PERFORMANCE AUDIT
FoodPoolTourist Program
Department of Human Resources March 2002

Performance Audit Operations Division Russell W. Hinton, State Auditor Department of Audits and Accounts

254 Washington St. Atlanta, GA 30334

Introduction
Background
The purpose of the Food-Pool-Tourist Program is to protect the public health and safety by regulating food service establishments, swimming pools, and tourist accommodations. Acting on behalf of the Department of Human Resources (DHR), county boards of health are responsible for permitting and inspecting restaurants and other food service establishments, public swimming pools, and tourist accommodations (such as hotels and motels). The FoodPool-Tourist Unit within the Environmental Health Section of DHR's Division of Public Health is responsible for developing Program regulations, providing technical assistance and training, and monitoring the overall Program.
The state began regulating tourist accommodations in 1953 and food service establishments in 1958. Legislation requiring the state to regulate swimming pools was enacted in 2000. This legislation, known as Michelle's Law, was passed subsequent to the drowning of two persons (including a pre-teen named Michelle) in separate incidents at a hotel swimming pool. Passage of the legislation was also impacted by a 1998 outbreak of E. coli bacteria at a metropolitan Atlanta waterpark that resulted in 26 children becoming ill and one death.
As shown by the map on the following page, the state's 159 county boards of health are organized into 19 Public Health Districts, ranging in size from one to 16 counties. The foodpool-tourist programs in the districts are under the direction of an environmental health district director. Depending on their size and organizational structure, the counties are staffed with environmental health urban county directors, environmental health county managers, environmental health specialists, and environmental health technicians. With the exception of the district directors, who are employed by the state, all of the environmentalists at the local level are county employees.
In addition to regulating food service establishments, swimming pools, and tourist accommodations, county environmentalists are responsible for regulating the installation and maintenance of individual on-site sewage management systems (septic tanks). County environmentalists are also responsible for responding to other types of environmental health issues, such as the West Nile virus.

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Exhibit 1
PUBLIC HEALTH DISTRICTS

1-2 Dalton
1-1 Northwest

2 Gainesville

3-4 East Metro

10 Athens

3-1 CobbDouglas
3-2 Fulton

4 LaGrange

5-2 North Central

6 Augusta

3-5 DeKalb
3-3 Clayton

7 West Central
8-2 Southwest

5-1 South Central
9-2 Southeast
8-1 Valdosta

Savannah 9-1
9-3 Coastal

Food Service Establishments (Restaurants)
As defined by state law, food service establishments include: coffee shops; cafeterias; shortorder cafes; luncheonettes; taverns; lunchrooms; soda fountains; public and private institutions; food carts; itinerant restaurants; industrial cafeterias; places that retail sandwiches or salads; and catering establishments as well as restaurants. Prior to opening for business, restaurants are required to obtain an operating permit from their county board of health. Exceptions to the permitting requirement include food service activities that are part of: outdoor recreational events sponsored by the state, a county, or a municipality; outdoor public and private school functions; and fairs or festivals that are sponsored by a governmental unit or a nonprofit organization and that last 120 hours (5 days) or less.
If the restaurant will be located in a new building or an extensively remodeled building, its

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owner must submit plans and specifications for review and approval at least 14 days prior to construction. The plan reviews are conducted to ensure the restaurant will meet applicable regulations (such as having the equipment necessary to maintain food at the proper temperature). New restaurants, including those located in existing facilities, are inspected on-site prior to their opening for business. By law, the permits for food service establishments are valid until suspended or revoked.
Under current DHR regulations, restaurants are required to be inspected at least twice a year. The inspections address the following major areas:
sources of food; employee hygiene; food storage and handling; proper temperature controls (e.g., hot foods kept at a temperature of at least 140?); equipment (including dishwashing equipment) and utensils; availability of hot and cold running water; sewage disposal system; plumbing; toilet and handwashing facilities; garbage and refuse disposal; physical facilities; and, other areas (such as rodent and insect control).
At the conclusion of the inspection, the completed inspection report is discussed with and given to the person in charge of the restaurant.
Although a numeric score is calculated and included on the inspection report (which must be posted by the food service establishment for public viewing), there is no passing score. Deficiencies noted during the inspections are classified as category I, category II, or category III depending on their potential impact on public health. Category I deficiencies, such as failing to keep food at the proper temperature, are considered imminent health hazards that must be corrected immediately upon receipt of the inspection report. Category II deficiencies, such as failing to use proper food storage containers, create the potential for causing foodborne illnesses and must be corrected within 72 hours. Category III deficiencies, such as failing to shield lighting fixtures, are considered general requirements that must be corrected within a reasonable period of time. A copy of the current DHR inspection form and an explanation of the scoring methodology are provided in Appendix A and Appendix B, respectively.
County health department personnel may suspend or revoke a food service establishment's permit if it fails to correct deficiencies within the required time frame. In those counties that have formally adopted DHR's regulations as part of their county ordinances, county health department personnel may issue citations under the jurisdiction of their local magistrate court. In emergency situations involving serious health hazards, county health departments may obtain a court injunction requiring the establishment to cease operation. Interviews with county health department personnel indicated that most restaurants take corrective action before any formal disciplinary action is necessary.

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Swimming Pools
County boards of health are also responsible for permitting and inspecting swimming pools. The 2000 legislation that established this requirement, however, only applies to public swimming pools that charge a daily access fee and to those swimming pools operated by municipalities, hotels/motels, and schools. Private, residential swimming pools and pools at apartment complexes, country clubs, and subdivisions (if open only to residents of the subdivision and their guests) are exempt from the permitting requirement. The legislation also specifies that it is applicable only in those counties that had not adopted their own regulations as of December 31, 2000. Department personnel have indicated that about 24 Georgia counties, most of which are in metropolitan areas, had their own regulations in place by the December 31st deadline and are not covered by the state legislation. It was also indicated that most, if not all, of these counties regulate swimming pools at apartment complexes and subdivisions.
As part of the permitting process, the owners of pools scheduled for construction or extensive remodeling must submit copies of the plans and specifications to their county health department at least 14 days prior to beginning construction. Swimming pools that were constructed or remodeled prior to December 31, 2000 are not required to comply with the design and construction requirements specified in the regulations (other than the requirement regarding the abatement of suction hazards).
Swimming pools that are open on or after April 1st and that close on or before October 31st must be inspected at least once during the period of operation; all other pools must be inspected at least twice a year. The regulations that were adopted by DHR in November 2001 require inspection personnel to check such items as the pool's:
water supply; circulation system (including drainage system and abatement of suction hazards); disinfectant equipment (e.g., chlorination); water clarity and alkalinity; lighting and electrical system; lifesaving equipment; and warning signs.
The regulations also require that pool operators be properly trained by attending courses such as those offered by the National Swimming Pool Foundation.
An inspection report, which must be posted in public view, is prepared at the completion of the inspection. The Department's regulations specify that an unsatisfactory rating will be given to a swimming pool when any violation is found that constitutes a substantial health hazard (such as failure to maintain the required disinfectant level), when any two or more other violations are found, or when any violation is repeated on a follow-up inspection. Failure to comply with the provisions of state law or DHR regulations may result in suspension or revocation of the pool's permit. A copy of the current DHR swimming pool inspection form is provided in Appendix C.

