NEHA September 2023 Journal of Environmental Health

The September 2023 issue of the Journal of Environmental Health (Volume 86, Number 2), published by the National Environmental Health Association.

JOURNAL OF Environmental Health Dedicated to the advancement of the environmental health professional

Volume 86, No. 2 September 2023

www. neha.org

Published by the National Environmental Health Association

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JOURNAL OF Environmental Health Dedicated to the advancement of the environmental health professional Volume 86 No 2 e15ember 22

ADVANCEMENT OF THE SCIENCE Special Report: Federal Meat and Poultry Inspection Duties and Requirements—Part 4: Food Defense, Product Sampling, Rules of Practice, and Summary ................................................. 8

ABOUT THE COVER

The Food Code from the Food and Drug Administra- tion (FDA) is a set of science-based food safety guide-

ADVANCEMENT OF THE PRACTICE Needs Assessment of Environmental Health Professionals in Montana:

A Post-COVID-19 Perspective ................................................................................................... 12 Special Report: A Collaborative Approach to National Food Code Adoption .............................. 22 Building Capacity: Build Capacity With Generative Artificial Intelligence .................................. 26 Direct From AEHAP: Expanding Horizons: Online, In-Person, and Hybrid Internship Opportunities to Meet the Needs of Environmental Health Students and Potential Employers ....... 30 Programs Accredited by the National Environmental Health Science and Protection Accreditation Council....................................................................................... 33 Direct From ATSDR: The Environmental Justice Index: Measuring Cumulative Impacts of Environmental Burdens on Health ........................................................................................... 34 Direct From CDC/Environmental Health Services: Retail Collaborative Provides Tools and Resources to Drive Food Safety .................................................................................... 38 Direct From the NEHA Preparedness Program Committee: Coordinating Environmental Health Preparedness Across Sectors ............................................................................................. 42 The Practitioner’s Tool Kit: Eective Cleaning: Our Influence on Good Sanitation Practices ....... 46 ADVANCEMENT OF THE PRACTITIONER Environmental Health Calendar ...............................................................................................48 Resource Corner........................................................................................................................ 49 YOUR ASSOCIATION President’s Message: Environmental Health—Everywhere and Nowhere ................................................ 6 NEHA Annual Financial Statement........................................................................................... 29 Special Listing ........................................................................................................................... 50 In Memoriam............................................................................................................................. 52 NEHA News .............................................................................................................................. 54 NEHA 2024 AEC....................................................................................................................... 57

lines that serve as the basis for

jurisdictional food codes that regulate

retail food service in the U.S. This month’s cover article, “A Collaborative Approach to National Food Code Adoption,” highlights the multipronged approach undertaken by the Retail Food Safety Regulatory Association Col- laborative to support adoption of the FDA Food Code . Furthermore, the Direct From CDC/ Environmental Health Services column in this issue spotlights other tools and resources pro- vided by the Collaborative to drive food safety. See pages 22 and 38. Cover image © iStockphoto: Irfan Khan Alvi

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Official Publication

Published monthly (except bimonthly in January/February and July/ August) by the National Environmental Health Association, 720 S. Colorado Blvd., Suite 105A, Denver, CO 80246-1910. Phone: (303) 802- 2200; Fax: (303) 691-9490; Internet: www.neha.org. E-mail: kruby@ neha.org. Volume 86, Number 2. Yearly subscription rates in U.S.: $150 (electronic), $160 (print), and $185 (electronic and print). Yearly international subscription rates: $150 (electronic), $200 (print), and $225 (electronic and print). Single copies: $15, if available. Reprint and advertising rates available at www.neha.org/jeh. Claims must be filed within 30 days domestic, 90 days foreign, © Copyright 2023, National Environmental Health Association (no refunds). All rights reserved. Contents may be reproduced only with permission of the managing editor. Opinions and conclusions expressed in articles, columns, and other contributions are those of the authors only and do not reflect the policies or views of NEHA. NEHA and the Journal of Environmental Health are not liable or responsible for the accuracy of, or actions taken on the basis of, any information stated herein. NEHA and the Journal of Environmental Health reserve the right to reject any advertising copy. Advertisers and their agencies will assume liability for the content of all advertisements printed and also assume responsibility for any claims arising therefrom against the publisher. The Journal of Environmental Health is indexed by Clarivate, EBSCO (Applied Science & Technology Index), Elsevier (Current Awareness in Biological Sciences), Gale Cengage, and ProQuest. The Journal of Environmental Health is archived by JSTOR (www.jstor.org/journal/ jenviheal). All technical manuscripts submitted for publication are subject to peer review. Contact the managing editor for Instructions for Authors, or visit www.neha.org/jeh. To submit a manuscript, visit http://jeh.msubmit.net. Direct all questions to Kristen Ruby-Cisneros, managing editor, kruby@neha.org. Periodicals postage paid at Denver, Colorado, and additional mailing offices. POSTMASTER: Send address changes to Journal of Environmental Health , 720 S. Colorado Blvd., Suite 105A, Denver, CO 80246-1910.

