Learn more about how the Regional Municipality of York explored and implemented a bylaw in their region mandating food handler certification for food premises.
Promoting evidence-based food handler legislation in York region (February 2020)
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Featuring:
Promoting evidence-based food handler legislation in York region
Chetna Pandya & Caitlyn Paget
February 26, 2020
1:00-2:00 PM EST
Funded by the Public Health Agency of Canada | Affiliated with McMaster University
Production of this presentation has been made possible through a financial
contribution from the Public Health Agency of Canada. The views expressed here do
not necessarily reflect the views of the Public Health Agency of Canada.
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13. What is Food Handler Certification (FHC)
and why offer it?
Mandates:
The Ontario Public Health Standards (2014)
and Food Safety Protocol (2013)
Promote: that at least one certified food
handler be present at the premises during all
hours of operation for all high and moderate
risk food premises
Haines Report 2002
14. There is no I in Team – Various disciplines
made up the team
Multiple disciplines and stakeholders took part in undertaking the FHC
bylaw.
Food safety manager
Epidemiologist
Senior public health inspector (PHI)
FHC committee
Food owner/operators
Health educators
15. Creation and implementation of a bylaw is
a complex project, which can be broken
down into multiple decision points.
To pursue
bylaw
Bylaw
criteria
Unintended
consequences
Bylaw
implementation
Adapt to new
regulations
16. Each decision was informed by the most
relevant evidence; overall the project
synthesized all types of information.
Public Health
Expertise
Public Health Resources
Community Health Issues,
Local Context
Community and Political
Preferences and Actions
Research Evidence
18. Started by looking for all available
evidence about the impact of FHC on
food safety outcomes.
Public Health
Expertise
Public Health Resources
Community Health Issues,
Local Context
Community and Political
Preferences and Actions
Research Evidence
19. There was no conclusive best practice
about mandatory FHC, based on the
available research.
Academic Literature:
Systematic search
No evidence
available about a
mandatory bylaw
Three strong review
articles about food
safety training to
improve knowledge
and practices
Grey Literature:
Peel Public Health
conducted a rapid
review, concluding a
lack of evidence
NCCEH had an
excellent summary
of the evidence
around inspection
programs, not FHC
Environmental Scan:
8 Ontario Public
Health Units had
mandatory bylaws
No evaluations yet
(bylaws were new)
20. A retrospective study of York Region
inspection data was done to explore the
local context of food handler certification.
2011-14
Compare
available food
safety
outcomes.
Categorize
premises by
food handler
status.
Summarize
inspections
for each
premises.
Extract four
years of
inspection
data.
Record FHC
presence
during
inspections.
21. FHC was consistently associated with
better food safety inspection outcomes,
throughout the four years of data.
% Premises with Enforcement Activities
Assessed multiple types of
inspection outcomes:
Presence of infractions
Average # of infractions
Critical infractions
Enforcement activities
Due to small sample size,
could not study food borne
illness rates or outbreaks.
22. A limitation of the retrospective cross-sectional study design is that it cannot
determine if there is a causal relationship.
Although FHC is correlated with better
food safety outcomes, we cannot
conclude whether or not FHC is the
cause.
OUTCOME
Food Safety Outcomes
EXPOSURE
Food Handler Certification
CONFOUNDER ?
Premises Culture
?
23. Mandatory food handler certification had
strong support from both York Region
residents and public health inspectors.
97%
of York Region PHIs supported
mandatory food handler certification.
In 2015, surveyed our Public Health
Inspectors (PHIs) to understand
their perception of certification.
88%
of York Region residents supported
mandatory food handler certification.
Estimated community support using
2014 Rapid Risk Factor Surveillance
System (RRFSS) telephone survey.
25. The specific bylaw criteria were informed
by looking at both our inspection evidence
and bylaws from other jurisdictions.
Public Health
Expertise
Public Health Resources
Community Health Issues,
Local Context
Community and Political
Preferences and Actions
Research Evidence
26. During the four study period, infractions
were less common at premises with a
certified manager, and consistent
presence. Premises with
Infractions
Premises with
Critical Infractions
Average # of
Infractions
Both certified manager and handler on staff.
Certified staff present at all inspections. 20% 8% 1.7
Certified staff present at all inspections. 29% 15% 1.9
Both certified manager and handler on staff.
40% 16% 2.0
At least 1 certified staff member (in any role). 46% 19% 2.2
No certified staff. 49% 22% 2.2
27. Making the most of the eight bylaws –
what criteria to use to best fit York
Region’s needs, and our local evidence.