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Tourist Accommodations (Motels)
Tourist accommodations include tourist courts; tourist cottages; tourist homes; trailer parks; trailer courts; motor hotels; hotels, and motels. As with restaurants and swimming pools, tourist accommodations must obtain a permit from their county board of health prior to beginning operation. County personnel review plans and specifications for new and extensively remodeled facilities prior to their opening for business.
All tourist accommodations are required by DHR regulations to be inspected at least twice a year. The inspections address the following major areas:
water supply; toilet facilities; sewers and sewage disposal; plumbing; garbage and refuse disposal; insect/rodent control; construction, layout, furnishings, and grounds; heating and fire safety; laundry; and, employee hygiene.
Tourist accommodations that have swimming pools are subject to the state's (or their county's) swimming pool laws and regulations. Similarly, tourist accommodations that have a restaurant or other type of food service facility are subject to the state laws and regulations governing food service establishments. Tourist accommodations that provide a continental breakfast, however, are not required to have a food service permit but are required to comply with specific regulations that are included as part of DHR's tourist accommodation regulations.
The inspection form, which must be posted in public view, provides for a numeric score of 0 to 100. There is no failing score but failure to comply with the provisions of state law or DHR regulations may result in suspension or revocation of the facility's permit. A copy of the current DHR inspection form for tourist accommodations is provided in Appendix D.
Activity Data
Information obtained from DHR indicates that there are approximately 23,200 food service establishments and 2,135 tourist accommodations in the state. Because most county health departments had only recently begun regulating swimming pools at the time of this performance audit, complete information regarding the number of regulated swimming pools in the state was not available.
Financial Information
The total cost of regulating food service establishments, swimming pools, and tourist accommodations could not be determined as part of this audit. While the state provides Public Health grant-in-aid funds to county boards of health, these funds are used for multiple programs, including the cost of operating their environmental health units. For fiscal year

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2002, the total amount of Public Health grant-in-aid funds was approximately $162.9 million, of which $87.3 million was designated for specific programs such as Adolescent Health. The remaining $75.6 million (which was subsequently revised to $70.1 million after redirection and other adjustments) was for county health departments' general operations, including their environmental health units. Unlike the program-specific funds, these general operating funds are given to all 159 counties and allocated among the counties based on the formula presented below. It should be noted that the formula is not updated each year to reflect changes in the counties' population and property tax digest; the population and property tax figures used in the formula have remained unchanged since 1970.
1/2 of the available funds are allocated in proportion to the civilian population of each county;
1/2 of the available funds are allocated in proportion to the civilian population of each county weighted inversely by the county's property tax digest (used as an indicator of each county's financial condition).
As a condition of receiving the grant-in-aid funds for general operations, each county health department is required to budget a specified amount of matching funds. The amount of matching funds required of each county is based on a formula reflective of each county's per capita tax digest. The data used in the formula has also not been updated since the 1970's (per DHR personnel).
For fiscal year 2002, the amount of general operating grant-in-aid funds budgeted for each county ranges from $71,858 (Webster County) to $7,974,039 (Fulton County). The amount of the required local match for fiscal year 2002 ranges from $1,953 in Chattahoochee County (2.5% of the county's $79,495 allocation) to $3.7 million in Fulton County (46.7% of the county's $7,974,039 allocation).
Audit Objectives, Scope, and Methodology
The primary objectives of this audit were to determine if : there is a continued need to regulate food service establishments, swimming pools, and
tourist accommodations; the Food-Pool-Tourist Program is being administered in a uniform and consistent manner
throughout the state; DHR has established measurable goals and objectives for evaluating the effectiveness of
the Food-Pool-Tourist Program; food service establishments and tourist accommodations are inspected with the required
frequency and in a thorough and uniform manner; the statutory exemption regarding swimming pools at apartment complexes, subdivi-
sions, and county clubs results in reduced public protection; and, if other southeastern states have developed regulatory procedures that should be consid-
ered for implementation in Georgia.
It should be noted that the audit did not attempt to determine if there were any food service establishments or tourist accommodations that had not obtained the required permit from

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their county health department. It was verified, however, that county health departments attempt to identify new establishments and require them to obtain a permit by working with local government offices that issue business licenses and building permits. The audit also did not address county health departments' implementation of DHR's swimming pool regulations since these regulations were not officially adopted until November 2001 (after the audit had been in progress for several months).
The audit was conducted in accordance with generally accepted government auditing standards for performance audits and focused on fiscal year 2001. The audit methodology included interviews with DHR personnel and on-site visits to 19 county health departments (one in each of the state's Public Health Districts).1 As part of the on-site visits, interviews were conducted with inspectors and other county health department personnel, and summary data was compiled regarding inspection dates and scores. Members of the audit team also accompanied county personnel on inspections of restaurants, swimming pools, and motels.
This report has been discussed with appropriate personnel representing the Department of Humans Resources. A draft copy of the report was provided for their review and comment; pertinent responses have been include in the report as appropriate.

1The 19 counties that were visited included: Bibb, Bulloch, Chatham, Clarke, Clayton, DeKalb, Dougherty, Douglas, Fayette, Floyd, Forsyth, Fulton, Laurens, Liberty, Muscogee, Newton, Richmond, Tift, and Whitfield.

