Reorienting food safety inspections: a new model for regulatory practice Open Access

Foodborne illness presents a significant threat to global public health, resulting in 600 million cases in 2010 (Havelaar et al., 2015). Worldwide, food safety inspections are a key health-protection measure used by governments to prevent foodborne illness. Food safety inspections are largely undertaken by Environmental Health Practitioners (EHPs) as a primary function of their food safety regulation role. Yet, while countless food safety inspections are performed by EHPs across the globe each year, there is currently a lack of guidance available on how best to perform these inspections (Almanza et al., 2014). Despite this lack of guidance, EHPs across a number of countries have largely converged on a common approach to performing food safety inspections with some divergences influenced by individual and social factors (Barnes et al., 2024a).

Although there is a common approach to performing food safety inspections, this approach is not without limitations. These limitations include the lack of a rigorous methodology, a lack of comprehensiveness in data being gathered to inform decisions, a lack of coherence in linking evidence to meaning and a failure to attend to bias (Barnes et al., 2024b). To address the shortcomings of the current approach to food safety inspection, a rigorous food safety inspection methodology is required (Barnes et al., 2024b). Furthermore, the methodology must step beyond a compliance check that evaluates compliance of a food premises with a set of prescribed criteria, toward adopting a food safety risk assessment ideology that comprehensively examines food safety control (Barnes et al., 2024a). A recent study by Barnes et al. (2024a) proposed that food safety inspection should be viewed as a form of qualitative field research. This approach provides an opportunity to draw from a well-established body of knowledge on approaches to maintaining rigor (Barnes et al., 2024b). In the domain of qualitative research, rigor is equated with the trustworthiness of research practices and findings, where the credibility, transferability, dependability and confirmability of the research are all determinant of rigor (Lincoln and Guba, 1985).

While rigor in quantitative research is associated with validity and repeatability, qualitative research generates different types of knowledge where these attributes and qualities are not applicable (Lincoln and Guba, 1985; Miles and Huberman, 1994). This could explain some of the typical criticisms levelled at food safety inspections, where the expectations of inspection practices do not align with the type of products that qualitative research is capable of producing (Barnes et al., 2022). Accordingly, as a means to devise a more rigorous food safety inspection methodology, Lincoln and Guba’s (1985) framework has been adapted to complement the food safety inspection context and tailor strategies for promoting trustworthiness in food safety inspection. Although various frameworks for establishing trustworthiness in qualitative research are available, Lincoln and Guba’s (1985) framework was selected to guide the model as it is a widely accepted framework in qualitative research disciplines, and it provides a comprehensive array of strategies for establishing trustworthiness that are practical and readily adaptable. Thus, by combining the recommendations of Barnes et al. (2024b) to overcome the limitations of current food safety inspection practice with devices adapted from the framework for establishing trustworthiness in qualitative research by Lincoln and Guba (1985), the Barnes model for food safety inspection was proposed to provide a more robust methodology for food safety inspection (Supplementary Table 1).

This study defines the Barnes model of food safety inspection and posits it as an effective health protection measure that adapts and applies conventions of qualitative field research to conduct food safety inspections. Training materials were created and provided to EHPs to support them interpreting and implementing the Barnes model of food safety inspection in field trials. Field observations and interviews were then conducted to evaluate the efficacy and practicability of utilizing the Barnes model and to identify barriers to implementation. The findings from this study will inform food safety regulatory practice by determining whether the Barnes model can be adopted and implemented by EHPs into their regulatory practice.

A model methodology for food safety inspection was constructed by:

1. Documenting current food safety inspection approaches (Barnes et al., 2024a).

2. Identifying limitations of the current common approach to food safety inspection (Barnes et al., 2024b).

3. Adapting Lincoln and Guba’s framework for trustworthiness in qualitative research (Lincoln and Guba, 1985) to the food safety inspection context.

