Scores on Doors - Food Safety

Scores on Doors Overview

My next couple of blogs will be focusing on the Scores on Doors scheme that is run as a joint venture between the NSW Food Authority and local councils.

According to the NSW Food Authority’s web site the goal is to:

“Scores on Doors allows the public to know how well food businesses are complying with food safety and hygiene requirements. The program requires participating businesses to display a certificate showing a star rating ranging from three stars, indicating a ‘good’ level of food safety compliance, to five stars, indicating an ‘excellent’ level of food safety compliance.”

So these blogs will be covering the topics of:

How does Scores on Doors Work?
What is the scoring system for Scores on Doors?
What are the problems with Scores on Doors?
What is good about Scores on Doors?
How badly can you fail and still pass?
Is a restaurant with 3-stars Scores on Doors safe to eat at?
Would my kitchen pass Scores on Doors?
Scores on Doors and temperature
Scores on Doors and hand washing
How can Scores on Doors be improved?

As a concept Scores on Doors is great. As a consumer it is great to know which restaurants are safe to eat at and which ones are pushing the legal boundaries.

The problem is with the final outcome. A restaurant will end up with:

5 stars = Excellent “The business has achieved the highest level of compliance with food safety standards.”
4 stars = Very good – “The business has very good food safety practices in place. Some minor areas where standards were not met will need to be addressed.”
3 stars = Good – “The business has a good standard of food safety compliance. A number of areas, although not serious, need to be corrected.”

It would also imply that there are 2 and 1 star restaurants that are below average – but there aren’t. Below 3 stars is a failure.

But here’s the big question – would you eat at a 3-star restaurant?

How Does Scores on Doors Work?

Scores on Doors is based on a demerit system. That is, a venue gains points for the more things it gets wrong. Depending upon how many points they get will determine their final rating.

For 5-stars they can score up to 3 points.
For 4-stars they can score up to 8 points.
For 3-stars they can score up to 15 points.

But wait, aren’t standards the minimum requirements?

So a 5-star restaurant is simply meeting its legal requirements for selling food to the public.

A 4-star restaurant is failing to meet its legal requirements but is still given a good outcome.

And a 3-star restaurant would imply that it is average, but it’s failing to meet its food safety requirements on a number of fronts.

If they fail more than 15 points the penalty is – nothing. They don’t get a sticker for the window.

So all the consumer has to do is avoid restaurants with no stickers. Alas, it’s not that simple. The program in voluntary. It is up to each restaurant to decide if they want to participate.

It is also up to each council to decide if they want to participate.

So a lack of sticker could mean the council isn’t participating, the restaurant isn’t participating, the restaurant didn’t want to display its 4-star award, or it bombed right out.

But maybe it’s very easy to lose points, and losing 15 points is no big deal.

Guess again. Currently a restaurant can lose a maximum of 120 points.

Here are some examples of problems and the points:

Food handlers wearing dirty clothes – one point
Single use items (e.g. drinking straws and disposable utensils) being reused – one point
Animals in areas where food is handled – one point
Cracked or chipped glasses and plates – one point
Food handlers smoking and spitting (yes spitting) in food handling areas … wait for it … four points.

Now imagine a restaurant failing those 5 issues and still getting a 4 star rating. They pass and would appear to pass reasonably well.

Spitting – four points!!!!

So how does Scores on Doors work? I’m not sure that it does.

Scores on Doors rating system

This section is basically a repeat of the sheet used by inspectors. This is it – the “exam”.

The Scores On Doors uses a “Food Premises Assessment Report” (FPAR) to try to have a uniform marking system in place. The current (version 3) scoring system is as follows:

General requirements

Food business has notified details to NSW Food Authority – 1 point
Food Safety Supervisor is appointed and FSS certificate is on the premises – 1point
Food handlers have skills and knowledge to handle food safely – 1 point
No sale of food that is damaged, deteriorated or perished; no use of cracked or dirty eggs or food past use by date – 4 points
Food Handling Controls FSS 3.2.2 cl 5-12
Food protected from the possibility of contamination; food receipt, storage, display and transport – 4 points
Names and addresses are available for manufacturer, supplier or importer of food – 1 point
Potentially hazardous food (PHF) is under temperature control: food receipt, storage, display and transport; less than 5 degrees, above 60 degrees Celsius. Frozen food is hard frozen – 1/4/8 points
Processing of foods; items thawed correctly; processed quickly; no contamination risk. – 4 points
Cooked PHF is cooled rapidly – 8 points
Reheating of PHF is rapid – oven, stove top or microwave but not bain marie – 8 points
Self serve food bar is supervised, has separate utensils and sneeze guard – 1 point
Food wraps and containers will not cause contamination – 1 point
Food for disposal is identified and separated from normal stock – 1 point
Health and Hygiene FSS 3.2.2 cl 13-18 Satisfactory
Food handlers wash and dry hands thoroughly using hand wash facilities – 4 points
Food handlers avoid unnecessary contact with ready to eat food or food contact surfaces by use of utensils, a gloved hand, food wraps etc – 1 point
Food handlers do not spit or smoke in food handling areas or eat over exposed food or food contact surfaces – 4 points
Food handlers have clean clothing, waterproof covering on bandages – 1 point
Food handlers wash hands before commencing/recommencing work and after: using the toilet, coughing, sneezing, smoking, handling raw meat, cleaning etc – 8 points
Food handlers do not handle food if ill (eg vomiting, gastro) – 8 points
Hand washing facilities easily accessible and used only for washing of hands, arms and face – 1 point
Hand washing facilities have warm running water through single spout, single use towels (or air dryer) and soap – 4/8 points
Cleaning and Sanitising FSS 3.2.2 cl 19-20
Premises, fixtures, fittings and equipment maintained to an appropriate standard of cleanliness – 1/4/8 points
Food contact surfaces, eating and drinking utensils in a clean and sanitary condition/appropriate sanitising method in use (eg chemicals or dishwasher) – 1/4/8 points
Miscellaneous FSS 3.2.2 cl 22-23
Accurate temperature measuring device readily accessible (eg digital probe thermometer) accurate to +/- 1 degree Celcius – 1 point
Single use items protected from contamination and not reused (eg drinking straws, disposable utensils) – 1 point
Animal and Pests FSS 3.2.2 cl24
Live animals not permitted in areas in which food is handled – 1 point
Practical pest exclusion measures used (eg screens, doorseals) – 1 point
Practical measures to eradicate and prevent harbourage of pests used (eg housekeeping, stock rotation, pest controller) – 1 point
No signs of insect infestation or rodent activity in premises – 1/4/8 point
Design and Construction
General design and construction of premises appropriate – 1 point
Adequate supply of potable water available – 1 point
Premises has adequate sewerage and waste water disposal system – 1 point
Premises has adequate storage facilities for garbage and recyclable matter – 1 point
Premises has sufficient lighting – 1 point
Floors are able to be effectively cleaned – 1 point
Walls and ceilings are sealed and able to be effectively cleaned – 1 point
Fixtures, fittings and equipment are able to be effectively cleaned and, if necessary, sanitised – 1 point
Adequate ventilation provided within the premises – 1 point
Premises has adequate storage facilities (eg chemicals) – 1 point
Maintenance
Premises, fixtures, fittings and equipment in a good state of repair and working order – 1 point
No chipped, broken or cracked eating or drinking utensils observed – 1 point
Labelling FSC Chapter 1
Food labelling complies with the Food Standards Code – 1 point
For ‘Standard food outlet’, nutrition information displayed – n/a points

It’s a simple check list, and the auditor just writes the number of points failed in one column and adds it up.

What are the problems with Scores on Doors?

Mediocrity isn’t excellence

Our biggest gripe with the Scores on Doors program is that it disguises a measure of mediocrity as a measure of excellence.

What?

It’s quite simple – if you see anything that is 5-star you expect it to be exceptional. You expect it to be the best.

With Scores on Doors, 5-star simply means they comply with the standards. Anywhere else it would be a “pass”. But with Scores on Doors passing gives you the best possible score available.

So it is making an acceptable performance look exceptional.

Why is this bad?

Because an exceptional restaurant has no benefit. A restaurant that goes beyond the minimum will receive no recognition of its efforts.

There is no benefit for a restaurant to put in the state of the art temperature monitoring system. There is no benefit for a restaurant to have exceptional training of staff. There is no benefit for a restaurant to have automated hand washing dispensers.

There is no benefit for a restaurant to be better than acceptable.

Bad is average

There is no 2-star or 1-star. It starts at 3-star.

But 3-star is meant to imply average. It’s the middle of the road on most other scales.

On Scores on Doors, the lowest score that is displayed is 3-stars. So a bad review gives an average result.

Failure is hidden

The third gripe is that failure is hidden. There is no requirement that a restaurant that failed to score 3-stars to do anything. Why not give them a big sign that says “FAILURE” or “CESS PIT”.