Eight health units with variances in each of
their bylaws
Niagara and Toronto Public Health were
the most stringent in their requirements
Niagara best aligned with York Region
Only high and moderate risk premises
were to be impacted
Transition period for implementation
Brant Halton
Hamilton Lambton
Middlesex -
London
Niagara
Peterborough Toronto
28. A Report to Council summarized the
evidence and implications; the bylaw was
enacted and passed on September 24,
2015.
Link or navigate to: york.ca > About York Region > Bylaws
30. Bylaw implementation required
coordination support for the community of
food handlers and premises
owner/operators.
Public Health
Expertise
Public Health Resources
Community Health Issues,
Local Context
Community and Political
Preferences and Actions
Research Evidence
31. Prior to bylaw implementation, the FHC
program was enhanced based on
consultations with food premises.
Feedback from Food Premises Owners/Operators:
Providing Selection in Course Modalities
Workshops Online Self-Study
Improving Scheduling
Evenings Weekends
32. Phased in approach by food premises risk
categorization, to focus resources
where they would have the highest
impact.
Preparation
2014 and earlier
- Assessing Evidence
- FHC Enhancement
2015
- Report to council
High Risk Premises
2016 (Year 1)
- Education
2017 (Year 2)
- Enforcement
Moderate Risk Premises
2017 (Year 1)
- Education
2018 (Year 2)
- Enforcement
33. Targeted communication campaign with
multiple components to inform and
support food premises owners/operators.
Stakeholder meetings
with owner/operators to
inform and for questions
Emails, letters and
postcards to all premises
Local advertisements
One-on-one education
during inspections
Reminders in advance of
bylaw enforcement
34. Most high-risk premises were in
compliance with the bylaw partway
through 2016, with moderates following in
2017.
36. FHC was adapted for adults with
intellectual disabilities, to support a
vulnerable population as the bylaw
impacted jobs.
Public Health
Expertise
Public Health Resources
Community Health Issues,
Local Context
Community and Political
Preferences and Actions
Research Evidence
37. By implementing a bylaw, was York
Region creating an unintended
consequence?
HEIA is a flexible and practical assessment tool that can be used to identify and address potential
unintended health impacts (positive or negative) of a policy, program, or initiative on specific
population groups.
NOTE: The HEIA Template is designed to be used alongside the accompanying HEIA Workbook,
which provides definitions, examples, and more detailed instructions to help you complete this
template.
Date: Workgroup meetings: July 21, 2015, August 26, 2015, September 2, 2015, September 17,
2015
Organization: York Region Public Health Branch
Contact: Becky Hester, Manager, Health Protection (905) 762-1282 x74689 becky.hester@york.ca
Project Name: Adaptation of Food Handler’s Certification Training for Adults with Intellectual
Disabilities
• Health equity
• Community interest
• Accessible program
• Meet population needs
• Evidence from research
38. New team working together to pilot an
adapted FHC program for York Region
community partner
Addition to team included public
health nurses, health equity
research specialist, community
agencies, and the participants
Engagement with community
partners
Consider different learning styles,
meet Ministry requirements of
food safety content and get
participants certified
40. Minimal impact from transitioning to the
Regulation from the bylaw
Bylaw advantage
Bylaw not rescinded
Communication and
education provided on
Regulatory requirement
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Funded by the Public Health Agency of Canada | Hosted by McMaster University
Production of this presentation has been made possible through a financial contribution from the Public Health Agency of Canada. The
views expressed here do not necessarily reflect the views of the Public Health Agency of Canada.
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5 slide intro
Requires health units to ensure food handlers in food premises have access to training in safe food-handling practices and principles
The OPHS also requires that we promote certification
In addition, Haines Report also recommended that the FPR adopt a mandatory FH training/certification
Some background information on YR’s Food Handler Certification.
Approximately 8 years ago, the Ministry standardized the food handler certification content based on a gold standard. From this, York Region took the new material and put a York Region flair on it.
Minimum content was to be covered in the in person, or workshop, training: role of the board of health; public health legislation; food safety management principles (HACCP); safe handling, preparation and storage of food; food handler hygiene; food premises sanitation, design and maintenance; and prevention of food allergies, incidents and response.
Working with the Ministry, a standardized 50 multiple choice exam was created, to ensure consistency amongst the province.
Our FHC course trains people working or wanting to work in the food industry on how to safely prepare food. In 2018, we had more than 5000 participants go through the program.
With language gaps and knowing the restaurant population, our manual has translated into Chinese and Tamil, in addition to having the Ministry’s French manual. With the Ministry French exam, we went one step further and translated our exams in Chinese, Farsi, Korean, Tamil and Russian. From staff resources, we were fortunate to provide Cantonese and Mandarin workshops on a yearly basis. This year with staff help, we held a Russian and Tamil workshop.
We have also accommodated people by adding afternoon, evening exam session, weekend workshops and online learning modules, by using our online registration system and having our internal call centre, Access York register as well.
