agency was defined as an inspection program
that oversees the inspection of food establish-
ments at the state government level, includ-
ing U.S. territories and Washington, DC. A
local agency differs in that the oversight of
the inspection programs is at the county, city,
city-county, or district government level.
One survey respondent represented a univer-
sity and thus was excluded from this analy-
sis, as there could be significant policy dif-
ferences between government agencies and
universities. Local agencies were the primary
focus of this analysis, as most food establish-
ment inspection programs are operated at the
local government level.
Four operational and foodborne illness out-
comes were calculated as rates from a combi-
nation of variables obtained from the survey
and expressed as an average number of:
1. Re-inspections/establishment/year (calcu-
lated as the quotient of average number
of re-inspections and number of licensed
food establishments within the jurisdiction
of the agency).
2. Foodborne illness complaints/1,000 licensed
food establishments/year (2016-2018; most
recent years included in data set).
TABLE 3
Mean, Standard Deviation, and Median Estimates for Outcomes by Point-of-Service (POS) Disclosure
Versus Online (no POS) Disclosure
Average # of Re-Inspections/
Establishment/Year
(n= 71)
Average # of
Complaints/1,000
Establishments/Year
(n = 62)
Average # of
Outbreaks/1,000
Establishments/Year
(n= 63)
Average # of Salmonella
Cases/100,000 Population
Served/Year
(n= 31)
p-value 65 .16 44
POS disclosure
Mean (SD) 0.35 (0.46) 30.3 (45.3) 0.92 (1.4) 11.7 (6.6)
Median 0.17 22.17 0.25 12.5
Online (no POS) disclosure
Mean (SD) 0.41 (0.57) 48.6 (50.0) 2.04 (2.69) 13.3 (8.5)
Median 0.24 29.0 0.95 12.7
3. Foodborne outbreaks/1,000 licensed food
establishments/year (2016-2018).
4. Salmonella cases reported/100,000 popula-
tion served/year (2016-2018).
In addition to the survey data, we were
able to obtain some Salmonella case counts
using departmental websites for jurisdictions
that reported these data online.
For the purposes of this study, active dis-
closure was defined as agencies that volun-
tarily and preemptively publicize some or
all inspection data to the public. Inspection
violation scheme was not included in the
survey, but was determined by searching
online for inspection data from the respond-
ing agencies.
Predictors were classified into three
categories:
1. Disclosure method consisting of online,
point-of-service, no disclosure, and other
disclosure methods.
2. Grading method consisting of numerical
score, letter grade, no grading, and other
grading methods.
3. Inspection violation scheme used for rou-
tine inspections consisting of subcatego-
ries Priority-Priority Foundations-Core;
Critical/Noncritical; Risk Factor-Good
Retail Practices; and other schemes.
The Risk Factor-Good Retail Practices sub-
category relates to the inspection report form
and therefore can be used in combination
with other violation schemes. The mean and
median values of outcomes for each combi-
nation of schemes were assessed in addition
to the nonmutually exclusive scheme catego-
ries previously stated. One respondent used
a combination of three schemes: Risk Factor-
Good Retail Practices, Critical/Noncritical,
and Red/Blue. Of note, Red/Blue is similar
and is sometimes used in reference to Criti-
cal/Noncritical; therefore, this respondent's
jurisdiction was included in the Risk Factor-
Good Retail Practices and Critical/Noncriti-
cal scheme combination.
Mean and median values were calculated
to identify trends in outcomes based on each
subcategory. The means were compared
using t-tests; p-values were reported assum-
ing unequal variance. The analysis was con-
ducted using SAS 9.4m6 University Edition.
Linear regression was used to determine
associations between the outcome variables
reported by the local responding agencies.
The level of statistical significance was set at
o = .05.
Results
Of the 149 survey respondents, 127 (85%)
represented a local food establishment
inspection agency. More than one half of
agencies (66%) actively disclosed inspection
scores to the public and most (91%) did so
by posting online; only some (30%) posted
at the point-of-service. Approximately 43%
of the agencies used numerical scores as
a grading method, 24% used no grading
method, and 16% used letter grades (Table
1). Frequently used inspection violation
schemes included Priority-Priority Foun-
dations-Core (32%) and Critical/Noncriti-
cal (28%). The scheme Risk Factor-Good
Retail Practices (31%) was used in combina-
tion with other violation schemes. Of the 23
agencies that used Risk Factor-Good Retail
Practices with another scheme, 43% used
Priority-Priority Foundations-Core, 22%
used Critical/Noncritical, and 13% used
Major/Minor schemes. Violation schemes
for 53 respondents could not be determined
using online searching.
