Frequently Asked Questions – Food Safety Partnership
How do you ensure inspectors are able to conduct standardized inspections before they have 18 months of experience on the job?
Once hired, staff must undergo six months of training before being released to conduct field inspections. During this six month period, they are standardized to the 2010 Southern Nevada Health District Regulations Governing the Sanitation of Food Establishments and must pass all criteria and standards set by the Health District Training Office. Inspectors are not released from training until they demonstrate that the meet the standards set forth by the Health District and the 2010 Food Regulations. This shouldn’t be confused with FDA Voluntary National Retail Food Regulatory Program Standards training, which is advanced on the job training the Health District is conducting to further fine tune staff and enhance the service that is provided to the public while focusing on the FDA risk factors.
Does the industry have access to the FDA standards?
The FDA Standards can be found on the FDA website: Voluntary National Retail Food Regulatory Program Standards
With the Health District’s enrollment in the FDA Voluntary National Retail Food Regulatory Program Standards, will we require a follow up inspection on critical and major violations?
The Health District has not determined how we will comply with that corrective action follow up requirement of the Standards. It is scheduled to be addressed in 2017.
Will HACCP (Hazard Analysis Critical Control Point) plans be required for acidified food. If so, can industry get a list?
The current 2010 food regulations detail HACCP plans are required for acidified foods in section 3-502.11(C); however, this has not been enforced in the past. This requirement will be implemented with the updated food regulations. An exception to this would be for the acidification of sushi rice.
A list cannot not be provided as the types of foods are too numerous to name. The regulations are applicable to time/temperature control for safety (TCS) foods; therefore, if TCS foods are being acidified, then, a HACCP plan will be required.
What is the process for culinary curing?
Apply for a waiver providing all the information on the “Food Safety Plan Adding Sodium Nitrate to Meats and Poultry (Culinary Curing).” In addition, a log for recordkeeping including quantity made and amount of sodium nitrate (curing accelerator) added. Next project is HACCP website.
Answer to follow up question: Jams and jellies following the FDA guide for standard recipe do not need a HACCP plan; 21 CFR 150 lists the standard ingredients. If other ingredients are added, a HACCP plan is required. For Dr. Nummer’s template, email: firstname.lastname@example.org or email@example.com.
Will the Health District be moving forward with Dr. Nummer’s culinary curing?
The Health District has decided to move forward with Dr. Nummer’s culinary curing. The draft document received from Dr. Nummer will be used as a guideline for the documents required for submittal, including the requirement for a log detailing the amount (weight) of meat, curing salts, etc. utilized in the recipe.
What do we need to do if using the Skinner-Larkin model?
Any approved HACCP plan must follow the timeframes specified in the plan. The Health District has been approving the Skinner-Larkin model for a few years now. The Skinner-Larkin model allows for ROP cook-chill and sous vide products that have been cooled to 41°F within normal 6 hour window to be held up to seven days at 41°F. If you already have an approved HACCP plan, you need to update the existing plan for the extended time. Also remember that electronic monitoring is required at 41°F when using the Skinner-Larkin model.
If chef is interested in adding ingredients to steaks using a two barrier ROP, what plan is needed?
For an existing plan, please update the plan with the ingredients; dry spices are okay, but an ingredient list is needed if using a marinade. When using the two barrier method for meat and poultry, the second barrier is competing microorganisms. The Health District needs to make sure that the pH of the marinade is not affecting the second barrier. Two barrier ROP products can be held at 41°F for up to 14 days.
Is there any limit on dry aging of meat in a cooler?
Dry aging is not a special process and does not require a HACCP plan as long as the aging is not done in a bag.
If using fresh garlic in ROP, can you hold a maximum of 7 days?
When using the two barrier method for garlic, competing microorganisms are the second barrier. Garlic is treated as a raw vegetable in this situation. If adding fresh garlic to raw meat or vacuum packaging raw garlic, it can held up to 14 days at 41°F.
If cooking in bag, then open immediately and serve, what is needed?
A written operational plan that describes the process the facility is following to ensure it’s being done correctly and consistently and not being stored in the bag. The operational plan does not need to be approved by the Special Processes Team, please work with your inspector.
When will we get guidelines on cooling in bag? Do we have to submit an operational plan?
Yes, if cooling in a bag an operational plan needs to be submitted for approval. The plan must describe the process the facility is following to ensure the products are not being stored in the bag for an extended time. There is a stricter requirement than cooking in a bag because the product is held in the facility. Due to comments from industry, this policy will be reconsidered, but at this time an approved operational plan is required.
Will there be any HACCP training in Nevada?
Companies usually come to Las Vegas on a quarterly basis. For Seafood HACCP, you will have to go to California. Certified HACCP Manager Training is not required by the Health District, but may be required by the USDA or FDA.
If there is only one food vendor at a location, is an Event Coordinator needed?
No, an Event Coordinator is not needed.
Do the special event rules apply to retail establishments, such as an art gallery?
Not if the food is offered to the general public, free of charge or compensation, including admission fees.
Can Annual Itinerants be billed and be valid for a year based on when they are applied for?
