Interventions

Interventions include a variety of activities that the Kansas Department of Helath and Environment (KDHE) Food Safety Program employs to assist and encourage food establishments to maintain managerial control of food safety procedures that could result in a foodborne illness if left unchecked. Several routine interventions occur during an inspection and include the following:

• correction on-site (COS) of violations, if possible, while the inspector is present
• providing food safety handouts and educational materials during the inspection
• demonstration of correct food safety procedures such as the rapid cooling method using an ice bath
• informal consultation/exit interview at the end of the inspection to discuss violations, remediation and answer questions
• Food safety training on-site or off-site.

Other interventions may be utilized when the violations continue or for critical violations that may place the public at unnecessary risk of foodborne illness or injury. These interventions are grouped into two categorizes - 'A' and 'B.' Category designation is a program designation and used for ease in identification. The categories are 'compliance progressive' and directly relate to the need to ensure that the best food safety practices are employed to protect the health of consumers.

Category A Interventions may include the following activities:

• Notice of Non-Compliance: The notice reminds the establishment that substantial compliance is required and it establishes a time for a reinspection.
• Risk Control Plan: This intervention is recommended by the inspector and is voluntary on the part of the establishment. It identifies specific food safety procedures that need controlled by the establishment. It sets up a method of maintaining control of food safety procedures, and it provides food safety education to the establishment.
• Hazard Analysis Critical Control Point Survey (HACCP): HACCP is similar to the Risk Control Plan but on a much larger scale. The inspector conducts an extensive survey that identifies the flow of food preparation and the process used in the establishment. The survey is presented to management of the establishment and best operating practices are recommended for optimum managerial control of food safety risk factors.
• Warning Letter: This letter is sent to the establishment encouraging them to come into voluntary compliance with food safety regulations and to maintain managerial control of food safety issues. It is generally sent after an administrative review if recent inspections indicate that substantial compliance with the food code has not been achieved or when other enforcement activities are not yet suitable. It establishes an increased inspection frequency based on past performance for numerous or repeated violations of the Kansas Food Code.
• Voluntary Closure: Management agrees to voluntarily close the establishment for a short period of time to devote time to the correction of critical food safety issues.

Category B Interventions may include the following activities:

• Formal Consultation: This intervention generally takes place in Topeka and may be used to discuss on-going food safety issues or to agree upon specific actions that need to be implemented to improve standard operational procedures. The goal is an increase in managerial control resulting in substantial compliance with food safety standards.
• Administrative Penalty: An intent to impose a civil penalty (fine) may be issued when a re-inspection shows that the establishment remains in non compliance with repeated critical violation. There is an appeal process that may lead to a hearing or settlement.
• Intent to Suspend License: An Intent to Suspend a food service license may be issued after a civil penalty if the establishment remains in non compliance with repeated critical violations. It may be issued as a stand alone intervention in some serious circumstances. There is an appeal process that leads to a hearing or settlement.
• Temporary Emergency License Suspension: The Emergency Suspension is issued to protect the public in the case of a serious imminent health hazard. There is no appeal process.
• Intent to Revoke License: License revocation is an intervention used when other enforcement activities have not succeeded and when serious food safety issues continue to be repeated with no management resolution forth coming.
• Intent to Deny License: An intervention that is employed when an establishment cannot meet licensing requirements that ensure food safety for consumers.