NEHA May 2024 Journal of Environmental Health

2013). This criticism, however, can be over- come by devising an appropriate inspection methodology that captures both capability and capacity for establishing and maintain- ing control and gives rise to comprehensive criteria to determine control. This result highlights a dichotomy of food safety inspection ideology. The first ideol- ogy is a traditional regulatory-based compli- ance check where the inspection is aimed at assessing compliance of a food business with established compliance criteria. This type of inspection is largely confined to assessing food handling practices and food production envi- ronments of the food business to meet criti- cal limits or required conditions at the time of inspection (Gri†th, 2005; Yapp & Fairman, 2005). Such an approach assesses the capabil- ity of the food business to meet compliance criteria or critical limits or conditions. The second and alternative ideology is a food safety risk assessment where the inspec- tion is outcome-focused and aimed at assess- ing the capability of the food business not only to meet critical limits or required condi- tions but also to reliably and sustainably meet critical limits or required conditions beyond the time of inspection (Green & Kane, 2014). While a compliance check provides a point- in-time assessment of the capability to com- ply, a food safety risk assessment can tran- scend time by assessing both capability and capacity to meet and sustain safe practices and conditions. The principles of hazard analysis critical control point (HACCP) planning provide a sound foundation for establishing decision criteria required for a comprehensive assess- ment of contamination control. The seven HACCP principles are: 1.Conduct a hazard analysis. 2. Determine the critical control points (CCP). 3.Establish critical limits. 4.Establish a monitoring system. 5.Establish a procedure for corrective action when monitoring at a CCP indicates a deviation from an established critical limit. 6. Establish procedures for verification to con- firm the e“ectiveness of the HACCP plan. 7.Establish documentation concerning all procedures and records appropriate to these principles and their application. The principles integrate a systems approach, guiding food producers in planning for sus- taining safe food production (Food and Agri-

culture Organization of the United Nations, 2002). Although it is designed for planning and quality control applications, the HACCP principles give a basis for developing inspec- tion criteria that consider control beyond a point in time. Thus, building on the seven HACCP principles, decision criteria for the control of contamination should include the following seven lines of inquiry: 1.Can the critical limit/conditions be met? 2.Is the procedure adequate for the critical limit/conditions to be reliably met? Has it been validated? 3. Is the procedure known and understood? 4.Are the critical limits/conditions and dimensions of the hazard understood? Does it provide for adequate motivation? Can sta“ identify key safety determinants? Would sta“ be able to determine suitable corrective actions or select suitable proce- dural alternatives? 5.Is the procedure reliably and faithfully enacted? 6.Is the procedure enactment, critical limit/ condition, or critical limit/condition proxy monitored? 7.Is the method of monitoring accurate and reliable? Adopting these seven criteria provides for a more naturalistic inquiry by returning the object of inquiry back to its natural position- ing within its social and environmental context (Lincoln & Guba, 1985). Examining these decision criteria should be the subject of fur- ther research, particularly in establishing their relative weight as decision-making criteria. The UK already widely uses HACCP prin- ciples in select ways to underpin food safety inspection approaches (Barnes & Mitchell, 2000; Green & Kane, 2014). Although the results of our research still indicate further integration of the principles in evidence gathering is required, respondents from the UK reported examining a more comprehen- sive suite of food safety hazards than other countries. This finding was demonstrated with statistically significant relationships in the areas of examining cooking adequacy, allergen control, water treatment, inherent contamination sources, and seeking evidence of adulteration. Despite some country-specific nuances that place regulation of particular food safety hazards in the domain of other authorities, significant historical food safety events might

Sarantakos, 2005). The methods for examin- ing food safety described by inspectors align closely with data-gathering methods common to qualitative field research. These methods include observational techniques, documen- tation and artifact analysis, interviewing, and the maintenance of field notes (Bailey, 2007; Patton, 2002; Schwandt, 2001). The findings of our research indicate that inspectors are generally aware of food safety hazards that might be present in a food busi- ness. Furthermore, inspectors are deploying a variety of relevant data-gathering methods to inform their examination of the extent of control of food contamination. We found, however, some methodological incongru- ence prevailed, which included a lack of comprehensiveness of evidence collected, the use of incompatible evidence to deter- mine the adequacy of contamination con- trols, and no mechanisms to overcome bias in making determinations. A Lack of Comprehensiveness The first source of incongruence pertains to insu†cient data being gathered to make a comprehensive determination of the extent of control, which is likely due to a lack of clarity in the research aims and objectives being ascribed to food safety inspections, or a lack of research aims and objectives alto- gether (Morse, 1994; Thomas & Hodges, 2010). A lack of adequate data gathering has been identified in other investigative disci- plines, where it has been suspected as lead- ing to false conclusions of causality (Drury et al., 2000; MacLean, 2022). For food safety inspections to be a viable health protection measure, inspectors must determine if food contamination is adequately controlled and if this control can be reliably sustained. Survey responses show that inspectors are determining the adequacy of control on some but not all necessary criteria. While criteria that relate to the capability of a food business to control contamination are being regularly examined, that is not the case for criteria relating to the capacity of the food business to sustain control over time and various circumstances. This finding resonates with a long-standing criticism that food safety inspections provide only a snapshot-in-time and have a significant e“ect on the utility of food safety inspection as a health protection measure (Fleetwood et al., 2019; Powell et al.,

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