And restaurants that score only 3 or 4 star don’t have to display their poor performance.

So if the restaurant is doing poorly, just ignore it. If it fails, just ignore it.

A voluntary system is a joke. It fails to address the very people it is targeting.

It’s a lose/lose

Being totally blunt, it doesn’t reward excellence and it doesn’t punish failure. That is a lose/lose.

So what wins? Mediocrity.

As long as you do the minimum expected you will get 5-stars. As long as you don’t spend any more money beyond this, you maximise profits. There’s no benefit in being exceptional.

And if you bomb out totally, just don’t put up the results. It’s not like the customers are looking for your score card.

And even if they do see 3-stars, will it impact on business? No, because 3-stars means average and average is acceptable. It’s passable.

What is good about Scores on Doors?

There are some good things and these are a few of the benefits that Scores on Doors has to offer.

It’s a clear standard. The score sheet is a very simple check list to work through. It is standard across all councils, across all restaurants. That was one of the goals and it was definitely achieved.

There is some room for interpretation, and some of the issues can have 1,2 or 4 points. So it’s still not black and white, but I suspect that this is a good thing. Face it, if you walk into a bad restaurant you will want to slam it anyway you can and I like the concept that they can ramp it up in various categories.

The list covers 43 topics and that’s good. It is manageable but reasonably comprehensive.

The list isn’t super complex and a restaurant owner could work through the list (like in my previous blog) and ensure they comply. It beats working through hundreds of pages of standards.

Some of the categories can score 8 points which is an automatic failure.

Scores on Doors also really punishes two important food safety issues – hand washing and temperature. In fact, if you do poorly in either of these areas it is possible to rapidly rack up points across a number of categories and fail.

And that’s great news for OnSolution because we sell products for hand washing, hand washing training, and logging temperature.

Scores on Doors does also slowly change with time to add new tests in. It adapts to the current weaknesses in industry and tries to solve specific problems.

It’s not all bad. It’s heading in the right direction.

How badly can you fail Scores On Doors and still pass?

Since Scores On Doors isn’t actually measuring excellence, but just working out how bad you are, the question “how badly can you fail Scores on Doors and still pass” makes sense.

So the question is “what’s the worst we can squeeze in and pass?” Or, “what problems can I squeeze into 15 points and still pass?”

A hypothetical restaurant “McChunders” doesn’t have the best reputation. In fact the roaches have moved out after protesting about the conditions.

The first thing that hits you as you walk into McChunders is the smell. Not the aroma of burgers or baking bread, but rubbish. It’s piling up and it’s starting to smell. Enough to close it down? No, just one point.

In theory there would be pests associated with the rubbish, but it just gets tossed at the end of the day.

A quick glance around reveals the hand washing facilities which is a relief. That could easily clock up 21 points by not having the facilities (1 point) or using them when needed (20 points). So let’s assume they all have clean hands.

But wait, the water has backed up in the drain and is hovering an inch below the rim. Their hands may be clean but the sinks aren’t. So how many points for McFloaters? Inadequate sewerage and waste water disposal system – one point.

I also discover that the reason why there are no rats is because of the three cats. One of them is on the work bench. Animals in the food preparation area – one point.

And there are live chooks. But wait, that’s still just the one point.

To be totally clear on how the system works – McChunders is still eligible for 5-stars because it has only lost 3 points.

Then there’s Eddie the kitchen-hand eating a sandwich over the bench. Finally a decent penalty – four points. After eating, Eddie lights up and has a smoke. Wait, that’s the same 4 points. It doesn’t matter that he went from a couple bread crumbs to smoking.

But to top it off, he takes the cigarette out of his mouth, looks around for the garbage bin, snorts, and spits across the walkway into the bin. Guess what, it’s the same four points.

But why am I surprised because Eddie looks like one of those stereotypical rednecks with his clothing. He wipes his mouth with the back of his sleeve, looks at me and says “what’s your problem?” I feel like saying “the grease on your overalls” but hold my tongue. Dirty clothing – one point.

He raises his hand at me and gives me the bird. That’s when I see the blood stained band-aid limply holding on to his finger. Awesome, that’s worth…actually that’s the dirty clothing point.

So now, despite Eddie’s contributions, the restaurant is still eligible for 4-star rating.

Now let’s go for a big one (as if spitting wasn’t enough) – the use of dirty eggs. In recent years the biggest outbreaks of food poisoning have been as a result of contamination from fresh eggs, and that contamination tends to come from the outside of the eggs, not the inside.