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Program Administration
Recommendation No. 1 The state should continue its efforts to regulate food service establishments, swimming pools, and tourist accommodations. A review of current literature and interviews with DHR personnel indicated that unsanitary conditions in restaurants, swimming pools, and motels can have a serious impact on public health. The following paragraphs discuss the public health issues associated with these types of facilities.
Restaurants: In December 2000, the Centers for Disease Control and Prevention (CDC) estimated that foodborne diseases, defined as those caused by the ingestion of contaminated food, cause 76 million illnesses, 325,000 hospitalizations, and 5,200 deaths in the United States every year. It has also been estimated that retail food establishments account for approximately 40% of all foodborne illnesses. The permitting and inspection functions performed by county health departments serve to reduce the incidence of foodborne illnesses by requiring restaurants to comply with regulations governing safe food preparation and serving procedures.
Swimming Pools: The types of public health issues involving public swimming pools include accidental drowning and diseases caused by cryptosporidium, giardia, and E. coli. Requiring pools to obtain an operating permit, employ certified operators, and undergo periodic inspections serves to ensure that pools will be properly maintained and operated. The involvement of public health personnel also serves to en-

sure that any disease outbreaks will be dealt with in an appropriate manner.

Motels: A public health concern regarding unsanitary motels is the spread of bedbugs and lice. Unsanitary restrooms in motels and other types of tourist accommodations can cause the spread of bacterial infections such as shigella and salmonella.

While there is a legitimate need for the Food-Pool-Tourist Program, DHR should take steps to improve the Program's overall operation. This issue is discussed in the following finding.

Recommendation No. 2

The Department of Human Resources

should take a more proactive role in en-

suring that the Food-Pool-Tourist Pro-

gram is administered in an efficient and

effective manner throughout the state.

Currently, Georgia does not have a uniform

statewide system for regulating restaurants,

swimming pools, or

motels. The food- Currently, Georgia

pool-tourist pro- does not have a

grams administered uniform statewide

by the state's 159 system for regulating

counties operate with little or no ad-

restaurants, swimming pools, or motels.

ministrative over-

sight by DHR, re-

sulting in an overall lack of uniformity,

consistency, and accountability. The need

for additional oversight, guidance, and ac-

countability is briefly discussed below and

is presented more fully in the remainder of

this report.

The Department does not have the person-

Food-Pool-Tourist Program

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nel or procedures in place to effectively monitor the counties' food-pool-tourist programs. In addition to having only two persons assigned to the Program, DHR does not have any type of management information system for ensuring that restaurants, swimming pools, or motels are being inspected as required.
Absent strong administrative oversight, there is little uniformity or consistency among the food-pool-tourist programs at the county level. Our review of 19 county health departments found substantial differences in all aspects of their programs, including different: restaurant inspection forms; tourist accommodation inspection forms; restaurant scoring procedures; and, restaurant re-inspection policies.
Because of these kinds of differences, DHR cannot provide reasonable assurances that restaurants and motels throughout the state are being held to the same public health standards.
County health departments are not required to separately identify the amount of grant-in-aid funds they spend on their food-pool-tourist programs. In addition, they are not required to comply with DHR's food-pool-tourist regulations as a condition of receiving the grant-in-aid funds.
For the state to have a more efficient and effective system for regulating restaurants, swimming pools, and motels, DHR should provide additional oversight, guidance, and direction. It should be noted that a 1975 performance audit also cited the need for DHR to assume a more positive role in the administration of the various environmental health programs carried out by the ... coun-

ties. Specific areas in which improvements should be effected are discussed in the remainder of this report.
In its written response, DHR noted that state law does not provide DHR with administrative or supervisory authority over county board of health personnel or programs. The Department also indicated, however, that within the statutory limitations, it has initiated a more proactive approach to providing administrative oversight, including providing training, interpreting rules, and requesting quarterly reports.
Recommendation No. 3 The Department should revise its grantin-aid agreement with county boards of health to provide increased accountability over how the funds are spent. Of the $70.1 million in general grant-in-aid funds that was provided to the 159 county boards of health for fiscal year 2002, DHR does not know how much would be spent on individual programs (such as the FoodPool-Tourist Program). Similarly, DHR does not require the county boards of health to comply with DHR regulations as a condition of receiving the funds.
Currently, data is not maintained by DHR or by the counties to determine the dollar amount of state funds that is expended each year to regulate food service establishments, swimming pools, and tourist accommodations. Absent such information, the cost-effectiveness of the Program as a whole or of its component parts cannot be determined. Information is not available, for example, to evaluate the cost incurred by the counties to conduct twice yearly motel inspections or to regulate public swimming pools.

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In addition to not knowing how much is

being spent on specific programs, DHR

does not hold boards of health account-

able for administering the programs in

compliance

Program personnel w i t h D H R

feel they have little or regulations. As

no authority to re- a result, Pro-

quire county boards gram personnel

of health to operate their food-pooltourist programs in a

feel they have little or no au-

uniform and consis- thority to re-

tent manner.

quire county

boards of

health to oper-

ate their food-pool-tourist programs in a

uniform and consistent manner (even

though DHR provides a substantial

amount of their funding).

The Department should take steps to determine how the Public Health grant-in-aid funds are expended, including the dollar amount that is expended by the county health departments to administer the FoodPool-Tourist Program. The Department should also consider modifying the grantin-aid agreement to specifically require county boards of health to comply with DHR regulations as a condition of receiving the funds. Implementation of this recommendation would provide greater accountability over the manner in which the grantin-aid funds are expended as well as enabling DHR personnel to ensure that the Program is operated in a more uniform and consistent manner throughout the state.

In its written response, DHR noted that it concurred with the recommendation and would take action to modify the grant-in-aid agreements to specify the funds to be spent on each environmental health program. The Department also indicated that a system would be developed to link performance and funding levels.

Recommendation No. 4 Action needs to be taken by DHR and by county health departments to compile statistical data for managing the FoodPool-Tourist Program at the state and county level, respectively. Currently, insufficient management information is compiled by DHR and by some of the counties to effectively monitor the Program's operation. As discussed in the following paragraphs, summary data regarding frequency of inspections, average inspection scores, and amount of time spent per inspection is not available.
The Department does not have an effective management information system for monitoring Program implementation at the county level. Data is not maintained for determining if restaurants and other facilities are being inspected as required, for monitoring variances in counties' inspection scores, or for evaluating the number of personnel the counties have assigned to the Program.
Six of the 19 county health departments visited as part of this audit do not have an effective management information system for administering their programs. Two county health departments do not have any type of information system (manual or automated) and four have automated systems that are ineffective. Two of these counties, for example, input all of their inspection reports into their systems but are unable to retrieve any type of summary reports.
Reviews of restaurant inspection reports found that 14 of the 19 counties do not require their inspectors to record the amount of time actually spent per inspection (even though space for recording this information is provided on the DHR inspection form). As a result,