The model methodology for food safety inspection was designed with a view to integrate complimentary aspects of current food safety inspection practices with new strategies that sought to overcome limitations of the current common approach to food safety inspection. The model comprises seven functions that occur outside of a food safety inspection cycle, and 16 actions that occur within the five major phases of a food safety inspection.

Instructional materials were devised for EHPs, including:

1. A summary of the Barnes model (Supplementary Table 1).

2. Guidelines that provide further descriptions and details of the components of the Barnes model (Supplementary Table 2).

3. A table detailing recommended changes to the current common approach to food safety inspection (Supplementary Table 3).

4. An explanatory video detailing the additional inspection conventions and where they should be applied in the inspection process. Video Link: https://share.voomly.com/v/FVna2bFfXrHBUYkc11hjitQZj83mRzKL1SQM_ndDeNKmbT0hS.

The aim of producing this material was to support EHPs understanding the components of the Barnes model and how they might be implemented into practice, including details on their timing, depth, relativity and rationale. Directly evaluating the effectiveness and quality of these instructional materials was outside the scope of this research, yet their interpretability and consequent impact on EHPs’ ability to implement the Barnes model was investigated.

The aim of this study was to determine whether the Barnes model can be effectively implemented into food safety inspection practices by Environmental Health Practitioners.

Australian Environmental Health Practitioners were invited to register their interest in participating in this research. Participants were selected based on their workplace’s geographical setting, with four EHPs selected to represent metropolitan, major city, regional and rural areas (see Table 1). The instructional/training materials were distributed to the participants and most participants opted for a period of approximately four weeks to review the materials.

Immediately prior to undertaking an observed food safety inspection, a semi-structured interview was conducted with participants. The interview schedule (Supplementary Table 4), comprised of eight questions that were aimed at understanding the participants’ views on the practicability of implementing the proposed model into their usual inspection practices, strengths and weaknesses of the model in terms of applicability and utility and the interpretability and impact of instructional materials on implementation of the model.

Following the completion of the semi-structured interview, participants were observed undertaking a food safety inspection during which they applied the Barnes model of inspection. During the field observations, participants’ actions and discussions were observed and noted. Where necessary, inspectors were asked to describe the intent of their actions, and the influence of phenomena and stimuli on their thoughts and their assessment of risk where this was not apparent. The field observations were aimed at gathering data on the practicality of implementing the inspection model, and the methodological strength of the model when it is applied to practice. Observations were performed to capture preparative processes that occurred at the inspectors’ workplaces, during the inspection at the food business, and to capture reporting and summative processes that occurred following the inspection, including note and report writing and debriefing.

Following the observed food safety inspection, a second semi-structured interview was undertaken with the participants. The interview schedule (Supplementary Table 5) comprised seven questions that sought to explore the participants’ experience in applying the inspection model. These questions were aimed at capturing data on the functionality, practicality and applicability of implementing the model.

Interviews undertaken with participants were recorded, transcribed and thematically analyzed using a deductive approach. A thematic framework devised from the research questions was used to guide this deductive analysis where manual coding was undertaken by the lead researcher and later moderated by the two contributing researchers. Field observation notes were used to verify themes identified in interview data.

A table detailing phases of the research is provided in Supplementary Table 6.

This research was approved by the Flinders University Human Research Ethics Committee (Reference HREC #5058).

All principal and supporting participants in this study were employed in Australian local governments. Further details of participant demographics are provided in Table 1.

For one principal participant, the Barnes model for food safety inspection closely reflected their natural style of performing food safety inspections, requiring only minor adjustments and minor enhancement of some activities that they were routinely undertaking. For others, the Barnes model represented a more notable contrast to their natural style and required further reconceptualization and reorientation of their normal practice to facilitate integration. Nonetheless, all principal participants reported the alignment of their natural approaches of performing food safety inspections with a risk-based approach and this stood to advance integration of the Barnes model as fundamental concepts underpinning the model were already axiomatic. Accordingly, established ideologies underpinning food safety inspection observed amongst principal participants were situated differently in their focus of measurement. While some were leaning toward measurement of control as is promoted by the Barnes model, others acted to measure control but their conceptualization of the data gathered and their subsequent determinations reflected a stronger alignment with measurement of compliance.

