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Take Active Control of Food Safety

January 31, 2020

Original content c/o: National Restaurant Association

National Restaurant Association webinar explains how an Active Managerial Control (AMC) system can help you improve food safety and reduce inspection violations.

Restaurants with good food safety management systems had half as many risk factors and out-of-compliance food safety practices as those without such systems in place.

In a webinar hosted by the National Restaurant Association, Charles S. Otto III, independent consultant, EAS Consulting Group LLC, Alexandria, Va., looked at the concept of Active Managerial Control programs, why they’re an effective way to help operators dramatically cut their food safety risks, and how to get started on implementing your own program. Put simply, an AMC plans, like a HACCP plan, is a type of food safety management system (FSMS). AMC programs focus on proactive steps and training to reduce food safety risks.

Common risk factors are improper cooking temperatures and time and temperature abuse of food.

Otto, a former deputy chief at the Centers for Disease Control and Prevention, noted that every year about 48 million people get sick from foodborne illnesses. Of those, about 128,000 are hospitalized and 3,000 die, according to CDC.

The economic impact on restaurants is huge, with costs ranging to more than $1.9 million for a fast food restaurant, $2.1 million for a fast-casual restaurant and $2.6 million for a white tablecloth restaurant for each foodborne illness incident.

Poor employee health and hygiene is another risk factor that could lead to an illness outbreak.


Otto says common risk factors are:

  1. Unsafe food source
  2. Poor employee health and hygiene
  3. Improper cooking temperatures
  4. Time and temperature abuse of foods
  5. Contaminated equipment

The CDC’s Environmental Health Services found that the top four contributing factors in outbreaks are:

  • Sick food workers contaminate ready-to-eat foods through bare-hand contact.
  • Sick food workers contaminate food through some other method, such as with a utensil they contaminated.
  • Sick food workers contaminate ready-to-eat food through glove-hand contact.
  • Food handling practices, such as not keeping food cold enough, lead to growth of pathogens.

How to cut the risk of foodborne illness

Restaurants with good food safety management systems, however, had half as many risk factors and out-of-compliance food safety practices as those without such systems in place, Otto says.

Active Managerial Control systems offer a proactive way to continuously improve your food safety management. Like a HACCP program, it starts with assessing the food safety risks in your operation, from sourcing to serving.

While putting an AMC program in place may seem daunting, Otto suggests looking at your highest risk first, and starting simply with one policy for your staff to mitigate risks, and one policy for a menu production process.

For example, a staff policy might be “All food employees are responsible for ensuring employees are in a healthy state while working…” A process policy might be something like “All food employees are responsible for cold holding of time/temperature control for safety (TCS) foods at or below 41°F.”

From there, you can customize and expand an AMC program to cover more aspects of your operation, including facilities, equipment, processes, staff, menu changes, and delivery. 

How to design an active managerial control system

To explain how to design an AMC system, Robert Stratman, managing supervisor, Maricopa County Environmental Services Dept., Phoenix, Ariz., referred to the AMC program created by the county’s Environmental Health Division. Stratman’s department created a toolbox with a complete set of materials to help operators develop and implement their own AMC system.

As an example, he showed how the site’s employee health policy template walks operators through:

  • why a health policy is important to have;
  • who it applies to;
  • when the policy should be performed or applied;
  • where it takes place;
  • how it ensures that employees are healthy;
  • the corrective action to take if an employee is sick;
  • monitoring steps to take to make sure staff is healthy;
  • training required to make the policy effective;
  • and verification that the policy is working and enforced.

Maricopa County held a two-hour class for operators on the health policy toolkit and how to implement an AMC. Before the class, operators in attendance had an average 2.04 priority food code violations per inspection.

After the class, operators experienced an average .71 priority violations on their first inspection, which rose only slightly to .86 violations on their fourth post-class inspection.

During National Food Safety Month last September, the Association introduced the concept of FSMS, and used Fairfax County, Va., as another successful example of an AMC in action. The county’s program results were shared in this webinar, too.

Ultimately, an AMC can help you reduce the the risk of a a foodborne illness by taking a proactive approach to creating a safer foodservice environment.


AMC Program Guide
An AMC program should include:

  1. Written policies. Policy statements set expectations for employees. For example, the policy for cold holding might be that all Temperature Controlled for Safety (TCS) food will be kept refrigerated below 41°F.
  2. Training. All staff should be trained on the policies. As part of a cold-holding policy, all food preparation staff should be trained that TCS food should be 41°F or less. The person in charge should not be the only person who is aware of and responsible for following the policies.
  3. Monitoring (a method for verifying that employees follow specific policies). A temperature log for checking temperatures of TCS foods throughout the day is one means of monitoring a cold holding policy, for example.
  4. Corrective action (what to do if the monitoring shows that a policy is not met). The corrective action should be part of the policy statement. For example, does the cold- holding policy tell staff what to do if the TCS food is out of temperature on the temperature log?

(Fairfax County, Va., Health Department AMC Toolkit)