How to Correct Critical Violations

“Eat at Your Own Risk,” a series aired by CBS Chicago last September, indicated that the City of Chicago found 15 percent of popular restaurants and over two dozen franchises faced critical violations. These violations are based on state defined specifications and the predetermined corrective actions.

On the surface it seems that the corrective actions solve critical violation problems. Critical violations reoccur, primarily because the practiced model of corrective actions does not prevent the likely repeat of the critical violation on another occasion. The accepted practice is that the corrective action “fixes” the violation to return to service or operating parameters. What is needed is a method on how to correct the violation, so that there is little likelihood of a re-occurrence.

HACCP provides the basis for monitoring the parameters for managing hazards at critical points. The concept of a corrective action is also embedded in the HACCP format, and seemingly, because of the “fix” tradition of the “corrective action” for violations, there is no strategy for re-occurrence prevention. Thus the same violation re-occurs over and over. An example of the practice is demonstrated by the laws of Sonoma County – Health Services#, which lists over 40 explanations of critical violations with appropriate corrective actions. This is against the background of the California Uniform Retail Food Facilities Law. The violation / corrective action demonstrated does little to impact on maintaining the prescribed conditions.

New Thinking

Corrective actions are meant to avoid reoccurrence of the violation. This thinking is found in the quality management systems known as plan, do, check and act (PDCA) and is the foundation of ISO 9001:2000. Essentially PDCA through corrective action drives continual improvement. The concept is intended to reduce non conformances, as time progresses.

Continual Improvement is facilitated by having an understanding of the root cause of the violation and making the correction at the root cause. It is usual to investigate this by asking the question why, successively until the cause is found. Generally by the time the 5th why is reached the answer is found.

So let us explore the Sonoma County violations, using the root cause methodology:

• Why is the refrigerated storage inadequate?
  Possible answer: The refrigeration gas was not being monitored
• Why was it not being monitored?
  Possible answer: There was no schedule
• Why was there no schedule?
  Possible answer: There was no maintenance program
• Why there was no maintenance program?
  Possible answer: None was put in place

Therefore, the root cause of the violation is lack of maintenance, and the corrective action is to implement a maintenance program to include a weekly and monthly check of refrigerated parameters.

This methodology, if adhered to, is likely to maintain the correct temperatures and prevent reoccurrence of the violation. The corrective action is nothing more than the scientific specifications to be maintained to avoid the hazard. It makes sense to have a corrective action based on the root cause, rather than identify the correction of the violation as the scientific specifications. The corrective action as shown by the county does not provide the opportunity to avoid the violation over time. The root cause analysis, however, does.

Although one of the seven elements of HACCP is the corrective action, it is likely that its intent is to utilize the root cause methodology. Compliance can only be served by continual improvement. If the continual improvement methodology is not implemented, organizations will continue to be in the violations / fix (corrective action) cycle. The “fix” is not a corrective action as defined within quality management systems.

The Continual Improvement Concept

The real root cause of the issue leads to a meaningful corrective action. Also, apart from the receiving department and as a critical control point, all other critical control points per process types are likely to have equipment to execute the respective process. This means that the following features should be available to establish the means to correct the critical violations via an improvement strategy: Preventive/monitoring procedures by way of checklists, “lock out/tag out,” to deal with any electrical related issues on equipment.