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these 14 counties do not have summary data for computing average inspection times or for determining the minimum number of personnel needed to conduct the required inspections. The absence of statistical data also makes it more difficult to evaluate employees' productivity.
Although it has the most restaurants in the state and the second-most tourist accommodations, Fulton County does not have an automated system for managing its food-pool-tourist program. As a result, County officials were unable to provide up-to-date information to verify that restaurants and tourist accommodations are being inspected as required. It should be noted that Fulton County is responsible for inspecting approximately 15% (3,500) of the state's restaurants and approximately 6% (134) of the state's tourist accommodations.
In addition to the lack of an automated record-keeping system, the County's manual files are in disarray or, as described by one Fulton County official, the files are chaotic. At the time of our review, the County was in the process of updating the files to include a substantial number of inspection reports that had not yet been posted in the files.
By improving their record-keeping procedures, both DHR and county health departments would be able to better monitor the extent to which the Program is operating in an efficient and effective manner. It should be noted that implementation of this recommendation would not require a single, statewide system nor would it require expensive systems at the local level. Using inexpensive spreadsheet or database software packages, counties could implement their own management information systems for moni-

toring their food-pool-tourist programs.

The Department has indicated that it concurs with the recommendation and would seek funding for a cost-effective statewide information management system.

Recommendation No. 5 The Department should work with the Office of Planning and Budget (OPB) to develop additional goals and performance objectives for the Food-Pool-Tourist Program. Currently, the Program's only ResultsBased Budgeting (RBB) goal is to reduce the rate of food-related illness; the only performance objective is to reduce the number of foodborne outbreaks from 21 in fiscal year 2001 to 18 in fiscal year 2002. In addition to refining its goals and objectives regarding food service establishments, DHR should also develop goals and performance objectives regarding the regulation of swimming pools and tourist accommodations.

Using the number of foodborne out-

breaks may not be an accurate measure

of the Program's effectiveness. As

noted by the CDC, only 1% to 5% of

foodborne illness cases are actually re-

ported. A performance measure that in-

dicates the state has only 18 foodborne

outbreaks a year

(defined by DHR as involv-

A better measure of the Program's effec-

ing two or more tiveness might be a

persons) may reduction in the

s u b s t a n t i a l l y number of restau-

overstate the rants that are found

Program's ef- to have serious defi-

fectiveness. As ciencies.

noted by OPB, a

better measure of the Program's effec-

tiveness might be a reduction in the

number of restaurants that are inspected

and found to have serious deficiencies.

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DHR should also develop goals and objectives regarding the Program's effectiveness in regulating swimming pools and tourist accommodations. For example, one objective might be to have all of the state's motels meet DHR's standards for sanitation and cleanliness.
The Department should work to establish more comprehensive goals and objectives regarding the Food-Pool-Tourist Program. Implementation of this recommendation would enable DHR to better monitor the Program's overall effectiveness.
In its written response, DHR indicated that it would work to develop additional goals and objectives within the limitations of Program staffing.
Recommendation No. 6 The Department should continue its efforts to enable county health departments to attract and retain qualified personnel. Of the 19 county health departments visited during this audit, 14 cited problems with employee turnover and/or difficulties in filling vacant positions. County officials noted that it was difficult to attract college graduates to work as environmental health specialists at a starting salary of $25,141. Information provided by DHR indicated that from July 1, 2000 through June 30, 2001, the turnover rate for environmental health specialists I was 42%, the rate for environmental health specialists II was 24%, and the rate for environmental health specialists III was 7%.
For fiscal year 2003, DHR proposed a onepay-grade increase in the starting salary for environmental health specialists, district directors, urban county directors, and county managers. The Department also proposed a three-pay-grade increase in the starting sal-

ary for environmental health technicians. The estimated annual cost of these proposed salary upgrades was about $2.2 million. The salary upgrade was not included in the proposed budget for fiscal year 2003.

Restaurants

Recommendation No. 1

The Department should continue its ef-

forts to revise the current restaurant in-

spection form.

As noted by the Centers for Disease Control

and Prevention (CDC), one of the ways

consumers can protect themselves from

foodborne illness is to find out how restau-

rants did on their

most recent inspec- The current inspec-

tions, and use that score to help guide [their] choice. The current inspection form, however, does not always provide an accurate

tion form does not always provide an accurate guide for consumers to use in determining whether they want to eat at a particular restaurant.

guide for consum-

ers to use in determining whether they want

to eat at a particular restaurant.

Using the current DHR inspection form, category I deficiencies (defined by DHR as hazardous) only count 6 2/3 points off a maximum score of 100; category II deficiencies (defined by DHR as critical) only count from 2/3 point to 5 points depending on the type and severity of the deficiency. As a result, a restaurant can be cited for significant deficiencies and still receive an aboveaverage inspection score (as perceived by the general public).

A restaurant with one hazardous (category I) deficiency and four critical

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Exhibit 2
DISTRIBUTION OF FOOD SERVICE INSPECTION SCORES
(18 of 19 counties visited)
1400

1200

Number of Inspections

1000

800

600

400

200

SCORE

0*

70

72

74

76

78

80

82

84

86

88

90

92

94

96

98

100

*Of the 7,431 inspections, 41 had a score less than 70; these inspection scores are not shown on the graph above.

Source: County health department records, including computer files.

(category II) deficiencies, for example, may receive a score of 90. A restaurant with two hazardous (category I) deficiencies and two critical (category II) deficiencies may receive a score of 85. Unless consumers take time to actually read the inspection form, it is unlikely they would perceive a score of 90 or 85 as indicative of major deficiencies. (The current inspection form and scoring methodology are shown in Appendix A and Appendix B, respectively.)
Because the current form allows restaurants with significant deficiencies to receive relatively high inspection scores, the average restaurant inspection score is so high that it may affect consumers' ability to distinguish between "good" and "bad" restaurants. For 18 of the 19 counties visited as part of this audit, the most recent inspection scores, excluding re-inspections, were obtained for 7,431 restaurants (data for Fulton County was not available). As shown by Exhibit 2

above, few restaurants received scores less than 70; the score most often received by the restaurants was a score of 100. Overall, the average inspection score for these 7,431 restaurants was 94.5; the median inspection score was 96.
The revised inspection form that has been proposed by the Program has two categories of violations (critical and non-critical) and provides for letter scores of A (excellent), B (satisfactory), U (unsatisfactory), and F (failure). Using the revised form, for example, a restaurant that has no critical item violations, no more than three non-critical item violations and/or no recurring violations from the last inspection would receive an A. The proposed form is shown in Appendix E.
If the proposed inspection form is not adopted, consideration should be given to adopting the form that is currently being used in two of the 19 counties that were vis-

