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Regulations Update

Marci Pederson, RN, BSN, Nurse Educator/Consultant

Federal Regulation - F371 Sanitary Conditions

F371 had 36 deficiencies cited in South Dakota long-term care facilities in 2010 (the same number of deficiencies as in 2009). It ranks number three in the top ten deficiencies for long-term care facilities in South Dakota.
F371 states, "The facility must –
Procure food from sources approved or considered satisfactory by Federal, State, or local authorities;
Store, prepare, distribute, and serve food under sanitary conditions."

The overall intent of F371 is to promote safe food handling to prevent food borne illness. Based on observations in client facilities' kitchens during food preparation, the problems tend to occur with cross-contamination. When I wrote the update for F371 last year I focused on key areas of the Guidance to Surveyors.  This year I want to include some helpful hints which are based on experiences from the past year while I provided consulting services to both long term care facilities and critical access hospitals.

Follow manufacturer's recommendations

Very recently I was invited by a long term care facility to be present during their annual survey conducted by the South Dakota Department of Health Office of Licensure and Certification. The surveyor who was assessing for dietary compliance asked why the measurement of the chlorine level for the dishwasher was consistently documented as 75 parts per million. The dietary manager indicated the company representative who provided the dishwasher chlorine product had verbally instructed the staff to keep the level of chlorine at 75 parts per million. The company representative came on-site during the survey and adjusted the product dispenser for the dishwasher so it dispensed 100 ppm; however, he still maintained the company recommended the chlorine level be at 75 ppm to prevent any smell of chlorine on the dishes.  When the dietary manager and I reviewed the manufacturer's label on the product container, we found there was no information about using 75 parts per million. Instead 100 parts per million was recommended by the manufacturer. This was a valuable lesson for everyone involved. In the Midwest we have the tendency to trust what is told to us verbally. We must remember to check the actual manufacturers' recommendations for usage of their products by reading the label information or equipment manuals before using any products. There are also two important items to remember about test strips used to measure the level of chlorine and they are:

  • The test strips should be the right test strips provided for that specific equipment from the manufacturer.
  • The test strips are not used beyond their expiration date.

Clean equipment according to manufacturers' recommendations

In the last few months I had the privilege of working with a dietary manager in a long-term care facility.  She had been working in that capacity for a few months. She had worked as a dietary manager for several years in another facility so her past experience was helpful.  One of the first things she addressed was the ice machine which was less than a year old. It was in desperate need of cleaning, but she could not find the manufacturer's manual. She took the initiative of contacting the company which had manufactured the ice machine, and the company mailed the manual for the ice machine to her. She was then able to obtain the appropriate chemical product and follow the directions for cleaning. A cleaning schedule and procedure was developed, and the cleaning and sanitizing products were added to the MSDS manual.

The last item to share in this update is the tray line

This may include both the steam table where hot prepared foods are held and served, and the chilled area where cold foods are held and served. The persons serving the tray line must be well trained and organized. They should:

  • Wash hands before beginning the process.
  • Make sure she/he has all of the serving utensils and equipment needed before serving to ensure she/he can continue the serving process without needing to step away and interrupt the clean process. If the server should forget something, another staff person should be available to provide any items needed using clean technique as well. By preparing ahead of time, the serving process takes less time and there is much less opportunity for cross-contamination.

I will be presenting more information on F371 and the Food Service Code May 25, 2011 at the PACE dietary meeting. I hope to see some of our readers there.  Remember, I love invitations from nursing facilities and hospitals to come and help improve compliance with regulations and improve quality of care for the residents/patients. Call AESS today 605-668-8475 to schedule a consultation with me, your survey specialist!

As a former health facilities senior surveyor, Marci worked at the Department of Health Office of Licensure and Certification for eight years. Marci provides Survey Preparedness Consulting designed to create a culture of constant survey preparedness by helping staff understand regulatory requirements, not just comply with them.

Contact me at for all of your Regulatory Compliance and Survey Preparation needs.

Do the math! The facility bottom line improves when resident care continually improves.

Read more Regulations Updates. The Avera Solutions’ Blog contains writings from Marci and other Avera Education & Staffing Solutions staff and consultants.

Marci Pederson, RN, BSN

Marci Pederson, RN, BSN

As a former health facilities senior surveyor, Marci served a variety of health care facilities. Her experience includes nursing education, medical/surgical nursing, psychiatric nursing, infection control, utilization review and quality assurance.

Have a question for Marci? A topic idea for her next column? Need more information on having a mock survey at your facility? Send her an email at