So here is a restaurant that has fresh eggs (remember the chooks). And like farm fresh eggs, they are covered in chook…stuff. Since this is known to cause massive food poisoning outbreaks it must be enough to fail the restaurant. Nope – 4-points.

I wander out into the seating area. There’s a salad bar up the back. By salad bar I mean table. And standing over it is a mother with her young kids making a mad grab for whatever they can. The spoons go from bowl to bowl. No supervisor and no dedicated utensils – one point. And then the feeding frenzy is broken by one of the kids sneezing all over the salads. The kids yell “gross” and then leave the table. Still the one point.

Eventually the waiter comes out and takes one of the bowls back into the kitchen and puts it next to the other bowls of salad. Food for disposal not separated from normal stock – one point.

And that leaves McChunders with one point spare to still have a 3-star rating.

Is a restaurant with 3-stars Scores On Doors safe to eat at?

That up there with:

Can I leave my cat alone with my canary?
Can I run across the road without looking?
Is it safe to play Russian Roulette with a gun that has only one bullet in it?

The answer to all of them is “yes, but eventually you are going to regret it”.

Would my kitchen pass Scores on Doors?

So we have just cracked down on restaurants, but let’s be honest, would my kitchen pass Scores on Doors?

We did two levels of tests – the day to day test and the guest test. In theory we have higher standards for guests, and face it, restaurants are serving guests.

The first 3 criteria, no problems, though we are ignoring ones that don’t apply (like registration).

Criteria 4 – no food past its use by date. Personal use – fail. Guests – pass. Yes I am happy to eat food past its use by date but with a careful check. Face it, we all know that the food is 100% acceptable up to the use by date. It is impossible for it to go from 100% good to %100 bad in an instant.

I feel a bit ripped off. That’s 4 points for personal consumption just because my yoghurt is 2 days over the use by date.

Food storage and heating no problems. But then the crunch – items thawed correctly. How often do I leave the frozen meat out all day to thaw? Actually I’ve improved quite a bit since being in the industry so since today there is nothing sitting around thawing, I pass. Yes.

Hand washing is a breeze. We have the facilities and we remind everyone to wash their hands before preparing food, coming to the table etc etc etc.

Since my wife cleaned the kitchen this morning, it is spotless. So we pass the clean surfaces test. And when guests are over, it is immaculate. But that’s a bit hit and miss. If it had been the teenagers cleaning the kitchen, I could have been clocking up some points.

Temperature measuring. For most domestic kitchens they would be failing but I sell the devices, so I pass. That’s one point for the rest of you.

No animals in food handling area. That depends on where the inspector would draw the line. The dogs sit on their mats at night in the dining room, but it’s a kitchen/dining room. So probably a point.

The maintenance of the place is reasonably good, but there are some broken doors so that’s a point.

And some of the plates have chips, but not for guests. They have “the good stuff”.

So for the domestic kitchen I scored 7 points (and 4 of them for old yoghurt!) and for the guest days 3 points.

So for guests I have a 5-star kitchen and for day to day existence I’m down to a 4-star.

By this it is obvious that we can easily survive with a less than 5-star restaurant but my wife likes to point out that there is a big difference between your own dirt and someone else’s dirt. And there’s a big difference between giving yourself food poisoning and giving your guests food poisoning.

And there’s a big difference between giving your 4 guests food poisoning and giving 177 customers food poisoning.

Now if I went back and did the test “Would my teenage sons pass Scores on Doors?” it would be another answer. But we won’t go there.

Scores on Doors and hand washing

Scores On Doors heavily penalises food premises that do not ensure that staff are correctly washing their hands.

Given that dirty hands are one of the most efficient means of cross contaminating food and spreading germs, and is one of the simplest to avoid, it makes sense that it is heavily policed.

Currently the points relating to hand washing are:

14: Food handlers wash and dry hands thoroughly using hand wash facilities – 1 point
18: Food handlers wash hands before commencing/recommencing work and after: using the toilet, sneezing, smoking, handling raw meat, cleaning – 8 points (that’s an automatic fail)
20: Food washing facilities easily accessible and used only for washing of hands, arms and face – 1 point
21: Hand washing facilities have warm running water through single spout, single use towels and soap – 4 or 8 points (another automatic fail)

So not only is it possible to score 18 points for incorrect hand washing, it is possible to have two automatic failures.

So what can a business do to ensure they aren’t penalised?