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Exhibit 3

FOOD SERVICE INSPECTION RESULTS

COUNTY
A B C D E F G H I J K L M N O P Q R 18-COUNTY TOTAL

TOTAL INSPECTIONS
237 154 252 594 116 1,821 294 204 96 370 576 179 206 128 116 924 558 606
7,431

AVERAGE SCORE 90.6 91.7 91.3 94.9 93.3 92.1 93.6 95.8 92.0 95.9 97.3 94.6 94.1 93.8 93.4 97.3 96.5 96.2
94.5

M E D IAN SCORE
93 92 94 96 96 93 95 97 94 97 98 96 96 95 95 98 98 98
96

PERFECT SCORES
3 (1% ) 2 (1% ) 11 (4%) 50 (8%) 10 (9%) 163 (9% ) 32 (11% ) 25 (12% ) 15 (16% ) 59 (16% ) 103 (18%) 34 (19% ) 48 (23% ) 37 (29% ) 34 (29% ) 302 (33%) 199 (36%) 227 (37%)
1,354 (18%)

SCORES LESS THAN 70
3 (1% ) 0 (0% ) 8 (3% ) 0 (0% ) 0 (0% ) 17 (0.9% ) 1 (0.3% ) 1 (0.5% ) 4 (4% ) 0 (0% ) 0 (0% ) 1 (0.6% ) 3 (1% ) 1 (0.8% ) 1 (0.9% ) 0 (0% ) 0 (0% ) 1 (0.2% )
41 (0.6% )

Source: County health departm ent records, including com p u ter files.

ited. This form, shown in Appendix F, provides separate scores for hazardous (category I) deficiencies, critical (category II) deficiencies, and general (category III) deficiencies.
Regardless of the type of inspection form that is used, DHR should ensure that all counties use the same form and compute the inspection scores in a uniform and consistent manner. This issue is discussed in the following finding.
In its written response, DHR indicated that all counties will be expected to use the new inspection form.
Recommendation No. 2 Action should be taken by DHR to ensure that county health departments are rea-

sonably consistent in their evaluations of restaurants' compliance with food safety standards. Our on-site reviews of county health departments found an overall lack of consistency and uniformity, including the use of different inspection forms and scoring procedures. As a result of this lack of consistency, the inspection scores received by restaurants in different counties do not provide a uniform basis for the public to use in determining if they should eat at a particular restaurant.
Our review of the most recent inspection results for 7,431 restaurants in 18 counties raised questions regarding the overall consistency of the counties' inspection procedures. (Fulton County was not included in the analysis due to the condition of the

Food-Pool-Tourist Program

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County's files.) Exhibit 3 shows the number of restaurant scores reviewed in each county, the average inspection score, the median inspection score, the percentage of restaurants receiving a perfect score, and the percentage receiving a score less than 70.
As shown by the Exhibit, the average inspection score in the 18 counties ranged from 90.6 to 97.3; the median inspection score ranged from 92 to 98. In five counties, at least one in every four restaurants inspected received a perfect score (100). In these five counties, only three (0.1%) of the 2,332 restaurants that were inspected received scores less than 70. In six other counties, however, fewer than 10 restaurants out of a 100 received a perfect score. In these six counties, 28 (0.9%) of the 3,174 restaurants that were inspected received scores less than 70.
While a number of factors may contribute to the substantial differences in the counties' inspection scores, our on-site reviews identified three significant differences in the counties' inspection procedures that could impact the resultant scores.
(1) Six of the 19 county health departments reviewed during the audit have implemented their own restaurant inspection forms or have revised the DHR form. The use of different forms can result in restaurants receiving substantially different scores even though they are cited for the same deficiencies. Depending on the type and severity of the deficiencies, for example, a restaurant that receives a score of 86 using the DHR form could receive a score of 95 using the form developed by one of the counties. Conversely, a restaurant that receives a score of 90 using the DHR form could receive a score of 82 using

another county's form.
(2) One of the 19 counties does not comply with DHR policy and deduct 20 points for each hazardous (category I) deficiency. County personnel indicated they thought they could deduct as few as 5 points for a category I deficiency. In one case, for example, a restaurant that was given a score of 89 should have received a score of 82 (had the correct number of points been deducted).
(3) One of the 19 counties visited during the audit does not deduct any points for a hazardous (category I) deficiency if the restaurant corrects the deficiency prior to the completion of the inspection. During an inspection in this county (in which the inspector was accompanied by a member of the audit team), it was found that food was not being stored at the proper temperature. Because the restaurant disposed of the food in question, no points were deducted for the violation. The restaurant received a score of 91 instead of the 84 it should have received.
The Department should take steps to ensure that county health departments follow uniform procedures in determining restaurants' inspection scores. This would serve to enable consumers to make more informed choices in determining if they should eat at a particular restaurant.
The Department indicated in its written response that it concurred with the recommendation and would implement training sessions in all 19 Public Health Districts following the adoption of the new food service regulations.
Recommendation No. 3 The Department should take steps to en-

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sure that county health departments comply with DHR regulations and inspect restaurants at least twice a year. Our review found that, overall, 95% (7,138) of 7,521 restaurants had been inspected within the preceding eight months (indicating they were being inspected approximately every six months, or twice a year). Six of the health departments, however, had inspected fewer than 95% of their restaurants during the preceding eight months, ranging from 81% to 93%. These six health departments accounted for 68% (262) of the 383 restaurants that had not been inspected as required. Fulton County was not included in this analysis due to the absence of reliable data; however, County officials acknowledged that restaurants were not always inspected twice a year as required.
Action should be taken to ensure that all restaurants are inspected as required. To enable county health departments to make better use of their resources, DHR should consider allowing counties to prioritize their restaurant inspections. This recommendation is discussed more fully in the following finding.
In its written response, DHR indicated it concurred with the recommendation.
Recommendation No. 4 The Program should be commended for taking steps to revise the regulations governing restaurants and other food service establishments. Although the Program's proposed regulations have not yet been formally adopted by DHR, they address many of the concerns identified during the course of our performance audit. As discussed below, the proposed regulations address frequency of inspections, training of restaurant personnel, and training of county inspectors.

