We recently discovered that one of our sanitarians has not been performing his assigned restaurant inspections and actually was falsifying restaurant inspection reports. I would like to know from other LHDs what QA procedures they use to confirm that inspections are truly being performed and the inspection reports are valid.

My understanding is that NYC has the most robust QA approach related to this issue. Since their inspectors only report to their office once or so per week, they have to submit a weekly schedule of FSE’s they intend to inspect. A separate QA individual then randomly stakes out the FSE scheduled to be inspected to verify an inspection was performed as well as interviewing the FSE operator as to how such inspection was conducted. NYC spends > $1.2M/ year just on this FSE QA work.

We use eforms for our inspections. The electronic inspection report must be signed by both the facility and the inspector to be submitted. The electronic inspection report is automatically sent to one or two facility emails unless the inspector selects not send. Then the inspector receives an email that reminds them to print it out and mail it. So to falsify an inspection report, the inspector would need to forge a facility signature (or put something in that box) and select not to send it to the facility.

In Tompkins, the Sr. Sanitarian in charge of the FSE program reviews all inspection reports. This is usually done the same day or the day after the inspection and is an opportunity to see if anything seems amiss. If there are red critical violations cited, we do another inspection within a month, usually within 2 weeks. It is typically a different inspector that conducts the re-inspection. The violations of the first inspection are reviewed during the re-inspection, which would be an awkward conversation if the facility had not received the initial inspection report or if that report was invalid.

We also try not to send the same inspector to the facility every year. This may help identify inconsistencies in inspection reports, although not as quickly as having the Sr. San review all inspection reports shortly after the inspection was conducted.

There are several actions we perform which we think are potential impediments (and deterrents) to falsification of inspection reports. We have a process involving multiple staff in which we review each report for quality assurance, control and improvement. We employ procedures for enforcement of repeat violations, which involve contacting facility operators by phone, email, and/or letters. Finally, we are a small enough county that we have established relationships with many of our operators, some of which we are confident would alert or question us if they received an inspection report without direct knowledge of an inspection actually being performed.

The NYC DOHMH Bureau of Food Safety & Community Sanitation has extensive anticorruption and quality assurance systems and protocols in place to ensure maximum oversight of their inspection activities:

• The Bureau has 106 inspectors on staff who conduct restaurant and other food service establishment inspections. A ratio of 1 supervisor to 6 inspectors allows for manageable supervision and oversight of inspectors’ daily activities. All inspectors check in with their supervisors by phone at the beginning of the work day and again at the end of the work day.
• Inspection routing is automated and supervisors confirm daily routes. Supervisors regularly conduct random follow-up inspections to confirm an inspectors findings. Inspectors are not made aware of which of their inspections will be followed up on.
• The Bureau’s hand-held computer devices are used to both track inspectors time and record inspection results. Inspectors must record all their time for the day, including when they began and ended an inspection, their travel time between sites, and their breaks. The hand-held tracks when a new inspection record is opened and when it is completed. Supervisors and Bureau leadership regularly review inspector daily time records to ensure they sync with the timing of the inspection recorded on the handhelds.
• QA reports that utilize data recorded in the handhelds and stored in the Bureau’s inspection tracking system are used to ensure inspectors are correct and consistent in their assessment of an establishment’s adherence to food safety practices and to identify any timing anomalies that may indicate an issue with a particular inspector.
• The issuance of letter grades is a further check on the validity of an inspection. If an establishment were to receive an A on initial, they’d be issued an A grade card at the end of the inspection. Grade cards are numbered and the inspector must record the issuance of the grade card to the establishment in their hand-held devices. Inspectors must account for every grade card in their possession daily. If the establishment does not receive an A at the initial inspection, then a notice of violation (NOV) must be issued and recorded in the hand-held as well. The absence of a NOV and the non-issuance of an A grade card would indicate an issue with that inspection.

In response to your questions on how counties might track inspectors’ daily activity and the validity of their inspections, I can tell you of the procedures in place here at Albany County that act as a type  of “checks and balance” for that issue. Each environmental health employee(this includes field inspectors, supervisors, engineers and directors)fills out a daily “Destination Sheet” with the following information:

1. where they are going
2. what activity they will be performing each day
3. approximately what time they will be at each stop. This sheet is prominently displayed on each employee’s desk. Should a Supervisor or the Director need to contact an inspector, we call the establishment and ask to speak to the inspector.