Food Safety 101

A number of factors will ensure the proper protocol is followed.

Consider this: according to a study by the Atlanta-based U.S. Center for Disease Control and Prevention (CDC), one in six delis had a refrigerator that was too warm; one in four delis had sanitizer solutions at improper concentrations for cleaning surfaces that come into contact with food; three in five delis had slicers that were damaged; about half of delis did not fully clean the slicers every four hours; and only one in four delis reported inspecting slicers for damage every four hours.

The CDC estimates that each year one in six Americans get sick from contaminated food or beverages and 3,000 die from foodborne illness. The U.S. Department of Agriculture (USDA) estimates that foodborne illnesses cost the United States more than $15.6 billion each year.

These statistics emphasize the importance of putting food safety at the forefront.

The Current Climate

With today’s supply chain interruptions, one of the most important aspects is checking in with food vendors to ensure food is kept safe during transit.

“You also want to make sure your vendors and suppliers are not implementing unauthorized substitutions and, if they are having to alter ingredients, that they are being transparent,” says Janet B. Rowat Kraiss, technical director, The Suter Co., Sycamore, IL. Half of the company’s business is in private label refrigerated ready-to-eat salads.


At press time, COVID concerns also remained top of mind.

“For the most part, the pandemic has impacted operations at the retail level by restricting the number of people at a manufacturing facility,” says Brian Kellerman, co-founder and chief food safety officer of Kellerman Consulting, Columbus, OH. “Because the virus is not foodborne, the risks are just communicable between people, so there have been no changes from a food safety standpoint.”

Matt Regusci, director of growth and public relations at ASI Food Safety, St. Ann, MO, and an expert in food compliance for two decades, agrees COVID can’t be passed on from food or consumed, which is a good thing.

“What we’ve seen is a lot of turnover, with kitchens having a hard time staffing people,” he says. “If you don’t have the right COVID protocols in place, people will get sick and be absent from work.”

This means lack of training for substitute and new employees may hinder food safety regimens.


“If people are constantly coming in and out, even if everyone is trained, the issue is the constant reminders and adherence during busy periods,” Regusci says. “If [food safety] is not part of muscle memory, shortcuts can happen; this is when people get sick.”

In the past, it was OSHA (Occupational Safety and Health Administration) that oversaw workplace safety, but now it’s also about being COVID-conscious.

“Companies are being forced to pay attention to COVID since it’s related to worker safety,” says Jeff Nelken, a food safety expert and consultant based out of Woodland Hills, CA. “[At the beginning of the pandemic], I sent a letter to our suppliers saying I wanted to know what COVID rules they are following and the training they received.”

Top Safety Concerns

Experts and information from the CDC concur that temperature control is high on the list of issues when it comes to food safety in supermarket delis.

“Storage areas need proper temperature control,” Rowat Kraiss says.

By the same token, FIFO (first in, first out) is key to ensuring product doesn’t bypass its shelf life date.

“Rotating stock is very important [to circumvent expiration problems],” Rowat Kraiss says.

Like temperature control, employee hygiene and overall store sanitation should not be overlooked.

“Behind the glass it’s about employees washing hands before food handling or when in contact with allergens,” Rowat Kraiss says. “Employee hygiene practices make the difference, as you don’t want to trace outbreaks to your store.”

“One of the biggest issues is if there is a commissary operation off site,” Kellerman says. “When we work with grocery stores, they have a low bar to clear for food safety.”

He adds that the requirements in this case are similar to restaurants, as both types of operations are regulated by county health departments.

“Delis need basic temperature control and proper food handling,” Kellerman says. “But when it’s a commissary operation, which is more popular, the rules get more significant, and there are multiple regulatory agencies overseeing it like the Department of Agriculture and health department.”

He agrees that, if food is being made on site, staff training is a crucial component of food safety.

“Also, good handwashing practices and making sure thermometers are calibrated properly [are key],” Kellerman adds.

Listeria, which can be a source of illness and outbreaks from sliced deli meats, causes the third highest number of foodborne illness deaths in the U.S. annually.

“This is because of lunch meats,” Regusci explains. “Another issue is hepatitis, along with salmonella and E. coli. Raw chicken and raw eggs should be kept far away from prepared foods and other items that can be at risk for cross contamination.”

When Regusci is assessing a retail operation, the first thing he looks for is whether these proper protocols are being followed by employees.

“It’s easy to put this information on paper but harder to follow consistently, especially with today’s high turnover and younger staff,” he says, adding that temperature control is a common mistake. “If staff pulls out deli meat to make a sandwich and forgets about it until an hour later or whenever food is left out of the heat or cold for a long period of time, there is potential for an issue.”