Agencies disclosing at the point-of-service
had lower mean values for all outcome mea-
sures than did agencies disclosing online
(Table 2). Of the 24 agencies disclosing
inspection results at the point-of-service,
however, 21 (88%) also disclosed inspection
results online (Table 1). Due to this overlap,
we made further comparisons of agencies dis-
closing at the point-of-service and agencies
disclosing online only (Table 3). Agencies
that disclosed inspection results at the point-
of-service reported fewer mean numbers of
re-inspections by 15%, complaints by 38%,
outbreaks by 55% (p = .03), and Salmonella
cases by 12% than did agencies that disclosed
online only.
Agencies that used some type of grading
method for inspection results reported fewer
mean numbers of re-inspections by 37%,
complaints by 22%, outbreaks by 61%, and
Salmonella cases by 25% than did agencies
that did not grade inspection results. Agen-
cies using letter grades had lower mean values
for complaints by 14% and outbreaks by 43%
January/February 2021 e Journal of Environmental Health 11
ADVANCEMENT OF THE SCIENCE
TABLE 4
Linear Regression Comparisons of Outcomes
Average # of Average # of
Complaints/1,000
Average # of
Outbreaks/1,000
Average # of Salmonella
Cases/100,000 Population
Re-Inspections/
Establishment/Year Establishments/Year Establishments/Year Served/Year
Parameter | p-Value | # Parameter | p-Value| # Parameter | p-Value| # Parameter | p-Value| #
Estimate Estimate Estimate Estimate
(SE) (SE) (SE) (SE)
Average # of re-inspections/ - 11.49 306 91 | 0.943 (3.44) 784 92 | -0.18 (3.21) .956 44
establishment/year (11.16)
Average # of 0.001 .306 91 - 0.058 .079 93 | 0.06 (0.031) .051 48
complaints/1,000 (0.000995) (0.033)
establishments/year
Average # of outbreaks/1,000 | 0.00089 78 92 0.579 .079 93 - 0.40 (0.50) A3 47
establishments/year (0.00323) (0.326)
Average # of Salmonella -0.00042 96 44 1.305 .051 48 0.035 43 47 -
cases/100,000 population (0.0074) (0.652) (0.044)
served/year
than agencies using numerical scores, but 5%
more Salmonella cases (Table 2). Almost one
third of agencies, however, using numerical
scores also used letter grades (Table 1).
Agencies that used a Critical/Noncritical
violation scheme reported 3% more mean
complaints but 3% fewer mean re-inspec-
tions, 27% fewer outbreaks, and 19% fewer
Salmonella cases than those using Priority-
Priority Foundations-Core schemes. Agencies
that used Risk Factor-Good Retail Practices
schemes tended to have fewer re-inspections
and complaints but more outbreaks and Sal-
monella cases than did agencies not using
these schemes (Table 2). Although most of
these findings are not statistically different
from each other, the overall pattern of results
is noteworthy.
Regarding associations between outcome
measures, we observed an almost statistically
significant relationship between reported
number of complaints/1,000 establishments/
year and number of Salmonella cases/100,000
population/year. Every unit of increase in
reported Salmonella cases/100,000 popula-
tion/year was associated with an increase in
1.03 complaints/1,000 establishments (p =
.051) (Table 4).
Discussion
The trends observed in this study comple-
ment the existing literature that supports
the value of transparency in the disclosure of
12 Volume 83 * Number 6
food establishment inspection data. Disclo-
sure at the point-of-service was associated
with fewer mean numbers of re-inspections,
complaints, outbreaks, and Salmonella cases
than disclosure online only, with a signifi-
cant difference (p = .03) in the number
of outbreaks between the two disclosure
methods. These findings are consistent with
previous studies in New York City and Los
Angeles that demonstrated benefits to dis-
closure at the point-of-service. In this study,
disclosure at the point-of-service included
posting of inspection results inside and
outside of the food establishment. It was
not the goal of this study to parse the out-
comes resulting from disclosures of inspec-
tion results posted inside or outside of food
establishments. Future studies might be
warranted to evaluate the effectiveness of
the nuance of disclosure location at food
establishments.