A key area of inquiry in this pilot research related to the functionality of the Barnes model. Results indicate that the model was generally deemed functional by participants, suiting its intended purpose. Three particular attributes of the model’s functionality were noted by participants.

Structure and clarity of the Barnes model were deemed advantageous attributes that contributed to its functionality.

The Barnes model was viewed to drive a greater level of comprehensiveness of inspections and the data gathered through the process.

Integration of the peer debrief stage of the model was viewed by participants as particularly useful in identifying data gaps and bias.

Participants identified that more detail was required in the Barnes model training materials to convey meaning and clarity of instruction. They also noted that the use of language needs to be suitable for practitioner interpretation, while communication mediums should be diversified.

Functionality of the Barnes model was identified to be influenced by two major aspects.

Firstly, officer training and competency was noted by participants to likely impact the wider EHP workforce’s ability to interpret and implement the model. Currently, very little training is provided to EHPs on how to perform food safety inspections. Participants recalled that earlier inspections in their career were very compliance-centric. They reflected that the skill, knowledge and competency they have gained through their personal career development supported them to be able to implement a more risk-based ideology in their inspection approach.

Secondly, participants reflected that a key barrier for EHPs would be the additional time needed for professional development to effectively implement the model. Competing obligations of the role, including other aspects of environmental health practice, local performance objectives such as the number of inspections being valued rather than quality of inspection and a lack of flexibility in their schedule make it challenging to be able to maintain their skills and capabilities.

These two barriers to functionality of the model may also converge, particularly where an inspector’s comprehension of Hazard Analysis and Critical Control Point [planning] (HACCP) and its underpinning principles are deficient. This barrier to functionality, however, was not observed in this pilot research as all participants demonstrated that they held a strong working knowledge of HACCP and its underpinning principles.

A second key area of inquiry in this pilot research related to the practicality of the Barnes model. Results indicate that the model was generally deemed practical by participants. Two particular attributes of the model’s practicality were noted by participants.

The structured approach driven by the Barnes model was viewed as supportive to EHPs achieving a systematic assessment of food safety.

The Barnes model was also recognized as advantageous in highlighting data gaps to EHPs.

Participant observations also demonstrated that the Barnes model is implicitly practical, although two minor revisions (outlined below) to the model may work to improve its practicality. All participants also identified these areas for improvement and proffered possible means to resolution.

Firstly, simultaneous note taking using thick description was identified as impractical in light of all other tasks that the EHP must undertake during the onsite element of inspection. It was suggested that simultaneous note taking could be substituted for contemporaneous note taking using thick description. Note taking onsite is still required but only as shorthand prompts and reminders while more detailed notes can be made at another time.

Secondly, the sample framing stage requires integration of a further mechanism to make assessment of control more practical. Rather than examining every instance where controls are applied, comparable control methods need to be clustered together and examined once.

Practicality of the Barnes model was identified to be influenced by two major aspects.

Firstly, participants reflected on the challenges that can arise when attempting to identify an optimal time for inspecting. The Barnes model positions optimal time as the time that the EHP is most likely to be able to obtain data and compare data across various sources. Some participants remarked that optimal time should not be dictated by the convenience to the food business and that the model would value from this being outlined more explicitly. One participant also noted that careful planning should be made using knowledge or general practices of the business type. Where sub-optimal timing is identified, the EHP needs to use discretion with respect to continuing with data gathering using limited sources and engaging with other data sources at a later time, or abandon the inspection and return at another time. To maintain practicality, EHPs require the necessary skills to identify optimal times for inspection and the discretion to apply other data gathering methods or reschedule the inspection.

