Services Department, n.d.). Through facili- tating policy development, AMC programs support operators in taking responsibility for long-term AMC and creating a culture of food safety at their establishments. By empowering operators to attain AMC, the AMC program is structured to interrupt a reactive enforcement cycle through program enrollment as an alternative to paying rein- spection fees and as an extension of time to implement new policies before the facility’s next inspection. Overall, MCESD reported a 41% decrease in enforcement actions taken following the institution of their AMC pro- gram. This result indicates preventative actions as not only a more successful com- pliance strategy but also a more ecient use of department resources (Shapiro, 2018). The county resources saved by reducing the num- ber of reinspections per establishment can be allocated to a risk-based frequency of routine inspections, which are more comprehensive and more ecient in responding to violations (Leinwand et al., 2017). Aside from the proactive protection of public health and improved eciency of environmental health agency resources, AMC program implementation can have sig- nificant collateral benefits for communities and business owners, which are important when considering public support of the pro- gram. WCHD inspects approximately 3,500 food establishments annually, a number that continues to increase alongside the thriv- ing food culture of the area. AMC program implementation supports the unique quali- ties of the community, such as local business ownership and diverse food oerings. Incor- poration of the AMC program in enforce- ment policy provides a more financially accessible and feasible solution for opera- tors of nonchain establishments who are typically not supported by the same internal food safety protocols and economies of scale associated with chain establishments (Lein- wand et al., 2017). By oering AMC program training courses and toolbox materials in languages other than English, AMC policies can encompass cultural food practices that might not be otherwise captured and can improve public health equity across jurisdictional demo- graphics. Like most of the country, food establishments in Washoe County have felt the financial pressure of rising food costs.
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by MCESD to inform a clear and compelling vision for its own program to be instituted in Washoe County. Results of a self-assessment conducted in 2021 for the Voluntary National Retail Food Regulatory Program Standards (FDA, 2023b) determined that WCHD does not possess ade- quate resources to enact its proposed compli- ance strategy of providing on-site food safety training to operators outside of the corrective actions required during routine inspections. Akin to many jurisdictions nationwide, the food safety enforcement policy at WCHD embodied the historically reactive nature of food safety regulation. Washoe County food establishments with multiple and/or repeat critical violations observed during routine inspections are subject to reinspection. If additional reinspections are warranted, each is associated with a fee to be paid by the food establishment operator. Despite sporadic success in reducing observed violations, the inspection and reinspection enforcement cycles introduce a wide margin of opportu- nity for foodborne illnesses to occur due to underemphasizing the development of pre- ventive food safety policies and long-term compliance with regulations (FDA, 2023a). Identifying the simultaneous need for a more ecient use of agency resources and proac- tive approaches to achieving compliance guided WCHD’s development of AMC pro- gram components that ensure success. Modeled after MCESD, the AMC pro- gram for WCHD (2023) is comprised of a
training course and online toolbox geared toward establishment managers or those individuals with the ability to enact change in a facility. When used in conjunction, the AMC training course and toolbox pro- vide instruction and resources for creating meaningful food safety management sys- tems—called AMC policies—that lead to sustained AMC. In an analysis conducted by FDA (2018), food establishments with well-developed food safety management systems were associated with fewer risk factor violations than those establishments with underdeveloped food safety manage- ment systems. Well-developed and eective food safety management systems generally consist of detailed food safety procedures, along with consistent training and monitor- ing practices (Brown, 2021). The AMC program training course instructs establishment operators on use of the procedures, training, and monitoring structure to create AMC policies that are spe- cific to their facilities. AMC toolbox materials and worksheets—including an editable policy template and sample policy language—guide operators through the procedures, training, and monitoring structure, further empower- ing operator confidence in developing AMC policies. As a whole, the AMC program is designed to support AMC policies developed by managers that are informed by input from sta stakeholders, specific to operations of the facility, and adaptable to change as nec- essary (Maricopa County Environmental
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July/August 2023 • <B?;.9 <3 ;C6?<;:2;A.9 2.9A5
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