Prior to the bylaw, York Region had been addressing a health equity gap with low income participants and those that are newcomers to the Region and partnering with agencies that service these areas by providing our course for free. Where those identified if there was a language barrier or required an accommodation (e.g., more time), our PHIs did their best to meet those needs.
Requires health units to ensure food handlers in food premises have access to training in safe food-handling practices and principles
The OPHS also requires that we promote certification
Food premises
Various means of learning
Different languages for tests
Availability to public
Online registration
Low-cost options
Chetna to speak to this
Our story is best told sequentially, talking about the different decisions throughout the larger project. For each decision, we considered different evidence to best suit the stage of the project…
Caitlyn speaks to this
This is a large project where we used a lot of different sources of evidence to inform our decisions.
For this presentation, we’re using the NCCMT’s model for Evidence-Informed Decision Making, and we will return to this diagram repeatedly to talk about the balance of evidence for different stages of the project.
10 slides
Community Health
PHACTS study – study of inspection results
Environmental scan at the time, Toronto had conducted an evaluation and that Hamilton was planning on doing one. After a period of adjustment when the bylaws were initially implemented, including communications and consultations with food premise operators and the public, the bylaws in these jurisdictions have been well received with minimal ongoing complaints. Many jurisdictions and operators have said these bylaws have been a positive change within the industry.
[Blue = Research]
Research bubble
Lit search
Conducted in 2013, where 3 strong systematic review articles were used
These documents concluded that interventions such as inspections and food safety training may lead to improved knowledge and practices of FH; enhanced food safety knowledge and behaviour among FH.
An environmental scan was conducted and found that eight health units were successful in implementing a mandatory FHC bylaw:
Toronto, Halton, Hamilton, Niagara, Brant, Middlesex-London, Lambton, and Peterborough
Each bylaw varied in requirements, but the goal was that food premises were to have a certified food handler at all times while in operation.
[Lime = Community Health Issues, Local Context]
Create a
[Lime = Community Health Issues, Local Context]
Our approach was to use the data that we had available.
Different available outcomes
Results were consistent!
[Lime = Community Health Issues, Local Context]
Correlation does not imply causation.
A possible confounder is the culture of the food premises, as those that care for food safety would be more likely to
Images:
Images may be added to any body slide at the discretion of the creator
Images should be high quality and in focus
Images should bleed colour on all sides so that they do not appear to ‘float’ on the slide
RRFSS
It was lucky that that we had the right questions asked at the right time
Very simple statistic, but also very powerful for our Report to Council to make the case for the bylaw.
5 slideds
Research:
The 8 health unit bylaws was used as a guide – choosing criteria that would be similar, yet meet the needs of YR
Toronto and Niagara: At least one Certified FH is present at the Food Premises to supervise the processing, preparation , storage, handling, display, distribution, transportation, sale service, or offering for sale of food at all times during operation
Niagara required that at a minimum, one operator and FH each have a valid certificate, where the FH would be onsite at all times of the operation.
Toronto required that all owner/operators be certified
Community and Political Preferences:
Reviewed bylaws and deemed that YR was to use Niagara’s as a guide
10 slides
Adapting our resources to support the implementation…
#6035530
In tangent and anticipation of the bylaw, a telephone survey was conducted to operators that didn’t have a certified food handler at their inspection in 2013. Goal was to register them over the phone and if they said no, what was the barrier
Location doesn’t work
Time doesn’t work
Too busy
Already use safe food handling practices
If the location didn’t work, operators preferred to have:
Weekend workshops
Evening workshops
Morning, afternoon or evening exam sessions
Online course
Resources:
Promotion was large part
Once bylaw passed, stakeholder meetings were conducted in the various municipalities to answer questions about the bylaw and to provide guidance on the criteria and where to become certified
Notification on our website, local newspaper, during PHI inspections, email and letters sent to all food premises
Increased number of exam sessions and one-day workshops to accommodate the influx of those needing to be certified
Afternoon and evening exam sessions offered at three of the five locations
Weekend workshops offered at three of the five locations
Online learning module created, making it easier for those that could not attend a one-day workshop
Developed online registration – no need to call in
Workshops offered in Cantonese and Mandarin – as resources were available
Translated Ministry exams into multiple languages – top four languages spoken in York Region: Chinese, Tamil, Russian and Farsi. Chinese and Tamil were identified as top 2 languages spoken in restaurants
Community and Political
Focus was to have high risk premises certified first (NEED TO EXPLAIN WHAT HIGH RISK MEANS!!! FIRST time mentioning high/mod in the slides.)
