When inspectors from USDA or FDA observe objectionable conditions in a food processing facility, those observations often find their way onto USDA Noncompliance Report or Notice of Intended Enforcement, or a FDA Form 483 or Warning Letter.

Indeed, while industry hopes to weather routine inspections without drama, the fact remains that when governmental inspectors fan out inside of a facility to conduct an inspection, there are an unlimited number of the potential conditions that could result in an alleged violation of the food safety regulations.

Putting the difficulty of passing such an inspection without a finding of any violations into the proper context can be difficult. Perhaps the best way to put things into the right perspective is to think about your own kitchen at home. Indeed, consider, for a moment, whether your own kitchen would pass scrutiny if USDA or FDA decided to pay you a visit to ensure the food you were preparing for your family was as safe as it could be.

It doesn’t take much to imagine the sinking feeling one might feel if federal inspectors knocked on the door, politely displayed their credentials, and asked to come in. “Good evening, I’m from FDA, and I’m here to inspect your kitchen, may I come in?”

Without a conference room, you promptly make room on the dining room table serve as the inspector’s “home” for the duration of the inspection. Before the inspector can unpack, she is asking to review your food safety documents for the previous six months. You shrug your shoulders, and out comes the clipboard and the pen.

Failure to establish or implement a written food safety plan.

You start to get a really bad feeling. Her next question is, “When was the last time you used the self-cleaning feature on your oven?” You pretend to have to think about the answer for a moment, then look down and shrug your shoulders for a second time. Clipboard and pen.

Failure to appropriately clean and sanitize equipment.

After crawling around on the floor with a flashlight for what seems like hours, she opens the refrigerator and pulls out two seemingly identical jars of grape jelly. “Can you tell me what the difference between these two jars is?”

“No ma’am, I cannot.”

“This one expired two years ago.” Clipboard and pen.

“I’m almost done,” she tells you. “There is just one other thing, I need your help pulling this fridge away from the wall so I can take some environmental swab samples from the floor back there. I’ll also need some from inside the garbage disposal and the cabinet under the sink, too…”

While this scenario is offered mostly in jest, I hope it demonstrates the monumental difficulty of keeping commercial food processing facilities compliant with the rigorous standards they face. How many of you would pass an FDA inspection of your home kitchen at this moment? Perhaps very few. Fewer yet if the inspection occurred while you were in the middle of cooking Sunday dinner.

Yet, that is what every USDA and FDA registered food facility is expected to do. Each and every day. For the most part, they do so successfully. And, for that, industry has earned and deserves our appreciation. Keep up the great work, and good luck on your next inspection.

Would your own kitchen pass a routine inspection?

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