Further to this, some participants identified that finding an optimal time is not analogous with making an appointment with the food business to undertake an inspection. Their view was that notifying a food business of the intention to inspect may not provide a faithful representation of food safety risk presented by the business.

Secondly, participants explained that EHPs need to be afforded autonomy by policy to truly apply the model in a practical way and derive the benefits. This means professional discretion needs to be supported for EHPs in determining risk, in determining inspection outcomes and administering prescriptive processes that are most suited to motivating relevant and sustainable change to maintain food safety at the food business.

The third key area of inquiry was related to the applicability of the Barnes model. Results indicate that the model was generally deemed applicable and compatible by participants. Two particular attributes of the model’s applicability were noted as strengths by participants.

Many elements of the model already feature in EHP practice which demonstrates it is largely applicable. The model provides a viable means of performing a systematic assessment of food safety risk in most situations.

Although the model may require more time to administer than a more traditional compliance check approach, it prevents more significant costs by facilitating systematic and comprehensive data gathering (described as thoroughness by respondents). This also supports EHPs feeling that they are fulfilling obligations of their role, maintaining trust, reputation and self-confidence.

Participants identified that training materials for the Barnes model need to be better tailored to the needs of the audience, particularly the detail of information and the use of accessible language.

Other participants provided further explanations of their difficulties interpreting the training materials and offered solutions on how it may be addressed.

The Barnes model specifically placed the review of historical records after the inspection had taken place. This is largely due to the findings of Ibanez and Toffel (2020) that inspector familiarity with compliance history can introduce a framing bias amongst EHPs with an emphasis on previous non-compliances. However, one respondent highlighted that a review of records can act to support EHPs in undertaking more complex tasks than compliance checking. Instead, a review of compliance history prior to undertaking the inspection can support EHPs developing rudimentary research instruments that can assist their measurement of attitude and food safety culture. It can also inform devices they apply to build rapport, identify possible knowledge deficits that may need to be addressed during the inspection or even shape motivators for behavior change.

Participants identified four situations when the applicability of the Barnes model may have shortcomings, but these views were not unanimous amongst all participants.

Firstly, dysfunctional and disadvantaged premises may not provide for complete application of the model in the first instance of engagement. It could be helpful to guide the prioritization of items for action but full application of the model may not be possible or relevant until repeat engagements with these businesses.

Premises with no critical control points (CCPs) in their food handling practices were identified as possibly lacking compatibility for the model.

One participant also identified that premises that are subject to annual third-party audits may diminish the necessity of applying the model as it will likely duplicate findings and effort.

Finally, the model was identified as being incompatible for inspecting temporary food stalls trading at events because the model would require too much time to perform the inspection.

Yet, this position was countered by another participant who offered an example of how these resource imposts may be overcome.

Through interviews and field observations of EHPs trialing the model, the findings of this pilot research indicate that the Barnes model is largely functional, practical and applicable for use in regulatory practice, providing EHPs with a systematic and comprehensive methodology for assessing food safety at food businesses. Although the logic of the model was not the focus of this pilot research, it was also observed to be effective and functional in driving a comprehensive focus on food safety control during inspections. Further investigation of the logic and effectiveness of the model inspection methodology is necessary to evaluate whether the model should be adopted and embedded into practice by inspectors.

This pilot research identified that training materials for supporting the adoption and implementation of the Barnes model into regulatory practice require revision and reconceptualization where they are tailored specifically to the needs of the three primary audiences, scilicet, EHPs, policy makers and tertiary educators. In doing so, it is envisaged that the training materials will be made more accessible and relevant to these audiences, removing barriers of complexity and inaccessible language identified by participants as a barrier to practitioners interpreting the training material.