Journal of Environmental Health (ISSN 0022-0892)

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e5+re& ou/5: o( #/ +e)o e1#r5me/5 o( /7+ro/me/5#l e#l5* #/ +e)o Thomas H. Hatfield, DrPH, REHS, DAAS #l+(or/+# 5#5e /+7er4+5: Nor5*r+&)e Dhitinut Ratnapradipa, PhD, MCHES re+)*5o/ /+7er4+5: m#*# N

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Volume 86 • Number 2

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September 2023 • Journal of Environmental Health

YOUR ASSOCIATION

 PRESIDENT’S MESSAGE

Environmental Health— Everywhere and Nowhere

Tom Butts, MSc, REHS

I have been in countless conversations over the past dozen or more years about all of the great work environmental health pro- fessionals do and how—time after time—the public health community and the public at large do not recognize our practice and the contributions made in our important eorts. In late June, this conversation was again the case at the California Environmental Health Association’s Annual Education Symposium in Sacramento. Both speakers and participants expressed their frustration about the lack of awareness about environmental health pro- grams, skills, abilities, and scope of expertise. We work hard to recognize our peers but the lack of system-wide recognition for environ- mental health professionals beyond our own circle seems very limited. Stories were shared from across the country about a lack of un- derstanding of our work, even among public health agency leaders at various levels of the governmental public health system. This problem is not new as it was one of several issues called out in a U.S. Department of Health and Human Services/Centers for Disease Control and Prevention (CDC) docu- ment published in November 2000— Healthy People 2010 . This report published objectives for improving the nation’s health. In response, the Division of Emergency and Environ- mental Health Services within the National Center for Environmental Health formed a steering committee that spearheaded a pro- cess that was responsible for developing and implementing the final strategy. The strategy was developed through the participation of an External Partners Work- ing Group made up of 31 members who

• Foster leadership • Communicate and market • Develop the workforce • Create strategic partnerships

I encourage each of you to get active in making our work more well-known.

In 2008, an assessment of the environ- mental health practice in Maryland iden- tified challenges that closely aligned with the goals from the 2003 strategy document. Unfortunately, it is remarkably similar to what many local environmental health pro- grams are experiencing today. The article identified issues such as funding structure vulnerabilities, workforce and recruitment challenges, poor compensation especially when compared to education requirements, and limitations in legal support (Resnik et al., 2008). So here we stand over two decades after this need was identified and the same challenges— impacted by a series of environmental pub- lic health events, most recently a worldwide pandemic—remain. Why were past efforts less than successful? From my perspective, we need a unified approach to address this issue that will engage federal, state, and local gov- ernments; our terrific industry partners; aca- demia; and other nonprofit environmental public health organizations. Is this our time to stand quietly by? No chance! A number of years ago, as an environmen- tal health director, I worked with the environ- mental health sta to estimate their contacts with community members and then com- pared those estimates to other public health programs. The conclusion was that the envi- ronmental health workforce (the second larg- est part of the public health workforce) has

represented the environmental public health and protection practice community; special populations; academia; advocacy groups; and representatives of other centers, institutes, and oces within CDC, as well as the Agency for Toxic Substances and Disease Regis- try. Included in this group was Mel Knight, NEHA past president (2011–2012), and Doug Farquhar, our current director of Gov- ernment Aairs. The draft strategy was then reviewed by more than 100 additional envi- ronmental health and public health experts and advocacy organizations. CDC (2003) published A National Strategy to Revitalize Environmental Public Health Ser- vices , which was intended to be a working doc- ument that would be modified over time. The intention was to identify needed resources, organize and implement activities described in the strategic plan, and create a timeline for the accomplishment of objectives. The strategy was to be a starting point for rejuvenating the environmental health sys- tem at the federal, state, tribal, territorial, and local levels in the U.S. (Buchanan, 2006). The goals of the strategy were to: • Build capacity • Support research

Volume 86 • Number 2

more contact with community members than any other part of the public health system. On a given day, an environmental health pro- fessional could have face-to-face contact with dozens of community members (e.g., regu- lated communities, peers in public health, city and county planning sta, elected and appointed ocials, community members). So how can we all become more active as ambassadors of environmental health? How can we work to address the lack of public rec- ognition and understanding of the important roles and functions environmental health plays in disease prevention, hazard reduction, and a variety of work that improves community health outcomes? We need to seek opportu- nities to make our work more visible through improving internal (e.g., leaders and public information ocers within health depart- ments) and external (e.g., the public, other government departments, elected ocials) rec- ognition and visibility in any way we can. NEHA has taken some important steps with an actively engaged marketing and com- munication team working to move the bar. One tool now available for peer-to-peer rec- ognition is our members-only online Com- munity platform and a second is the Swipe Right for Environmental Health campaign recently piloted in Ohio. On Community (https://community.neha. org), I found this contribution from Charles Treser, principal lecturer at the University of Washington: I think one of the reasons that EPH [environmental public health] tends to