Letter grading methods were associated
with fewer complaints and outbreaks than
numerical scoring methods but both meth-
ods had better outcomes than for inspections
in the absence of a grading system. The Criti-
cal/Noncritical inspection violation scheme
was associated with fewer outbreaks and Sal-
monella cases than Priority-Priority Founda-
tions-Core or Risk Factor-Good Retail Prac-
tices schemes. These results suggest that how
local agencies conduct and score food estab-
lishment inspections and disclose results
to the public likely affect the success of the
programs to control and prevent foodborne
illnesses and food safety hazards.
A strength of this study is that use of the
Retail Program Standards listserv allowed
for direct contact and survey dissemination
to managers or primary contacts of food
establishment inspection programs. The use
of this listserv also enabled access to a wide
geographic range of potential respondents,
as this program includes agencies from
all 50 states and Washington, DC, as well
as five U.S. territories: American Samoa,
Guam, Northern Mariana Islands, Puerto
Rico, and the Virgin Islands. Additionally,
given the variations in inspection practices,
many survey questions included an open-
text option for “Other” answers that were
not listed as potential answer choices. This
feature allowed for the capture of unique or
less common practices.
There are several limitations to this
study. First, the presence of selection bias
cannot be understated given the use of a
convenience sample of survey recipients
and online recruitment, which limits the
representativeness of the results to those
who participated in the FDA Retail Food
Program. Second, Salmonella cases were
self-reported. Many inspection agencies do
not track the number of Salmonella cases,
as that is typically the duty of epidemiol-
ogy divisions. As such, the number of cases
reported by survey respondents might not
reflect true case counts. Third, missing data
and an abbreviated collection period weak-
ened the survey data analysis; the data col-
lection period was truncated by local and
state health departments needing to focus
on the COVID-19 pandemic response. This
necessity limited the ability to obtain miss-
ing data points and limited the ability of
agencies to respond. Fourth, the survey did
not collect information about the number
and types of triggers for re-inspection of
an establishment, which vary across agen-
cies. A potential confounder might be the
size of the inspection agency or the num-
ber of inspectors, as agencies with more
inspectors or more aggressive practices
could potentially be able to conduct more
re-inspections or to detect more violations,
illnesses, and outbreaks than smaller agen-
cies. Fifth, the survey did not allow for cap-
ture of programmatic changes that occurred
between 2016 and 2018 (e.g., if a jurisdic-
tion updated its food code during this time).
"SS
References
Although most findings were not statisti-
cally significant on an individual basis due to
limitations in sample size, the overall pattern
of results supports and enhances the existing
literature on the performance of food estab-
lishment inspection programs. For example,
for every unit increase in complaints, there
was a corresponding increase in the number
of re-inspections. There was a similar rela-
tionship with reported foodborne outbreaks.
Future research should include a larger num-
ber of agencies by a factor of 2 or 3 to clarify
several of these relationships.
Conclusion
Overall, characteristics of food establishment
inspection programs appear to be associated
with foodborne illness and outcomes. These
results warrant future research efforts to
improve the effectiveness of these programs.
This study suggests that agencies that disclose
at the point-of-service reported 55% fewer
average number of outbreaks compared with
those using online disclosure only. Similarly,
applying a grading scheme as a summary
measure of inspection results was associated
with improved foodborne illness outcomes.
Policy makers should consider these findings
when evaluating program effectiveness mea-
sures and when considering changes to exist-
ing food inspection programs. “39M
Acknowledgements: This study was funded
through cooperative agreement 6NU380T
000300 between the Centers for Disease Con-
trol and Prevention (CDC) and the National
Environmental Health Association (NEHA).
The findings and conclusions are solely the
responsibility of the authors and do not nec-
essarily represent the official views of CDC
and NEHA.
Corresponding Author: Thuy N. Kim, Divi-
sion of Environmental Health Sciences, Uni-
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