Start with the easy (I didn’t say cheap, I said easy) things that don’t relate to people. Ensure that the facilities are there, are available, and are working. This may mean ensuring that there are other sinks available for the preparation of food.

Then next to the basin put in a fixed hand wash dispenser like OxyBAC. You want to use a hand wash that is designed for frequent use, is not rough on sensitive hands (otherwise your staff won’t use it) and is fast acting. Like I said, Oxybac J

Then ensure that your procedures clearly state when staff are to wash their hands.

Now for the hard part – convincing your staff to wash their hands. Telling staff they need to wash their hands, and policing it are both important, but you have to convince staff that it is in everyone’s best interest to regularly wash their hands.

We recommend Glitterbug Potion for training. It is a fun way to show people how poorly they wash their hands, and how they can’t assume they know how to wash their hands. It is used as part of many food safety training courses, but we recommend that all food premises use it to train their own staff.

Scores on Doors and temperature

Scores on Doors also heavily penalise food based on incorrect temperatures.

Like dirty hands, the temperature of food is one of the biggest contributors to food poisoning and one that can now be easily avoided.

Bacteria flourishes between 5° and 60°. Above 60° it is killed, and below 5° it slows down. So the standards are about trying to keep the food out of the 5° to 60° range, or minimise the time it is within this range.

The points relating to temperature include:

7: Potentially hazardous food (PHF) is under temperature control: food receipt, storage, display and transport; less than 5°C, above 60°C. Frozen food is hard frozen. – 1, 4 or 8 points

8: Processing of foods; items thawed correctly; processed quickly; no contamination risk. – 4 points

9: Cooked PHF is cooled rapidly – 8 points

10: Reheating of PHF is rapid – oven, storve top or microwave but not bain marie – 8 points

That’s up to 28 points relating to temperature, and 3 potential automatic failures.

On the topic of temperature there is a large amount we can say (and have, over many blogs), but following are some key points:

Ensure that all storage areas are monitored and the results reliably recorded. The best solution is a temperature logger such as Logtag or Thermocron.
Likewise monitor all vehicles with a temperature logger. For caterers, if items are stored in an esky or larger container then log them as well.
When heating or cooling food, ensure that you are doing it quickly. Many of our customers have placed a Thermocron in the middle of a pot to log the heating and cooling process. For many, the results meant using different shaped containers or smaller containers to ensure they complied.
Food grade thermometers are essential. Cheap thermometers that don’t indicate their accuracy are not compliant.
Infrared thermometers (the “guns”) are OK at testing temperature when receiving items, but are prone to operator error and the user must know their limitations.
Be very careful about food that is outside a controlled environment. This is typically food that is moving from one store to another (e.g. the delivery vehicle to the fridges, fridges to display cabinets). Ensure that PHF can’t be accidentally left out.

How can Scores on Doors be improved?

Following are my thoughts on how Scores on Doors can be improved. I’m not saying that my suggestions are perfect, and it would be great if someone did debate the points I make. There are issues with my proposals, but I think my proposals are worth mentioning.

Show passing as a pass

Simply put, remove two stars from the existing scores.

So a premise that meets the legal requirements will score 3 points. Any premise that doesn’t will score 2, 1 or 0 points.

Then there would be a huge impact on business for restaurants that aren’t fully compliant.

Strive for excellence, not compliance

Using 3-stars for compliance means that there are now 2 stars free to show excellence. Bonus points can then be applied to businesses that score a 3-star rating. These bonus points are then used to determine if the business is eligible for an extra one or two stars.

And since it only applies to venues that have already scored 3-stars, it ensures that across the board compliance is achieved.

Each of the categories can be reviewed to determine what is best practice, not just what is required.

For example, bonus points can be given for

venues that use temperature loggers and not just thermometers.
the training levels of all staff
automated hand wash dispensers
businesses that regularly use biological tests on surfaces

Then hopefully, as time goes on, these practices become standard practice, and become part of the standards. They then contribute to the pass mark, and new “best practices” are identified.

Mandatory

Make it mandatory.

As a consumer, I think that it is reasonable to be informed that a restaurant is failing to comply with the food safety standards.

Public

Build upon the name-and-shame web site and have the results from all restaurants uploaded to a web site.

With the results only shown on the door, it isn’t until a customer has booked and arrived that they see the results. Why not allow people to check out the results online before they arrive?

Why not go a step further and have the results in Google Maps? Imagine being able to check out what restaurants are in the local area, and see the results!!!