be invisible is how broad our mandate is. No other profession covers every- thing from air quality to zoonotic dis- eases. And the list of program areas has been expanding almost exponentially as new science discoveries, emerging tech- nologies, and changing conditions (like climate change) reveal new health risks. So, while people can identify with the food inspectors, the onsite sew- age inspector, the industrial hygienists, etc., they don’t see these, and we seldom point out that these are all part of the mandate of EPH. The one thing that uni- fies our profession is risk—any environ- mental factor or condition that poses a risk to human life, health, or safety is the province of EPH. Treser identified many of the challenges we face and I hope that the marketing and com- munication eort we have undertaken will provide tools and support to confront this challenge. The conversation on the platform that followed was insightful and shows this challenge is one many of us identify with. Treser went on to suggest that by “high- lighting human health risk as the common theme of all the many aspects of our profes- sion, I think we can help the public and our policymakers better understand the critical importance of the environmental health pro- fessional to their own health and well-being.” The Swipe Right for Environmental Health campaign—launched as a pilot in Ohio dur- ing May and June 2023 and to be advertised again in September 2023—was developed in

response to concerns we heard from our mem- bers about how invisible and undervalued they felt as a profession. In response, we developed an advertising campaign to raise the visibility and appreciation of our important workforce among decision makers and the public. The advertising targeted decision makers at and around the Ohio Statehouse. The ads featured three environmental health professionals from Ohio and urge viewers to support environ- mental health. You can view the campaign and ads at www.neha.org/swipe-right. I encourage each of you to get active in making our work more well-known.

tbutts@neha.org

References Buchanan, S. (2006). Revisiting revitalization. Journal of Environmental Health , 68 (6), 69–70. https://www.cdc.gov/nceh/ehs/docs/ jeh/2006/Jan_Feb_2006_Buchanan.pdf Centers for Disease Control and Prevention. (2003). A national strategy to revitalize environmental public health services . https:// www.cdc.gov/nceh/ehs/Docs/National Strategy2003.pdf Resnik, B., Zablotsky, J., Nachman, K., & Burke, T. (2008). Examining the front line of local environmental health prac- tice: A Maryland case study. Journal of Public Health Practice and Management , 14 (1), 42–50. https://doi.org/10.1097/01. PHH.0000303412.12227.86

Stand out in the crowd. Show the world you are the environmental health expert you know you are with a credential. You might even earn more or get promoted. neha.org/credentials

September 2023 • our/#l o( /7+ro/me/5#l e#l5*

ADVANCEMENT OF THE SCIENCE

 SPECIAL REPORT

Federal Meat and Poultry Inspection Duties and Requirements—Part 4: Food Defense, Product Sampling, Rules of Practice, and Summary

Roger W. Amery, CP-FS

findings. These meetings are documented on memoranda of interview and not on non- compliance records because there are no reg- ulations regarding food defense. Mandatory Zero Tolerance Due to contamination from pathogens in feces, ingesta (i.e., material such as food and drink taken into the body by way of the digestive tract), and milk, FSIS has mandated that companies inspect red meat carcasses from the carcass rail inspection to the final wash with zero tolerance for those contami- nants. This requirement applies also to head meat, cheek meat, and weasands (i.e., eso- phogi) that are inspected separately from car- casses. Companies should have e ective con- trols in place, which are monitored by FSIS to ensure that zero tolerance is maintained (U.S. Department of Agriculture [USDA], 2019).

b45r#%5 This 4-part series aims to inform environmental health specialists of the duties and requirements for federal meat and poultry inspectors and the companies they regulate. Part 1 provided general attributes of U.S. Department of Agriculture Food Safety and Inspection Service inspection personnel and regulated companies (Amery, 2023a). Part 2 covered the computer-based system used to communicate results of inspection tasks, the marks of inspection, and slaughter inspection duties and company responsibilities (Amery, 2023b). Part 3 covered the duties performed by consumer safety inspectors who monitor food safety systems. These duties include monitoring of Sanitation Standard Operating Procedures, hazard analysis critical control point (HACCP) procedures, reinspection, labeling issues, and company allergen controls (Amery, 2023c). Part 4 will discuss the verification of company food defenses, laboratory sampling of products, and the Rules of Practice. A summary of the 4-part series is also provided.