Prioritization of Inspections: Current DHR regulations mandate that all restaurants be inspected at least twice a year, regardless of such factors as inspection history, size, or extent of onsite food preparation. As a result, county resources are used to conduct routine inspections of low-risk facilities instead of focusing on those restaurants with a history of violations.
Under the proposed regulations, the frequency of inspections will be based on a risk categorization of the restaurant's menu and previous inspection results. For example, restaurants serving prepackaged, non-potentially hazardous food will be subject to only one routine inspection per year; restaurants that extensively handle raw ingredients will be subject to three routine inspections per year. Restaurants will be subject to additional inspections based on previous inspection scores.
Training of Restaurant Personnel: As noted by the National Restaurant Association (on its website), the key [to eliminating foodborne outbreaks] is education and training. Currently, however, there is no statewide requirement for food service personnel to have formal training. County governments in two of the 19 counties visited as part of this audit have adopted ordinances requiring food service workers to obtain training as one of the requirements for a restaurant to obtain a permit.
The Program's proposed regulations would require restaurant owners or managers to successfully complete an accredited food safety training program and pass a professionally validated examination. Current restaurant owners/ managers would have two years to com-

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ply with the requirement; owners/ managers of new restaurants would have to comply as a condition of receiving a permit. It should be noted that the National Restaurant Association has indicated (on its website) that it supports obligatory food safety training and that such training doesn't have to be inconvenient or costly.
Inspector Training and Standardization: Currently, DHR does not require county inspection personnel to complete any type of formal training on how to conduct restaurant inspections. While DHR offers a four-week course covering all aspects of environmental health, the course is not required, does not include any hands-on training, and may not coincide with a new employee's start date. In addition, only 4 days are spent on issues dealing with the FoodPool-Tourist Program. As a result, most inspectors learn how to conduct inspections through on-the-job training.
During the course of this audit, members of the audit team accompanied county personnel on a total of 21 restaurant inspections, resulting in questions regarding the quality and consistency of the inspection process. For eight of these inspections, the restaurants received scores that were 10 or more points less than the scores the restaurants had received on their prior inspection (when the auditors were not present). For only two inspections did the restaurant receive a higher score when the inspector was accompanied by a member of the audit team.
Under the proposed regulations, inspectors will be required to complete a food safety training program (or qualify for professional registration), complete

eight hours of food safety continuing education every two years, and successfully complete a program in food safety standardization. Current employees would have two years to complete these requirements; new employees would have 12 months.

The Program should be commended for taking steps to revise the current regulations. In addition to adopting the regulations proposed by the Program, DHR should establish procedures for ensuring that the regulations are complied with by all of the county health departments.

Recommendation No. 5

Restaurants that are cited for serious de-

ficiencies should be re-inspected in a

timely manner to verify they no longer

pose a serious public health risk.

Current DHR regulations require restau-

rants to correct hazardous (category I) defi-

ciencies immediately and critical (category

II) deficiencies within 72 hours. The regu-

lations, however, do not specifically require

county health departments to conduct re-

inspections to verify that all of the deficien-

cies have been cor-

rected (if they were Absent specific regu-

not corrected at the time of the inspection) or to verify that the restaurants

latory guidance from DHR, counties have developed their own re-inspection policies.

are operating in

compliance with food safety standards. Ab-

sent specific regulatory guidance from

DHR, counties have developed their own

re-inspection policies. As discussed below,

the counties' policies differ substantially

from one another and do not always ensure

that restaurants cited for serious deficien-

cies are re-inspected in a timely manner.

For category I deficiencies, most county health departments indicated they would

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Exhibit 4

COUNTY HEALTH DEPARTMENT RE-INSPECTION POLICIES 1

County RE-INSPECT OR RE-VISIT: A Within 24-48 hours if score is 70 or less, within 30 days if score is between 70 and 80 B In 90 days if score is less than 80 C Within 72 hours D If score is 85 or less and there is a combination of Category I and Category II deficiencies E Within 2 weeks if score is less than 90 F At environmentalist's discretion based on such factors as severity of violation, repeat violations G If score is less than 70 H At environmentalist's discretion I Monthly if score less than 90, until "back in line" J At next routine inspection K Within 72 hours if more than 3 Category II violations L "in a week or so" M Within 7-10 days if score is less than 85 N If score is less than 85 O Within two weeks if score is less than 80, and/or there are major Category II violations P "Usually," if not corrected at time of inspection Q Within 7 days for Category I violations, within 30 days for Category II violations R If score is less than 90 S Within 24 hours for "critical" violations

1 Other than the general policy of following up on Category I violations within 24 hours if the violation was not corrected immediately. Source: On-site interviews with county health department personnel.

follow up within 24 hours if the deficiencies were not corrected on-site. Other than this general guideline, however, the counties have developed reinspection policies that differ substantially. As shown in Exhibit 4 above, one county does not conduct a reinspection unless the restaurant scores less than 70 - a score received by fewer than 1% of the 7,431 restaurants inspected by 18 of the 19 counties for which data was available. Another county's policy is to conduct a reinspection within 7 to 10 days if a restaurant scores 84 or below. A third county indicated it would probably conduct a re-inspection if the restaurant

scored less than 90 and there were any serious deficiencies.
Our review of the most recent restaurant inspection reports indicated that restaurants cited for serious deficiencies are not always re-inspected. Of a sample of 568 restaurants that had been cited for two or more category I or category II deficiencies, 202 (36%) had not been reinspected (based on available documentation). It should be noted that different samples were reviewed in the counties due to differences in their re-inspection policies and filing systems.
The Department should revise its regula-

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tions to specify the circumstances that require a re-inspection and the time frame for conducting re-inspections. Action should also be taken to ensure that counties comply with the revised regulations.
In its written response, DHR indicated that it concurred with the recommendation. The Department noted, however, that the current regulations require county health departments to perform inspections as often as necessary to enforce the regulations.
Recommendation No. 6 Consideration should be given to increasing the penalty for restaurants that fail to post their most recent inspection report as required. Although restaurants that receive a low score are more likely (than other restaurants) to want to keep this information from potential diners, there is no substantial penalty for failing to post the inspection report. Using the current inspection form, only 2/3 point is deducted (from a maximum score of 100) for failing to post the previous inspection report. Using the Program's proposed inspection form, this would be considered a non-critical violation.
Because the inspection reports are one means citizens have of protecting themselves from foodborne illnesses, restaurants that fail to post the reports as required should be subject to more stringent penalties. One alternative (using the current form) would be to increase the number of points that are deducted. Another alternative would be to impose some type of monetary penalty.
In its written response, DHR noted that while the requirement for posting the most recent inspection form is an important consumer education and protection provision, failure to comply with the requirement does

