Restaurant 911: Prevent Imminent Health Hazard Closures

“Sorry, we’re closed”—These 3 words are possibly the worst a manager can hear from a health inspector. There are very specific events that can lead to an imminent health hazard closure. It could be an interruption in service in one facility or a large-scale emergency that could lead to all facilities closing down. It’s important to understand what could lead to a closure and how to develop plans to avoid it.

2009 FDA Food Code

Imminent health hazard means a significant threat or danger to health that is considered to exist when there is evidence sufficient to show that a product, practice, circumstances or event creates a situation that requires immediate correction or cessation of operation to prevent injury based on:

• The number of potential injuries
• The nature, severity and duration of the anticipated injury

What does this mean? The key part of this is evidence showing the immediate need for correction or cessation of operation to prevent injury or, more specifically, illness. The events that could cause this include loss of power, gas, hot and cold water, or a sewer backup. These events, if food service continues, could lead to foodborne illness.

The health department wants to ensure that no operations, such as food prep, warewashing, food service or any other actions that could compromise public health in the restaurant as a result of the event, continue. If a restaurant has any loss in service as described above, it should close until it has been corrected.

Crisis Management & Pre-Planning

When there is a loss in service, it’s important to correct it immediately and as quickly as possible so there is no interruption in daily operation and sales. The best way to make sure services are restored as quickly as possible is to line up approved repair companies or vendors that have quick response times, a high quality of work, and a clear understanding of restaurant needs. A list of who to call should be created before something breaks. Using vendors that have guaranteed response times is a must.

Have a Plan

Every restaurant will encounter these problems at some point in its operation, so it’s very important that there is a plan to mitigate any situation that could create an imminent health hazard until the repairs can be made. This plan should be trained on and practiced by all staff regularly. Here are some basic plans to mitigate the most common events. Every restaurant is different, so there may be additional points to add for customization. The first point in each plan should be making the appropriate calls to repair personnel as soon as possible. In the meantime, plans for loss of power, loss of hot or cold water service, sewer backup and large-scale emergencies can be put into place until service is restored.

Loss of Power

• Have refrigerator trucks available to keep food cold. This can be negotiated ahead of time with your main food distributors.
• Use dry ice. This can be placed in cold-holding units such as reach-ins and walk-ins to keep food cold until power is restored.
• Have flashlights and other emergency lights available with fresh batteries.
• Have a large commercial backup generator available.

No Hot or Cold Water Service 

• If there is no hot or cold water available for hand washing or warewashing, all food operations should cease.
• Set up temporary hand-wash sinks. There are companies that have portable hand-washing facilities available with water, soap and towels.
• Have extra, clean utensils available to switch out dirty ones until water is restored.

Sewer Backup

• Keep all food and equipment away from any wastewater coming out of drains.
• Install a sewer backflow prevention device. This may be expensive, but it might be worth it to ensure a sewer backup doesn’t interrupt your operation or lead to a closure.

Large-Scale Emergencies

Having a plan can allow any operation to seamlessly mitigate a crisis with a minimal loss in business. It could also lead to an increase in sales if a restaurant is the first to resume operations in the middle of a large-scale emergency such as an earthquake, flood or tornado. It could instantly lead to thousands of new customers if there is nowhere else to eat.

Start developing plans today to avoid an imminent health hazard tomorrow. With additional help in developing restaurant emergency plans, please contact me at dennis@resprofsp.com.