Microbiological Sampling

Introduction and Overview At prescribed frequencies, consumer safety inspectors (CSIs) collect product samples, medium washes, and swabs, then send them to U.S. Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS) laboratories for analysis of pathogens related to the product types. At slaughter compa- nies, samples are taken by FSIS inspectors to test for antimicrobials and residual chemi- cal abuse by livestock suppliers. The Rules of Practice are used to address numerous noncompliances. This 4-part series has provided a treatise for environmental health specialists on the duties and policies of FSIS inspectors for the protec- tion of public health. To round out the series, part 4 discusses verification of company food

defenses, laboratory sampling, and the Rules of Practice. Furthermore, a summary and con- clusions from the series are provided. Food Defense Verification Food defense is the voluntary action that companies can take to ensure that intentional contamination does not take place. Threats of intentional contamination could be from outside or inside companies. Companies are encouraged but not required to have written and tested procedures for food defense. FSIS inspectors complete a computerized survey 4 times a year regarding the written food defense procedures of companies. If FSIS inspectors find vulnerabilities that could result in intentional contamination, they meet with the companies and explain the

Generic E. coli Sampling FSIS requires companies that slaughter live- stock to test for E. coli biotype 1 to verify that the slaughter process is under control (Contamination With Microorganisms, 2023; Subpart K—Post Mortem Inspection, 2023a). Carcasses are to be totally free of all fecal material; E. coli is a good indicator of undetectable fecal material. CSIs are to check the slaughter company activities and records regarding E. coli testing. The establishments are to have written procedures showing that the chilled carcasses are selected randomly and from what sites on the carcasses the sam- ples are taken. Testing frequencies (i.e., tests per carcasses produced) are determined according to spe-

Volume 86 • Number 2

cies slaughtered. Companies slaughtering more than one species must test the species with the largest volume slaughtered. Laborato- ries that conduct the analyses must use analyt- ical methods approved by a recognized scien- tific body. Results are recorded and charted in terms of CFU per surface area. If needed, FSIS takes corrective actions based on the results. Pathogen Reduction Performance Standards: Sampling to Test for Acceptable Levels of Salmonella At the regulated companies, FSIS sampling is conducted to test for acceptable levels of Salmonella in red meat and Salmonella and Campylobacter in poultry (Contamination With Microorganisms, 2023; Subpart K— Post Mortem Inspection, 2023b). These stan- dards are based on nationwide microbiologi- cal data collection surveys on these classes of products. The Oce of Public Health Science (OPHS) within FSIS determines which com- panies are to be tested and the frequency of testing based on previous company perfor- mance data. The number of samples taken for each sample set depends on the product class. Only a specified number of the samples, listed in the regulations, can test positive for Salmonella . If the first set passes, no more samples are taken at that time. If the first set fails, the company must take immediate cor- rective action, and then a second sample set is taken. If the second set of samples shows failure, the company is to reassess their haz- ard analysis critical control point (HACCP) program and take corrective action before a third set is taken. If the third set of samples fails, FSIS acts according to its Rules of Prac- tice (2023). Directed Microbiological Sampling At a frequency determined by OPHS, CSIs and public health veterinarians (PHVs) are directed to collect and process specific prod- uct samples produced by the companies and express mail the samples to FSIS laboratories. These samples could be raw ground beef to test for E. coli O157:H7 and other pathogenic E. coli , or final, finished, and packaged ready- to-eat, fully cooked products to test for Sal- monella and/or Listeria monocytogenes . Occasionally, CSIs and PHVs are directed to collect product or sponge samples of beef, pork, and poultry carcasses for national base-

line studies and/or for verifying the eective- ness of the food safety systems. The com- panies are to hold the product lots that the sampled product represent in case of positive results. In the event of a positive result, the aected product is disposed of or recondi- tioned by the company. Then that same prod- uct is on test-and-hold restriction until five compliant results occur, after which the plant may produce the product without testing. Samples Taken for Listeria monocytogenes Control Verification L. monocytogenes is an environmental patho- gen that can contaminate ready-to-eat prod- ucts after the pathogens have been addressed at a previous lethality step (e.g., usually the cooking step). If ready-to-eat products have cooled and remain exposed until packaged and the surrounding environment contains L. monocytogenes , the ready-to-eat product could be contaminated—but it gets pack- aged and dispensed into commerce. As a result, the consumer unknowingly consumes the contaminated product (without cooking and therefore killing the L. monocytogenes ) because the product is labeled as ready-to-eat. This concern led to FSIS requirements that detail procedures companies must implement in the food safety system to address this issue (Requirements for Specific Classes of Prod- ucts, 2023). Essentially, companies choose from among three alternatives: • Alternative 1: Use of both post-lethality treatment and an antimicrobial process or agent. • Alternative 2: Use of either the post-lethal- ity treatment or an antimicrobial process or agent. •Alternative 3: Use of sanitation mea- sures only. The companies choosing alternative 2 or alternative 3 must have provisions in writ- ing for product hold-and-test procedures and actions to take on positive results of prod- uct and swab samples. Companies choosing alternative 3 and producing deli or hot dog products have the greatest risk for L. mono- cytogenes contamination. Alternative 3 is the least safe of the alternatives. Therefore, FSIS requires FSIS-directed product sampling at companies that use sanitation measures only. Companies are not under regulation to fol- low these alternatives if they cook the prod- uct inside cooking bags and the products are