not constitute a potential disease hazard. As a result, no additional deduction of points or other penalties would be appropriate.
Recommendation No. 7 The Department should consider requiring county health departments to inspect new restaurants within the first 60 days of their opening for business. Although health department personnel in the 19 sampled counties indicated they conducted on-site inspections prior to a restaurant opening for business, six of the 19 counties do not have a policy of inspecting restaurants shortly after they open (within 60 days). Without observing a restaurant preparing food and serving customers, health departments cannot ensure that restaurant personnel are aware of and in compliance with all of the health and sanitation standards.
In its written response, DHR noted that the pre-opening inspection process provides sufficient opportunities for assessing the capabilities of the restaurant manager and staff as well as the need for early inspections.
Recommendation No. 8 Action should be taken to ensure that county health departments have all of the equipment necessary to conduct thorough restaurant inspections. Currently, DHR does not have a list of the equipment that every county health department should use in conducting restaurant inspections. On-site reviews at 19 county health departments found a lack of uniformity in the type of equipment used by the inspectors. Six health departments, for example, do not use the thermocouple thermometers recommended by the U.S. Food and Drug Administration (FDA). Only one health department had pH meters and none

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had water-activity meters, recommended by the FDA for inspecting restaurants that perform complex food preparation.
In its written response, DHR indicated that it concurred with the recommendation and would develop a list of minimum required equipment and distribute it to the county health departments.
Swimming Pools
Recommendation No. 1 The Department should monitor the application of its swimming pool regulations to ensure that they do not result in pool operators being overly penalized for minor violations. Under the current regulations (which were adopted by DHR in November 2001), a swimming pool that is cited on a follow-up inspection for any repeat violation, including a non-substantial health hazard, is to receive an unsatisfactory rating. If, for example, a pool is cited on a routine inspection for failing to have a clock visible to spa users, the regulations require the pool receive an unsatisfactory rating if it is cited for the same violation on a follow-up inspection. The regulations do not address when a follow-up inspection should be conducted or if it should include all of the items on the checklist or only those items that were cited on the previous inspection.
The Department should monitor the manner in which the swimming pool regulations are applied by county health departments and should amend the regulations to specify when follow-up inspections should be conducted.
The Department has indicated its concurrence with the recommendation.

Tourist Accommodations
Recommendation No. 1 The Department should reconsider the need for county health departments to conduct routine inspections of tourist accommodations. Current DHR regulations specify that all tourist accommodations must be inspected no less than twice annually, with the The need for twice result that county yearly inspections of health departments tourist accommodaare spending ap- tions should be reproximately 6,400 considered. man-hours per year inspecting hotels and motels (2,135 facilities at 1.5 hours per inspection twice a year). As discussed in the following paragraphs, the need for these twice yearly inspections is questionable and should be reconsidered.
Although unsanitary conditions in a motel could affect public health, many of the items that are checked during the inspections are readily apparent to consumers. These items include the condition of the bathroom, clean sheets and towels, the availability of hot water, and protective covers on the drinking glasses. Items that might not or could not be checked by a consumer include the motel's ice machines, laundry, furnace, and water heaters.
Hotels and motels that are part of a national or regional chain (such as Wyndham and Best Western) are subject to periodic inspections by their corporate headquarters. Interviews with county personnel and motel management personnel indicated that these corporate inspections were more rigorous than the health department inspections.

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Health department officials in 10 of the 19 counties also questioned the need for routine inspections of tourist accommodations. Comments made by these officials included: if there's a program to ax, this is it; there's no significant health risk; and could do [an inspection] once a year for public relations.
The need for county health departments to conduct routine inspections of every tourist accommodation on a twice yearly basis should be reconsidered. Conducting inspections on an as-needed basis would result in counties having more time for inspecting restaurants and swimming pools (which pose a more serious public health risk).
In its written response, DHR indicated that it would explore the feasibility of adopting a variable frequency approach that would link inspection frequency to past performance, thereby better utilizing limited resources.
Recommendation No. 2 The Department needs to establish written procedures for conducting inspections of hotels, motels, and other types of tourist accommodations. Although the need for routine inspections of tourist accommodations is questionable (as discussed in the preceding finding), DHR should take steps to ensure that the inspections are conducted in a reasonably uniform manner throughout the state. On-site reviews conducted during the audit disclosed substantial differences among the counties in the percentage of rooms inspected and the items reviewed during the inspections.
The percentage of motel rooms inspected by each county health department varies substantially. Four of the

19 counties that were visited indicated they checked only two to four rooms per motel, regardless of the size of the facility. One county indicated it checked a 5% sample of rooms, nine counties indicated they checked a 10% sample, and one county indicated it checked a 2025% sample. It should be noted, however, that the percentage of rooms actually checked by the county's inspector did not always agree with the county's stated policy.
The items reviewed during the motel inspections also varied substantially among the 19 county health departments. In seven counties, for example, the inspectors did not examine the cleanliness of the bed sheets even though DHR personnel indicated that this was a primary reason for conducting the inspections. In one of these counties, the inspection consisted of little more than looking in the bathroom, looking under the bed, and opening a few drawers.
In six of the 19 counties, the inspectors did not check the motel's smoke detectors even though they were inside the room and only had to push the test button on the detector. Department personnel have indicated the smoke detectors should not be checked because they are the responsibility of the State Fire Marshal's Office (even though the DHR inspection form still includes this item). An interview with an official in the Fire Marshal's Office indicated, however, that tourist accommodations are not routinely inspected and that it would be prudent for county public health inspectors to check the condition of the fire extinguishers and smoke detectors during their inspections.

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Our on-site reviews also disclosed that six of the 19 county health departments are not using the DHR inspection form. The form used by three counties, for example, does not include three items included on the DHR form: (1) smoke detectors and fire extinguishers, (2) personal hygiene, and (3) permit displayed and inspection report posted as required. The number of points that is deducted for each item also differs from the DHR form. Another county is using a form that covers the same general areas as the DHR form (but in less detail).

The Department should develop formal guidelines regarding motel inspections outlining the percentage of rooms that should be inspected and the items that should be checked. Action should also be taken to formally clarify the responsibility of county health departments regarding the fire safety equipment in motels. Every county should be required to use the same inspection form.
The Department has indicated that guidelines will be developed for inspections of tourist accommodations.

Recommendation No. 1

Consideration should be given to amend-

ing current state law to provide for the

regulation of swimming pools at apart-

ment complexes, subdivisions, and coun-

try clubs.