All annual permits run from July 1st to June 30th (Southern Nevada Health District fiscal year) due to accounting systems in place.
Would the Health District consider giving a courtesy notification of night inspections; the week they will be performed, not the exact night?
It is the Health District’s policy to conduct unannounced inspections at all of our 19,000+ food permits, and the Health District must remain fair and impartial to all of them. Our inspections assess the conditions of each permit while in operation to ensure proper food sanitation and compliance with the regulations. It is the Health District’s mission to protect the health and well being of all residents and visitors of Southern Nevada. Unannounced inspections at any moment of time are the best way to gauge a facility in its operation to ensure they are serving in a safe and sanitary manner.
Inspections not anticipated by the regulated kitchen staff gives an unprejudiced evaluation of the kitchen’s sanitary conditions. Any type of advanced notification jeopardizes this, and is unfair to all of the other facilities not receiving advanced notification. This fails to provide the service the public demands and expects.
Are cooling logs required?
Cooling logs are not typically required. The food in the cooling process must be monitored and the PIC must provide accurate information on the product(s) cooling. This is done through interviewing the PIC and the food handlers responsible for cooling. A cooling log is only required as part of a required (HACCP) plan or through a Supervisory conference.
Will inspections outside of Health District’s normal business hours be done by non-food staff?
No, all Health District staff conducting inspections are trained in food. Experienced plan review and training staff will be helping to fill in.
Are there differences in regulations and enforcement in different parts of the city?
All staff has the same skills and criteria and there shouldn’t be different inspection focuses. The 2010 Regulations had a lot of changes and a switch in philosophy with a bigger focus on the five foodborne illness risk factors. Currently the Health District is undergoing FDA standardization. All inspectors have the same goal, which is to achieve compliance. There are 19,000 permits in Clark County, each facility is different and staff has to overcome barriers to get compliance.
Can the Health District offer Certified Food Protection Manager training?
Vegas PBS offers online training with a proctored exam and the Nevada Restaurant Association also proctors the exam.
In regard to pets and service animals, what is the responsibility of a restaurant with a patio?
Per the American with Disabilities Act (ADA), a service animal is a dog or mini horse only. A facility is allowed to ask what service the animal provides. Health District Regulations state that unless it is a service animal, it is not allowed in a restaurant; however, restaurants with a patio and a separate entrance for the patio may apply for a waiver for pet dogs.
Can a food truck park in a fixed location in front of a “restaurant” and use it as its commissary?
A mobile vendor may use a restaurant as its commissary provided that the restaurant has the infrastructure to support the mobile vending operations. Please contact the Downtown Office at 702-759-1110 for more information about specific requirements. Also, a restaurant may act as a commissary for only one mobile vending business entity.
For a mobile vendor staying in a specific location, regulations require that mobile vendors move every 30 minutes. If a mobile vendor wants to stay in a specific location for up to four hours, contact the Downtown Office at 702-759-1110 for information on an operational waiver. The Health District may approve a waiver for a specific location for a mobile vendor if the operator can mitigate food handling risks; please discuss details with the Downtown Office.
For operators wishing to remain at a specific location for more than 4 hours on a mobile vendor platform, a specific permit will be required. That permit is a Portable Unit for the Service of Food (PUSF) permit. Contact the Health District’s Facility, Design, Assessment, and Permitting (FDAP) office at 702-759-1258 for more information about the PUSF permit.
Do you need to time label clams stored in water since there is no temperature requirement?
Clams should not be stored in standing water. As long as they are alive, there is no temperature requirement and a time label at room temperature is not required. Remember that tags must be kept for 90 days and in chronological order from the date served.
Do stickers on avocados have to be removed?
Stickers must be removed as part of washing process. Like all fruit (and vegetables), avocados must be washed prior to preparation (cutting).
What are the hand sink requirements for a Portable Unit for the Service of Food (PUSF)?
A hand washing sink is required for any PUSF where open food and beverage is handled. The minimum size requirement is at least 10 inches x 10 inches at the water line, with a minimum depth of 6 inches. It must be drained to sanitary sewer. The water must be at least 100°F. An adequate supply of potable water and wastewater capacity is required as specified in Chapter 11, Portable Units for the Service of Food.
Is it acceptable to keep copies of Food Handler cards?
You can, but the food handler is still required to keep the card on his/her person. It’s technically a violation if they do not have it. Also, the Health District staff hears complaints that management “takes their food handler cards” and they “work another job”. These are considered personal property and may have an impact at other employment if management holds onto the cards.
Does the Health District have a 24-hour number?
Yes, the after hour number is 702-759-1600 and it is for imminent health hazards/public health emergencies. We will respond the next business day as do other jurisdictions.
How often do you inspect and what do you look for?
The inspection frequency varies depending on how the food operator performs on inspections and the complexity of the food service or risk category. The state mandate for inspections is once per calendar year. Our Food Establishment Inspection Report is on our website and can be used to see how/what we inspect. You can use the report as a checklist in your facility to do your own inspections.
Phone: (702) 759-0588
Updated on: November 6, 2019