then cooled, packaged, labeled, and shipped while remaining inside the bags. In this man- ner, the product never contacts other food contact surfaces that could be contaminated by L. monocytogenes . The bags are opened only after purchase by the consumer. If a company continually fails tests for L. monocytogenes , an enforcement investigation and analysis ocer (EIAO) could be sent to the company to perform an assessment that could result in the recommendation of inten- sified verification testing (IVT) for L. mono- cytogenes . Then, EIAOs enter the company unannounced shortly after the company has executed the corrective actions for remedy of the L. monocytogenes contamination. The IVT is conducted to ensure that the company’s corrective actions are eective in preventing contamination by L. monocytogenes of ready- to-eat products. National Antimicrobial Resistance Monitoring System The National Antimicrobial Resistance Moni- toring System for Enteric Bacteria (NARMS) is a national surveillance system to moni- tor antimicrobial enteric bacteria that could enter the human food chain (Centers for Dis- ease Control and Prevention, 2023). When directed by the Public Health Inspection Sys- tem (PHIS), a PHV schedules a time to collect a sample of ceca contents from the cecum/ large intestine of freshly killed livestock. This sample is sent to a FSIS laboratory for analy- sis of Salmonella , generic E. coli , Campylo- bacter , and enterococcus species. NARMS is a collaborative eort of FSIS, the Food and Drug Administration (FDA), and the Centers for Disease Control and Preven- tion. In addition to monitoring antimicrobial susceptibility, microbiological and epidemio- logical research is conducted to better under- stand antimicrobial resistance. The results of these samples are nonregulatory, and as such, companies do not hold the carcasses and oal, and the results are not provided to PHVs or the companies.

Chemical Sampling

National Residue Program: Residue Sampling of Carcasses The National Residue Program is a collab- orative eort with FDA, the U.S. Environ- mental Protection Agency, and FSIS (USDA,

September 2023 • our/#l o( /7+ro/me/5#l e#l5*

ADVANCEMENT OF THE SCIENCE

2022). PHVs are directed by PHIS to ran- domly select a carcass and excise choice tissues such as kidneys, livers, or muscles. When FSIS collects a sample, the slaughter company provides the address of where the animal originated. Pending the results of testing, the company is to hold the carcass and o al. The choice tissues are sent to an FSIS laboratory for testing of potential illegal injections or feeding of the livestock with antibiotics or hormones by the farm ani- mal producers. The illegal chemicals could have detrimental e ects on the consumers of meat and poultry products. If the labora- tory results are negative for illegal chemi- cals, the carcass and o al are released, and there is no violation against the farm ani- mal producer. If the choice tissues show a laboratory result of an illegal chemical or drug, the carcass and o al are condemned, the producer is warned and placed on a list of residue violators, and the livestock from that producer is closely monitored by slaughter companies and FSIS. Food inspectors on the slaughter line can segregate for veterinary disposition a carcass that appears diseased and possibly unfit for human consumption. If a PHV is suspicious that this pathology is due to illegal residues of hormones or antibiotics, the PHV will collect a kidney and run a kidney inhibition swab (KIS) test, which is a screening test for antibiotics and hormones. If the KIS test is negative, then there is no potential violation, and the carcass and o al are released. If the KIS test shows a positive result, then the kidney, liver, and mus- cle tissues are excised from that carcass. These tissues are sent to an FSIS laboratory to deter- mine if the positive KIS test is the result of an illegal use of antibiotics or hormones. Rules of Practice A regulatory control action is when CSIs retain product, reject equipment or areas, or stop production. A withholding action is when FSIS refuses the mark of inspection (e.g., branding, packaging materials with inspection legends) to be applied to products. Whenever FSIS inspectors or EIAOs determine that an enforcement action is required against a com- pany, it is completed in accordance with FSIS regulations (Rules of Practice, 2023). Parts 500.2 through 500.7 of the Rules of Practice give more detail about the reasons

for FSIS to take such enforcement actions, how companies can appeal the actions, how establishments might come into abeyance (i.e., suspension), conditions for withdrawal of inspection rights, and refusals of grant of inspection to establishments that are found unacceptable. Part 500.8 describes condi- tions for rescinding product labels. Whenever enforcement actions leading to a suspension are taken, case files are created. If companies have committed a potential crime, the case files are provided to the Oce of Program Evaluation Enforcement and Review within FSIS, where the matters are investigated for possible criminal prosecution. Technical Support FSIS inspection is a team e ort. Whenever FSIS inspectors have urgent issues and need assistance or guidance, there are knowledge- able supervisors to contact for advice and support. Those supervisors can contact upper management for further assistance. For ques- tions about technical concerns, FSIS inspec- tors can contact askFSIS (www.fsis.usda.gov/ contact-us/askfsis) online or call 1-800-233- 3935. Sometimes the technical questions can lead to changes in national policy. Part 4 Summary Companies are encouraged to have written procedures on food defense against threats of potential contamination. CSIs check for vul- nerabilities and, if vulnerabilities are found, CSIs meet with the companies and document the meeting using a memorandum of inter- view. Zero tolerance is monitored by FSIS and is mandated to prevent fecal, ingesta, and milk contamination of carcasses and o al in slaughter companies. In addition, FSIS requires companies that slaughter livestock to conduct testing for generic E. coli to determine if their processes are under control. The Pathogen Reduction Performance Standards require companies to test for acceptable levels of Salmonella and Campylobacter . At a frequency determined by OPHS, FSIS is directed to collect ground beef samples to test for pathogenic E. coli as well as fully cooked products for Salmonella and/ or L. monocytogenes . When directed, FSIS collects aseptic products or sponge samples of carcasses for national baseline studies and/or to verify food safety e ectiveness. Antimicrobial enteric