Regusci compares food safety outbreaks to a baseball game.

“You have a massive lead but can still lose by a cascade of errors or failures, and this can be over a short or long period of time,” he says. “The biggest problem is not having muscle memory [in following the proper food safety protocol].”

Allergen Awareness

A hot food safety topic in recent years surrounds the topic of allergens.

“A law has been passed that goes into effect in two years, but the industry needs to get ready,” Nelken says. “Although it mainly impacts the food processing and manufacturing ends, it will trickle down to retailers.”

On April 23, the U.S. Congress passed the Food Allergy Safety, Treatment, Education and Research Act of 2021 (FASTER), making the allergen term “Big 8” obsolete. The Act expands the definition of major food allergens to include a ninth allergen—sesame, making sesame subject to all allergen food-labeling requirements. The Act also requires the Department of Health and Human Services to report on certain information related to food allergy research and data collection activities to be used in decision making on the potential addition of other allergens to the list.

In essence, the new law is quite simple: any sesame-containing food that is “introduced or delivered for introduction into interstate commerce on or after January 1, 2023” must be labeled as containing sesame following all current Food Allergen Labeling and Consumer Protection Act (FALCPA) requirements for allergen labeling.

For delis, this would include items such as dressings, oils, sesame buns, salads and prepared foods.

“This means reassessing most, if not all, of your products and re-connecting with suppliers to determine if sesame is included in any of their provided foods or ingredients,” Nelken says. “People won’t realize the impact because sesame has been hidden for the last 50 years.”

Proper Protocol

Bottom line, it is imperative for supermarket delis to have food safety standards and rules in place.

“We need to rethink people touching items in the deli, and staff needs to use gloves and have hands covered at all times,” Nelken says. “It’s important to properly sanitize the front of the deli case regularly to show you care about customers as well as address frequently touched spots in the deli. I recommend having a program where frequent touch points are sanitized every 20-30 minutes.”

He adds that, with the current studies about listeria in delis, it’s important to re-examine the possible risks and do in-service training for staff.

“This includes having swab checks periodically to see how they’re doing, along with a monthly or quarterly review of sanitation programs, and a quarterly review of the deli’s entire food safety program. Delis should have a supervisor on staff to monitor food safety programs every day.”

This staff member would be charged with making sure proper protocol is followed and for surveillance. If accidents happen, they would oversee proper investigations.

There are other methods to ensure proper guidelines are being followed.

“The Hurdle concept, where roadblocks are put in place to make it more difficult for pathogens to grow, can be effective,” Rowat Kraiss says. “For example, utilizing refrigeration, preservatives and pH control are examples of hurdles.”

However, when it comes to food safety, there is no substitute for proper training.

“Employees need to be taught constantly through training; it is the most important thing, along with follow-up and creating muscle memory,” Regusci says. “The biggest issue in the current climate is finding and training employees.”

Another often overlooked aspect of food safety programs is taking audits to examine what is being accomplished correctly and what needs fixing.

“With audits, we look at cleanliness and cross contamination, especially with allergens,” Regusci notes. “We make sure employees are gloved and masked and hair netted; we can see these things quickly.”

What is not as noticeable is whether a deli is following appropriate protocols for keeping food at proper temperatures.

“This is the fastest way to get a foodborne illness, aside from undercooked food,” Regusci says. “If the heat or cold chain is broken, that’s the quickest way to grow bacteria.”

To avoid issues, Kellerman recommends not hot holding food under heat lamps or on burners for extended periods of time and to make items to order, rather than preparing in advance.

There is good news for the segment. “Fortunately, when it comes to food safety, there are not a whole lot of issues with retail delis,” Kellerman says. DB

Addressing Food Safety Gaps

Federal guidelines recommend several food safety practices for retail delis. According to the U.S. Center for Disease Control, any gaps in protocol can be addressed by:

• Encouraging or requiring kitchen managers to be certified in food safety.

• Providing food safety training to workers.

• Monitoring and recording refrigerator temperatures.

• Having written slicer cleaning policies.

The Food and Drug Administration (FDA) and the U.S. Department of Agriculture Food Safety and Inspection Service recommend these food safety practices for controlling growth and contamination of bacteria, including listeria:

• Storing deli meats in refrigerators at 41 degrees F or colder.

• Using sanitizer solution at proper concentrations for cleaning surfaces that contact food.

• Using undamaged slicers. Damaged slicers are harder to clean.

• Cleaning and inspecting in-use food slicers every four hours. Cleaning at this frequency, and inspecting for damage and debris, can reduce contamination of food sliced on the slicers.

• Keeping raw meat away from ready-to-eat food to prevent potentially contaminated raw meat from contaminating ready-to-eat food.

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