The Barnes model has been revised following findings from this pilot research, comprising one modification and two minor enhancements (Table 2). The modification involves a repositioning of the timing of note taking during the onsite element of a food safety inspection. While the proposed model anticipated the fact that detailed and descriptive notes would be taken simultaneously with the onsite element of a food safety inspection, the observed and reported difficulty of taking detailed notes during this phase of the inspection has resulted in the revised model adopting a position of contemporaneous note taking instead. The first enhancement of the model involves the addition of further guidance for practitioners on setting an inspection sample frame and clustering comparable food handling points and processes together, rather than examining each individually. The second enhancement pertains to providing practitioners with more explicit instruction when identifying an optimal time to undertake a food safety inspection, clarifying that this model component refers to identifying an optimal time to gather comprehensive data but this does not necessitate prior notification of the food business of the intention to inspect, and that optimal time for the purposes of the model may not align with what a food business views as an optimal time.

One participant reported uncertainty on the compatibility of the model inspection methodology, particularly in circumstances where a food business may have minimal or no critical control points in their food handling activities. This, however, may indicate a need for the reorientation of the conceptualization of control amongst EHPs. Codex Alimentarius provides the following definitions of control:

The definition of control provided in the context of HACCP bears reference to the overall compliance with food safety criteria in all aspects of the food business. Thus, control in this sense extends beyond the maintenance of control at critical control points. Accordingly, the Barnes model remains relevant to these circumstances, albeit with a reduced intensity in the examination of maintenance of control at critical control points.

Further uncertainty on the compatibility of the Barnes model was also identified by the participant for circumstances where a food business may receive third-party food safety audits, as well as inspecting temporary food premises. In these instances, the imputations for incompatibility appear to relate to the context of resource management and resource availability. For food businesses subject to a third-party audit, the incompatibility perceived of the model spanned from a basis of utility, as it was only likely to duplicate findings and effort already yielded and expended through the audit process. In contrast, the incompatibility perceived of the model to inspecting temporary and mobile food premises related to the constrained time resources available to inspectors in these circumstances. Although these factors may influence the implementation of the model in these circumstances, these factors do not represent a deficiency of the model, but rather reflect values, policies and practices of the inspector and their workplace that will shape how the Barnes model is implemented.

Correspondingly, the key finding of this pilot research is that the effective implementation of the model is not subject to attributes or aspects of the model, but rather to broader considerations and decision making on how the model is implemented by the inspector as shaped by their organizational practices. The findings of this pilot study demonstrate that very little modification is required for the model to be implemented, but sound decision making is required for the model to be fully realized and holistically embedded into practice. Three key barriers to successful integration of this model into the broader food safety regulatory system have been identified.

Firstly, reorientation of legislation is necessary to support the implementation of the model. This requires a shift from embodying a compliance check ideology toward a food safety risk assessment ideology. Although the Barnes model can be implemented by EHPs now, the current food safety regulatory frameworks comprise a number of antithetical elements that render the model largely incompatible with the system and leaves compliance and enforcement tools inaccessible. Despite efforts of policy makers to instill a risk-based food regulatory system in Australia (Martin et al., 2003), too many remnants of command and control remain within the system (Smith et al., 2016). Addressing this issue requires reorientation of the structural elements that transcend the current food safety regulatory framework including the legislative intent, the major food safety offences, the definitions, the enforcement tools and the role of authorities. Until the essential elements of legislation can be realigned to genuinely facilitate a food safety risk assessment approach, the full potential of the Barnes model will not be attainable. This issue of incompatible legislation is likely to extend to other countries as well due to the drivers of their legislation remaining parallel to those enshrined in Australian legislation (Parliament of Australian Capital Territory, 2001; Parliament of Ireland, 1998; Parliament of New South Wales, 2003; Parliament of New Zealand, 2014; Parliament of Queensland, 2006; Parliament of South Australia, 2001; Parliament of Tasmania, 2003; Parliament of the Northern Territory of Australia, 2004; Parliament of Victoria, 1984; Parliament of Western Australia, 2008; United Kingdom Parliament, 1990; United States of America Congress, 2011).