samples are taken as part of the NARMS program to better understand antimicrobial resistance. The National Residue Program requires FSIS to select carcasses and remove choice tissues to test for potential illegal injections of antibiotics or hormones into the livestock. The Rules of Practice given in the regulations describe actions to be taken to bring noncompliant companies either into compliance or complete closing. Series Summary and Conclusion FSIS inspects regulated companies from the time livestock first enter the slaughter com- panies to the point where the derived food products are shipped to consignees. Nonfed- erally inspected warehouses, stores, and even consumers are contacted by FSIS regarding FSIS-regulated products, indicating a large range of inspection responsibilities. FSIS uses utensils and organoleptic measures to determine food safety of carcasses and car- cass parts in slaughter companies. Observa- tions are made, data are reviewed, records are checked, microbiological and chemical samples are taken and analyzed, and prod- uct labels and written food safety systems are scrutinized. Actions are taken accordingly, and documentation is created to protect pub- lic health in regulated companies that pro- duce meat and poultry products. Of note, this series is not all-inclusive or com- prehensive. For example, it does not include egg inspection, pet food, canning, cooking/ cooling times, and temperature controls. Professionals in a food safety career in another government agency will note that there can be considerable di erences between their agency policies and the policies imple- mented by FSIS. For example, the author is not aware of any government food inspec- tion agency—other than state agriculture agencies—where government regulators have permanent oces inside the companies they regulate. The FSIS education requirements might also be a surprise to food safety inspec- tors in other government agencies. The author has noticed little mention of federal meat and poultry inspection in the Journal of Environmental Health . The aim of this 4-part series, therefore, is to inform environmental health specialists of the duties and requirements of federal meat and poultry inspectors. This series fills an infor- mation gap about public health protection—

Volume 86 • Number 2

from antemortem inspections of live animals used for food to retail inspections of meat and poultry. Acknowledgements: The author thanks Inspectors Shanna Tull, Maria Cornejo, Suzy Grien, and Drs. Mohsen Ali, Khadim Awan, and Stephanie Glanz for reviewing this 4-part series. William Cranford is acknowledged

for providing the author with information about EIAO qualifications. The author also thanks Edward Amery for the use of his com- puter. Finally, without the superb editing of Suzanne Evans, this 4-part series would not have been possible.

and do not necessarily represent the ocial position of USDA or FSIS. Further, the inter- pretation of the regulations used to support this special report may not reflect the actual interpretation set forth by USDA and FSIS. Corresponding Author: Roger W. Amery, 1663 Delaware Court, Geneva, IL 60134. Email: ameryrogerw@yahoo.com.

Disclaimer: The information and conclusions of this special report are those of the author

References

Amery, R.W. (2023a). Federal meat and poultry inspection duties and requirements—Part 1: History and current responsibilities. Journal of Environmental Health , 85 (9), 22–25. Amery, R.W. (2023b). Federal meat and poultry inspection duties and requirements—Part 2: The Public Health Inspection System, marks of inspection, and slaughter inspections. Journal of Environ- mental Health , 85 (10), 16–19. Amery, R.W. (2023c). Federal meat and poultry inspection duties and requirements—Part 3: Monitoring of food safety systems. Journal of Environmental Health , 86 (1), 24–27. Centers for Disease Control and Prevention. (2023). National Antimicrobial Resistance Monitoring System for Enteric Bacteria (NARMS) . https://www.cdc.gov/narms/index.html Contamination With Microorganisms; Process Control Verifica- tion Criteria and Testing; Pathogen Reduction Standards, 9 C.F.R. § 310.25(a,b) (2023). https://www.ecfr.gov/current/title-9/ chapter-III/subchapter-A/part-310/section-310.25 Requirements for Specific Classes of Products, 9 C.F.R. §430 (2023). https://www.ecfr.gov/current/title-9/chapter-III/subchapter-E/ part-430

