NEHA April 2024 Journal of Environmental Health

Forensic The forensic inspection is unique. The back- ground information is generally provided by the client and is already well-documented. Your role is to objectively verify and expand on this information within your scope of knowledge and skill, and identify any erro- neous or false environmental health-related materials that could bias arguments and con- clusions. Most typically, the forensic inspec- tion is conducted as a part of litigation or an insurance-related issue. Unlike the regulatory compliance inspec- tion that provides a snapshot of a facility at the time of the inspection, the forensic inspection relies on time-dependent observa- tions that detail both the temporal and spatial changes in the environment and reconstruct the conditions that prompted the review. It is your responsibility to present substantiated data for use by the client. To accomplish this inspection, there is a reliance on the exten- sive use of calibrated or validated field instru- ments and verifiable sampling protocols. The inspection itself has three requirements. 1.The first, and most important, is to avoid bias. A true and scientifically correct pre- sentation significantly aids the case for the client. 2.The second requirement is to ensure that the data collection—including observa- tions and field sampling—is repeatable and supported by good practices and verifiable methodologies. This requirement is neces- sary to avoid challenges to your work by opposing counsel and experts. The most useful guidelines to meet these challenges are detailed in two military standards (U.S. Department of Defense, 1989, 2000) and a compendium of standard methods (Salfin- ger & Tortorello, 2015). Together, these resources provide the necessary informa- tion for designing the sampling strategies and statistical support of the inspection, as well as detailing sampling techniques, preserving samples, and maintaining the chain of custody of the samples. 3.The third requirement is to keep the entire exercise (i.e., research, fieldwork, report, and conclusions) within your area of expertise, which is known as the Daubert standard. This standard provides a systematic frame- work for a judge to assess the reliability and relevance of your testimony as an environ- continued on page 47

tion history. Similar strategies can also pro- vide additional oversight for potable water, wastewater, built environments, waste man- agement, and vector control. Auditing The American Society for Quality (ASQ) defines auditing as an on-site verification activity, such as inspection or examination of a process or quality system to ensure compliance with requirements. Unlike the compliance inspection that is formally structured, the audit diers by employing a formal process. This prescribed process involves four phases of the audit cycle: 1) planning and preparation, 2) execution, 3) reporting, and 4) follow-up and closure. These follow a sequential order of activities detailed by ASQ in a standard(International Organization for Standards, 2018) and handbook (Coleman, 2020). Auditing is the fastest growing, highest demand, and most lucrative opportunity for environmental health professions and sani- tarians. The market for environmental health auditors is expanding exponentially. Primary customers include industries in certain high- risk categories that seek certification to meet foreign requirements or accreditation. Addi- tional trends in this industry include clients who seek value-added assessments to prevent litigation and product recalls. Still others seek follow-up audits for products, processes, or systems that need guidance for corrective action or verification of established criteria required by their customers or even regula- tory agencies. In August 2022, the Food and Drug Ad- ministration issued the Voluntary National Retail Food Regulatory Program Standards. This program is designed to achieve national uniformity among regulatory programs re- sponsible for retail food protection. It will re- quire audits of retail food program standards and has set criteria for auditors. This require- ment within the program will be an up-and- coming opportunity for us. Basically, audits objectively evaluate estab- lished criteria such as policies and proce- dures that are provided by the client. It is your responsibility to verify that the criteria detailed in these documents are met in prac- tice. You also assist the client in assigning performance expectations (i.e., percent com- pliance) to each policy.

accommodate new equipment; modifications to electrical outlets, wiring, and circuit break- ers; and remodeling structural changes. When you see these conditions, consider asking for professional assistance from building, electri- cal, plumbing, and fire inspectors to ensure that the whole of the environment meets cur- rent code requirements. You may also ask for assistance from a medical professional such as a public health nurse to help assess conditions and processes that are not specified in codes. These con- ditions and processes could include critical perceived health risks in institutions and businesses such as long-term care facilities, gyms, childcare centers, and facilities that oer body art services. Before we leave the regulatory compliance inspection, you may want to consider the scope of coverage. Again, using the example of retail food, the average full-service res- taurant operates approximately 16 hr/day. During this time, there are two overlapping operations that can dier somewhat in activi- ties and tra‚c patterns: 1) preparation and sanitation and 2) full service with custom- ers. Each operation, however, has an impact on food safety. Assuming that the restau- rant is open 6 days a week, this represents approximately 5,000 hr of operation a year. If you conduct four inspections of that facil- ity within that time, and each inspection takes approximately 1 hr, you have only seen 0.0008% of what that restaurant does. There- fore, you may want to consider varying the times to observe the entirety of the operation and its food safety practices. You may also want to consider a variant of the multimedia inspection that specifi- cally uses your expertise. Again, using the food model, consider doing an abbreviated plan review to ensure that the facility can safely accommodate the items on the menu (Conference for Food Protection, 2016), a street HACCP (hazard analysis critical con- trol point) audit on selected high-risk tem- perature sensitive foods (Powitz, 2005), or an active managerial controlplan (Vaccaro, 2013). These additional initiatives are par- ticularly useful in assessing traditional and unique food handling practices and prepara- tion techniques used in the growing number of restaurants oering authentic ethnic cui- sine. These are also indispensable tools for assessing facilities with a checkered inspec-


April 2024 • our9-l o2 9@5ro9me9>-l e-l>4

Powered by