Secondly, the food safety regulatory sector must redevise measurements of inspector performance. All participants in this study identified the limitations placed on their role and the way they perform inspections by the amount of time they are afforded to perform them, as well as the number of food safety inspections or “stats” they were required to achieve. Another participant further discussed the imposition of mounting workload pressures leading to an inability to undertake professional development. Excessive EHP workload, scheduling and time constraints have all been observed to interfere with the quality of inspections (Liu et al., 2024; Ibanez and Toffel, 2020). Measurement of performance for inspection must be realigned to correspond with EHPs implementing an effective health protection measure, rather than quantifying the amount of inspections they complete, the time spent undertaking inspections or the number of non-compliances they identify (Kufel et al., 2011). While the measurement of reduction in burden of foodborne illness presents considerable difficulty (Havelaar et al., 2015), the alignment of inspection methodology with measurement of control provides a basis for devising performance measurement instruments that are relevant to health protection and risk. At present, measurements are being oversimplified and applied indiscriminately, impeding application of an effective methodology and resulting in common unintended consequences known to span from performance measurement (Lewis, 2015; Lowe, 2013; Smith, 1995a, b; Ridgway, 1956). Measurement should be shifted to evaluation of how effectively an EHP is applying the model, and this gives further support to the implementation of the peer review element that remains a feature of the Barnes model. Rather than measuring how many inspections an EHP performs, or how many non-compliances they identify, measurement of effectiveness should be concerned with what and how EHPs are informing their determinations of food safety risk.

Finally, the effective implementation of the Barnes model requires oversight and harmonization by a governing body. The current food safety regulatory system in most areas of Australia involves a very high number of individual regulators that work at the local level (Smith et al., 2016). These regulators are principally local governments that stand and function independently of one another. Thus, internal policy, resources, culture and strategy of these organizations are likely to lead to differing interpretation and incommensurate implementation of the model between these regulators (Kettunen et al., 2018). While this inconsistency does not necessarily present a risk to public health (Barnes et al., 2022), the fragmentation may mean that some regulators do not apply an effective health protection measure where these internal pressures lead to the model being unfaithfully or incompletely implemented (Demeritt et al., 2015). Thus, a centralized governing body is required to harmonize and unify the implementation of the Barnes model to reliably instate it as an effective health protection measure.

A small sample size stands as a limitation of this research by restricting the generalizability of EHPs’ experiences implementing the Barnes inspection model. Thus, the findings of this research have been explicitly represented as spanning from a pilot that aimed to test the functionality, practicality and applicability of implementing a model inspection methodology. However, the central aim of this research was to determine whether the Barnes inspection model could be implemented by EHPs, which has been demonstrated in four separate instances. These findings provide the necessary foundations for further research into the effectiveness of the Barnes model as a health protection measure.

This study evaluates whether the Barnes model can be effectively implemented into food safety inspection practice by environmental health practitioners. This model food safety inspection methodology, devised from examination of current practices, combined with an adaptation of Lincoln and Guba’s (1985) framework for establishing trustworthiness was demonstrated by this pilot research to be functional, practical and applicable for implementation in food safety inspection practice. Minor modifications and enhancements were made to the model following findings of this pilot research, including the recommended timing of note taking, as well as providing more explicit guidance on identifying an optimal time to inspect and establishing a sample frame. While the training materials developed to support EHPs implementing the Barnes model in this study could be interpreted and applied by EHPs, it was identified that the development of training materials may need to be tailored to three key audiences, comprising EHPs, policy makers and tertiary educators. Three key barriers stand in the way of sector-wide adoption and implementation of the model by food safety inspectors, including the relics of compliance check ideology transcending food safety legislation, specious EHP inspection performance metrics and the lack of an integral governing body to foster harmonization through oversight. Further research is necessary to identify how these barriers to implementation of the Barnes model may be overcome. Notwithstanding, this study has demonstrated that individual EHPs were able to implement the Barnes model, setting the necessary foundations for further research on the effectiveness of the Barnes model as a health protection measure.

The supplementary material for this article can be found online.