Rules of Practice, 9 C.F.R. § 500.1–8 (2023). https://www.ecfr.gov/ current/title-9/chapter-III/subchapter-E/part-500 Subpart K—Post Mortem Inspection; Disposition of Carcasses and Parts, 9 C.F.R. § 381.94 (2023a). https://www.ecfr.gov/ current/title-9/chapter-III/subchapter-A/part-381/subpart-K/ section-381.94 Subpart K—Post Mortem Inspection; Disposition of Carcasses and Parts, 9 C.F.R. § 381.76 (2023b). https://www.ecfr.gov/ current/title-9/chapter-III/subchapter-A/part-381/subpart-K/ section-381.76 U.S. Department of Agriculture, Food Safety and Inspection Service. (2019). FSIS directive: Verification of procedures for controlling fecal material, ingesta, and milk in livestock slaughter operations (6420.2, Revision 2). https://www.fsis.usda.gov/sites/default/files/ media_file/2020-07/6420.2.pdf U.S. Department of Agriculture, Food Safety and Inspection Service. (2022). FSIS directive: The National Residue Program roles, func- tions, and responsibilities (10,800.4). https://www.fsis.usda.gov/ sites/default/files/media_file/2022-02/10800.4.pdf

The food industry moves fast. The Certified Professional–Food Safety (CP-FS) credential keeps you up-to-date with the rapidly changing food industry and tells your community that you know the science and practice to keep them safe. Learn the requirements: neha.org/cpfs-credential

September 2023 • Journal of Environmental Health

ADVANCEMENT OF THE PRACTICE

Needs Assessment of Environmental Health Professionals in Montana: A Post-COVID-19 Perspective

The COVID-19 pandemic created addi- tional demands and significantly exacerbated the stresses and strains on the profession in unforeseen ways. Two rapid national needs assessment surveys were administered by the National Environmental Health Asso- ciation (NEHA, 2020a, 2020b) during the pandemic. Despite eorts to begin the pro- cess of developing a deeper understanding of the changing landscape for EH professionals, there remains a lack of research to compre- hensively identify and characterize the scope, impact, conditions, and current and future needs of the profession (McCormick, 2020). The last comprehensive national study of EH professionals was completed more than 50 years ago (Brooks et al., 2019). While EH professionals in Montana (also referred to as sanitarians) face challenges and concerns similar to those reported nationally, they are faced with responsibilities for a vast geo- graphic area that includes 147,000 mi 2 . The remote and rural characteristics of towns, cit- ies, and residents across the state are further complicated by the decentralized nature of public health in Montana. Similar to their national counterparts, EH professionals in Montana in rural areas commonly face a lack of public health per- sonnel, resources, and training; some EH employees have no specific public health training or experience and must learn on the job (Denison, 2020; Rosenblatt et al., 2002). Health departments are hampered by stang shortages, unexpected retirements brought on by the COVID-19 pandemic, low pay, and National Environmental Health Science and Protection Accreditation Council David P. Gilkey, DC, PhD, REHS Montana Technological University Seana Westcarr-Gray, MS, JD University of Montana School of Public and Community Health Sciences Leigh Taggart, MPH University of Montana School of Public and Community Health Sciences Emily Weiler Montana Public Health Training Center Jeffrey Havens, RS/REHS Montana Department of Public Health and Human Services Priscilla Oliver, PhD

b45r#%5 We designed a cross-sectional study for environ- mental health (EH) professionals in Montana as a follow-up to a needs assessment conducted in 2020 by the Montana Public Health Workforce Development Group. A 57-question survey was developed to deepen the understanding of the profession regarding demographics, work status and position, education and licensure, work prior to and during the COVID-19 pandemic, professional preparation and continuing educa- tion, job satisfaction, recruitment and retention, and emerging issues. The survey was administered electronically in 2022 to all health depart- ments in Montana and had a 74% response rate. The results revealed that most EH professionals in Montana are predominately White. Re- spondents reported being adequately trained but highlighted that ad- ditional training would be beneficial. Job-related stress, staffing levels, and salary levels were identified as areas of concern. Furthermore, re- spondents reported that they are otherwise fulfilled by the purposeful nature of their jobs. Our study was successful in capturing an updated view of the challenges facing EH professionals in Montana. Using these findings, the Montana Environmental Health Association and the Mon- tana Public Health Training Center are developing training solutions for these professionals.

Introduction The field of environmental health (EH) has advanced considerably, evolving from prac- tices rooted in ancient civilizations such as the Egyptians, Minoans, Greeks, and Romans (Duy, 1992; see Supplemental for a back- ground of the profession at www.neha.org/ jeh-supplementals). While many of the duties and expectations remain the same today, EH has become more complex and specialized, which has resulted in a struggle to define and categorize this workforce as job responsibili-

ties can be vastly encompassing (McCormick, 2020). Today, the EH professional must pos- sess expertise in multiple areas including drinking water quality, wastewater manage- ment, healthy homes, food safety, vectors and public health pests, and emerging issues (Brooks et al., 2019; National Environmen- tal Health Science and Protection Accredita- tion Council [EHAC], 2019). Moreover, the evolution of technology and information dis- semination has led to ever-expanding respon- sibilities (Gerding et al., 2020).