2016, year 1 was education
2017, year 2 was enforcement
Moderate risk premises had an additional year of education as there were more of these premises in the Region
2016-2017 was education
2018 was enforcement
Focus was on high and moderate risk food premises as they are more likely to have a foodborne illness, compared to a low risk food premises.
Risk is determined on the MOHLTC’s risk categorization, based on profile and performance factors
The Operational Approaches for Food Safety Guideline, 2019 details what the risk categorization is. The purpose of Ontario’s risk categorization of food premises approach is to prevent or reduce food-borne illness attributed to food premises. Food premises do not all present the same potential risk of causing food-borne illness, so a standard approach to risk categorization (high, moderate, or low) is necessary so PHIs can appropriately focus on premises that pose the highest levels of risk. Levels of risk are attributable to a number of factors including: • Profile factors such as those that consider the type of operation, population served, and the complexity and extent of food handling; and • Performance factors such as those that are attributable to the operators’ performance and commitment to food safety practices (i.e., compliance with regulations, commitment to training of food handlers, and the extent to which they incorporate food safety plans into their operations).
It is important to note that being a high risk premises does not necessarily mean it is a bad place to eat, it just means that there are factors that are weighted more. When in doubt check out the disclosure website for a recent inspection.
Resources:
Promotion was large part
Once bylaw passed, stakeholder meetings were conducted in the various municipalities to answer questions about the bylaw and to provide guidance on the criteria and where to become certified
Notification on our website, local newspaper, during PHI inspections, email and letters sent to all food premises
Increased number of exam sessions and one-day workshops to accommodate the influx of those needing to be certified
Afternoon and evening exam sessions offered at three of the five locations
Weekend workshops offered at three of the five locations
Online learning module created, making it easier for those that could not attend a one-day workshop
Developed online registration – no need to call in
Workshops offered in Cantonese and Mandarin – as resources were available
Translated Ministry exams into multiple languages – top four languages spoken in York Region: Chinese, Tamil, Russian and Farsi. Chinese and Tamil were identified as top 2 languages spoken in restaurants
Chetna only allowed 5 slides including title
YR had an internal health equity team of nurses looking to work with other departments to apply the HEIA tool
Interest from community partner to adapt FHC for those with ID arose simultaneously as YR went towards the bylaw
Going for a bylaw would hinder those looking for employment in the food industry
Research:
A lit search found working gave individuals a sense of community and able to provide financially
Health equity impact assessment (HEIA) tool was applied to this project, which assisted in our decision to go ahead with adaptation
Community Health Issues
We were approached by a few not-for-profit groups asking if we had an adapted program
Great opportunity to do a pilot project and work with our external partners on this venture
Community & Political
FHC was already providing the workshop for free to new comers and low income individuals, exams translated into many languages
Logical step was to provide program to those with ID
Resources
Did we have what it took to adapt the program when not have worked with this population
public health nurses (PHNs) that specialize in the social determinants of health in the Health Equity Program
an evaluation specialist and a health equity research specialist, Dr. Ingrid Tyler from Public Health Ontario
Worked with community partner to better understand need of group – some could not read, write or have ever written a test
Needed to incorporate different learning styles
Taking a one day WS and breaking into smaller learning modules – feedback from participant
More interaction
Different ways to do a test and not calling it that
Using clickers to obtain answers for the exam
Additional staff resources from public health and the community partner
Needed to ensure needs of the group were being met and still meet the Ministry requirements (Guidance Document for the Provincial Food Handler Training Plan) in providing the minimum required content for food safety
We knew there was a gap for those with disabilities, specifically intellectual disabilities, wanting to do our course, but the struggle was how to accommodate them in our workshop and ensure that
they could pass the exam.
This was all set up in preparation for when the bylaw passed.
Have worked with high schools, as it was easier to incorporate our program into their school day and schools could see the benefit.
Each group is unique and the program is modified to meet each one
No on shoe fits all
I personally met one of the original participants working at a McDonald’s booth at a SE.
Chetna only allowed 5 slides including title
As Bylaw was implemented in 2015, YR had a head start and the majority of our premises had a CFH, therefore it was a relative smooth transition
YR bylaw is more stringent that the Reg and was not rescinded
Can still issue a ticket under the bylaw if needed
Other health units are not planning on rescinding their bylaws
Additional communication was sent to our operators, educating on the Reg requirements
Email, letters, by PHIs during inspection
Every operator of a food service premise shall ensure that there is at least one food handler or supervisor on the premise who has completed food handler training during every hour in which the premise is operating.
Changes:
Not based on risk of a premises, but definition of a food service premises
any food premise where meals or meal portions are prepared for immediate consumption or sold or served in a form that will permit immediate consumption on the premises or elsewhere
Education on this was required as some premises under the bylaw did not require a CFH, now did under the Regulation