March 30, 2017 Meeting

Attached you will find the proposed changes to the Illinois Food Code, and proposed Food Inspection Form.
Here are some highlights of the meeting.

Legislation
HB2510 - Allergen Safety - IDPH is in opposition with the Illinois Restaurant Association in support.  When asked, the IRA rep said their restaurant members were in support.

HB3063 - Cottage Food - IDPH is now in support after agreement reached with parties involved.  When asked who the parties were IDPH it included Stewardship Alliance, NIPHC, IPHA, and IAPHA.

HB3684 - Sanitation Certificate - IDPH is in opposition.  The main opposition is no accountability to assure training prior to the test.  Currently rules require proctors to assure that training has occurred prior to testing with no change to this.  When getting their certificates online, applicants are required to mark a box saying they have taken training.  This replaced the training assurance form completed by an instructor given to a proctor and included with the scan sheets to IDPH to assure training prior to testing.  IDPH removed this check when they went to an online certificate.

SB1662 - Pasteurized MIlk (Raw Milk) - IDPH is in support with Stewardship Alliance.  Everyone else is in opposition.  Enough said.

OK - where do we incorporate the plumbing code? Where do we account the Priority and Priority Foundation violations in the "Good Retail Food Practices"

Why can't we just change this to the number of priority risk factors, # of priority foundation and # repeat violations?

The Illinois Plumbing code is adopted in 750.5.

Accounting for Priority Foundation, Priority and Core interventions is within the scope of enforcement procedures and policy's adopted by the LHD. Guidance on this in Chapter 8 of the 2013 FDA Food Code. The question becomes, are enforcement procedures based on the interventions or risk factors. I think this is where we should seek out the experiences that are currently utilizing the FDA Food Code and Inspection form the way designed by FDA in a workshop setting to begin the path of a working document for LHD's to utilize. My personal opinion should be to base enforcement on Risk Factors since that is what the inspection form tracks, not interventions since they can be General Manufacturing Practices. Yes this would require LHD's to change inspection mindsets but that has to occur with the mindset IDPH has adopted inspection protocol.

I support reviewing activities in other states - none of us have time to re-invent the wheel.

We love to learn new things but resist diving backwards in time as we do so.

One question is - are we trying to actually incorporate the Illinois Plumbing Code in any way?

Non-potable water in our area presents a huge risk factor. Perhaps other areas don't have experience with private wells and weekend plumbers who know nothing about back-flow. Once again, the FDA FOOD CODE was meant as a GUIDE to build upon.

As always, thanks for your prompt response and sharing!

The Illinois Plumbing Code is adopted in the Illinois Food Code, Section 750.5. The Illinois Plumbing Code has precedence if conflicts exist with the FDA Food Code.

but the way the inspection violations are recorded, this violations are not even accounted unless they are repeats.

How can we travel backwards with our knowledge of sewage back-ups in ice machines causing food-borne illnesses? Why is that not then a risk factor? I just can't assign these the same weighting as tears in vinyl seating.

Mary Cooper and Craig Bussman have asked IDPH to send a representative to our meeting next Thursday on enforcement concepts.

I just can't buy this format in total.

Yes, our mindsets have to change: focus enforcement on Risk Factors especially the Repeat Risk Factors--no score.