Volume 86 • Number 2

increased workload. With the backlash from the public and a perceived increase in politi- cal involvement in public health, many EH professionals feel more stress and thus have an increased desire to leave the workforce (Montana Public Health Workforce Develop- ment Group, 2020). In addition, there exists a short supply of graduates who choose to enter the field. Montana State University (MSU) recently developed a bachelor’s level environmental health program that is accred- ited by the National Environmental Health Sciences and Protection Accreditation Coun- cil (EHAC, 2020). In 2020, a public health workforce assess- ment survey was completed by the Montana Public Health Workforce Development Group (MPHWDG, 2020), which is made up of pro- fessionals from the Montana Public Health Association (MPHA), Montana Public Health Training Center, Montana Department of Pub- lic Health and Human Services, and Montana Environmental Health Association (MEHA). The assessment classified needs into three tiers of general categories: 1) policy development and program management, 2) communication skills, and 3) cultural competency. The assess- ment was designed to obtain a deeper under- standing of the current conditions and needs of EH professionals practicing in Montana, with the hope of addressing current needs and future challenges while learning what recruit- ing and retention strategies are preferred to grow the workforce. EH respondents reported feeling that their level of skill and familiarity with public health concepts were between “not much” and “a little” for tiers 1–3. This finding sug- gests that the EH workforce could benefit from various trainings and continuing educa- tion eorts to fill gaps in needed knowledge, skills, and abilities. Results also suggest that education and recruitment to the profes- sion should begin at the high school level (MPHWDG, 2020), which would provide an introduction and early exposure to the field of public health for college-bound students. MSU and the University of Montana School of Public Health are working to develop ways to increase the number of students entering the public health field. In April and October 2020, a national needs assessment of EH professionals was conducted in response to the ongoing COVID-19 pandemic (NEHA, 2020a, 2020b).

Results from the initial assessment revealed that 60% of EH professionals at local health departments were involved with COVID-19 responses in addition to their usual respon- sibilities. Respondents prioritized needs for COVID-19 cleaning and disinfection, per- sonal protective equipment (PPE), and safe food guidance (NEHA, 2020a). The follow- up assessment in October (NEHA, 2020b) revealed that high-priority needs included increased stang and personnel, more PPE, more consistent and high-quality COVID-19 information, and more technical support and guidance from the Centers for Disease Con- trol and Prevention. Based on a subset of data from the 2020 workforce study survey conducted by MPHWDG, it was determined that a separate survey that focused on the needs of EH profes- sionals in Montana would be useful to identify the eect of COVID-19 on the workforce. This separate survey would also garner ideas for sustaining and growing the profession given recent challenges such as the COVID-19 pan- demic. Our eort included a needs assessment survey developed to identify and characterize needs and gaps in information associated with EH practice, conditions, concerns, priorities, influences of the pandemic, and strategies for growing the workforce. We sought to answer the following ques- tions through the needs assessment: • What are the key characteristics of the cur- rent workforce? • Is the workforce adequately trained, staed, and paid? • How has the COVID-19 pandemic aected the workforce? •Are current social and political forces aecting the workforce? • What are the recommendations to support growth of the workforce? •What strategies might improve working conditions for the workforce? Methods The needs assessment survey was designed to focus on the needs, circumstances, inter- nal and external forces, and conditions of the EH workforce in Montana, with an empha- sis on improving recruitment and retention. A 57-question survey was developed. Ques- tions were designed to identify and classify the work-related duties prior to COVID-19, levels of satisfaction, and how these duties

changed because of COVID-19. Another area of interest was the qualification and training methods preferred by EH professionals, as well as projected needs for the future. Survey domains included demograph- ics, work status and position, education and licensure, work prior to COVID-19, practice in times of COVID-19, professional prepara- tion and continuing education, job satisfac- tion, recruitment and retention, and emerg- ing issues. Of the 57 questions, 36 were quantitative and 21 were qualitative. Ques- tion structures included single or multiple choice, completion, and open-ended ques- tions (see Supplemental Survey). The completed survey was approved by the institutional review board (IRB) of the University of Montana under the exempt category in accordance with federal regula- tions. After IRB review, a Qualtrics link to the survey was sent in 2022 to all public health departments across Montana for distribution to EH employees. The invitation and survey instructions informed participants of the pur- pose of the needs assessment and that partici- pation was voluntary. It also stated that ano- nymity would be assured and results would be aggregated. Completed surveys were downloaded from Qualtrics into an Excel spreadsheet for coding and analysis. The analysis was carried out using Minitab 20 and included frequencies, descriptive statistics, and cor- relations. Comparison of proportions was carried out using chi-square goodness of fit test when suitable sample counts and pro- portions were available. Results There were 100 completed or partially com- pleted surveys received from 135 respondents (74% response rate). We propose that vari- ability in the number of responses to each question occurred based on the comfort level of participants, perceived anonymity, time, and personal choice. Demographics Of the 100 participants surveyed, 58% self- identified as female. The largest age groups were 30–39 years and 50–59 years, at approx- imately 25% each. Only 1% of respondents identified as younger than 25 years and 7% identified as younger than 30 years. The majority of participants self-identified as

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