Under current state law, only public swim-

ming pools that charge a daily access fee

and pools operated

Swimming pools at by municipalities,

apartment complexes, hotels/motels, and

subdivisions, and country clubs are currently exempt from

schools are subject to regulation by

having to comply with DHR. Environ-

state regulations.

mental health offi-

cials in all of the

19 counties visited as part of this audit indi-

cated that they did not agree with exempt-

ing public swimming pools at apartment

complexes, subdivisions, and country clubs.

As noted by one of the public health offi-

cials if we're gonna do it, let's check the

places where the public really is. Another

official expressed concern that the exemp-

tion leaves a big hole in the regulations. A

third official noted that people who live in

apartment complexes need the protection.

It should be noted that DHR personnel have indicated that swimming pools at apartment complexes, subdivisions, and country clubs are subject to regulation in about 24 counties, including most of the state's more populous counties. These counties were exempt (by statute) from complying with the state's regulations because they had their own swimming pool regulations in place as of December 31, 2000.
Recommendation No. 2 Although legislation was enacted in 1997 to provide for a civil penalty for restaurant workers who fail to wear an appropriate hair restraint, this legislation is not being enforced. Under the terms of the 1997 amendment, county boards of health are authorized to impose a fine of up to $50 on any restaurant worker involved in food preparation for a second or subsequent offense of failing to wear a hair net, hat, or other restraint. DHR personnel and some county health department officials indicated that this amendment is not enforceable. Officials in two county health departments noted that the term hair restraint is not defined and could

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include a bobby pin or hair spray. Personnel in DHR indicated that unrestrained hair did not constitute a significant health hazard and was not worth the effort of trying to issue a $50 fine. This data is presented for informational purposes only.
Recommendation No. 3 Consideration should be given to ensuring that all of the food service establishments, swimming pools, and tourist accommodations throughout the state are subject to uniform regulations. Under current state law, a county with a population of 550,000 or more is authorized to establish a board of health and wellness that has its own rules and regulations covering health and sanitation within the county. At the present time only Fulton County has exercised this option and established its own county board and its own health regulations. Interviews with DHR and Fulton County personnel indicated that the regulations that have been adopted by Fulton County with regard to food service establishments, swimming pools, and tourist ac-

commodations are in line with DHR's regulations. As a result of the 2000 census, however, three additional counties (Cobb, DeKalb, and Gwinnett) could create boards of health and wellness and establish their own sanitation regulations. Should any of these counties choose to exercise this option, there is no assurance they would adopt regulations that are in line with those established by DHR. As a result, restaurants in metropolitan Atlanta could be subject to different regulations depending on the county in which they were located.
Consideration should be given to specifying that counties eligible to adopt their own public health regulations may not establish regulations that are less stringent than those adopted by DHR. This would serve to ensure that all food service establishments, swimming pools, and tourist accommodations are subject to the same minimum standards, regardless of their location in the state.

For additional information, please contact Paul E. Bernard, Director, Performance Audit Operations Division, at 404.657.5220.

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Appendix A

Source: Program Records Food-Pool-Tourist Program

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Appendix B
Food Service Establishment Inspection Report Scoring Methodology

Enforcement is not based on the score. The category of the item violated determines the enforcement action.

Each category has a point value of 100; thus the cumulative point total of 300.

Scoring is as follows:

Category I

One item violated: Two items violated: Three items violated: Four items violated: Five items violated:

Deduct 20 points Deduct 40 points Deduct 60 points Deduct 80 points Deduct 100 points (maximum)

Category II and III

The evaluating official has three options. No violations, violations with minimum point value, or violations with maximum point value.

To compute the score to be posted, you total the points debited, subtract from the total point value (300) and divide by 3.

Total Point Value (300) - Total Points Debited = Score 3

NOTE: A maximum of 100 points is deducted for Category I items even if more
than five are violated. Category I items are to be corrected immediately and the method of correc-
tion noted at the bottom of the inspection form. The deduction of 20 points for each Category I item is to be made regardless of whether violation is corrected or not.
Source: Program Records

Food-Pool-Tourist Program

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Appendix C

Source: Program Records Food-Pool-Tourist Program

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Appendix D

Source: Program Records Food-Pool-Tourist Program

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Appendix E

GEORGIA DEPARTMENT OF HUMAN RESOURCES FOOD SERVICE ESTABLISHMENT INSPECTION REPORT
_______________________________________COUNTY

CURRENT GRADE

Name of Establishment:___________________________________________________ Address:_______________________________________________City:____________________________
Certified Food Safety Manager:____________________________________

Permit No.:

Inspection Date:

-

-

PREVIOUS GRADE

A means Food Safety Excellence No critical items violated, no more than three non-critical items violated and/or no reoccurring violations from last previous routine inspection.
B means Satisfactory No more than one critical item violated, no more than five non-critical items violated and/or no more than two reoccurring violations from last previous routine inspection.
U means Unsatisfactory No more than two critical items violated, no more than ten non-critical item violated and/or more than two reoccurring violations from last previous routine inspection.
F means Failure Three or more critical items violated and/or more than ten non-critical items violated.

Purpose of Inspection Routine Preliminary/Opening Follow-up Request Compliance

CRITICAL ITEMS-RISKS TO FOOD SAFETY (Rule number is noted if item is a violation) In means in Compliance Out means out of Compliance N.O. means Not Observed Mark N.A. if not applicable

Temperatures Potentially Hazardous Foods (*Place beside non-compliant temperature)

In Out N.O. _________ _________ _________

Demonstration of Knowledge Employee Health Conformance with HACCP Plan

Time/Temperature Controls

_________

Inadequate Cook

_________

Reheating for Hot Holding

_________

Cooling

_________

PHF Cold & Hot Holding

_________

Time as only Control

In Out N.O. _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________ _________

Food: Food from Approved Source Food Prep. for Highly Susceptible Pop. Protection from Contamination Date Marking & Discarding Proper Handwashing Good Hygienic Practices Prevention of Contamination from Hands Handwash Facilities Toxic Material Control Food Contact Surfaces Water Supply/Sewage System Plumbing Cross Connection

Temp F

Rule No. CRITICAL ITEM COMMENTS:

Rule No. NON-CRITICAL ITEMS-GENERAL OPERATION AND MAINTENANCE COMMENTS:

Signature of Person in Charge:
Source: Program Staff Food-Pool-Tourist Program

Inspected By:

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Appendix F

Source: Clarke County Environmental Health Food-Pool-Tourist Program

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