The State of Texas has long been a leader in demonstrating care and concern for the health of its dining public. While sparing its foodservice industry from unnecessary regulation, the Texas Department of State Health Services (TDSHS) has created an infrastructure where local environmental health officials and industry operators can access food safety training in a variety of formats and at a broad range of price points. The marketplace for food safety trainers has generally been healthy, giving the public a variety of options for food safety training. But in recent years, there has been a noticeable decline in the quality of programs being promoted through the TDSHS website. This document aims to address this important issue.
The Texas Department of State Health Services Food Handler Program is dedicated to the health and safety of the citizens of the state, educating food service employees in the principles of food safety to produce safe food products for Texas consumers.
What is the purpose of food safety training?
According to Texas Administrative Code, “education of food handlers provides more qualified employees, thereby reducing the risk of foodborne illness outbreaks caused by improper food preparation and handling techniques.” Quality training should yield positive behavioral change, which results in safer food and a safer public. Many public and private organizations have implemented food safety training programs and seen improvement in their regulatory and third-party inspections. Additionally, studies have demonstrated that an emphasis on training can reduce workforce turnover, resulting in increasingly experienced and well-trained food workers over time.
What makes a QUALITY food safety training program?
While beauty is the eye of the beholder, quality in training is much less subjective. There are professional standards for instruction that should be met depending on the training format, student needs, and desired learning outcomes. Individuals involved in developing legislation, crafting rules and implementation guidelines, or approving materials for TDSHS may wish to consider the following:
- Do students (food workers) understand what they are expected to learn at the outset of the training program?
- Does the training program provide clear instruction that correlates directly with stated learning outcomes?
- Are considerations made for students not fluent or literate in the English language?
- Are mechanisms provided to allow students to gauge their comprehension (e.g., quizzes or activities)?
- What accessibility tools are provided? Is the program compliant with ADA guidelines?
- Is it inferable that the program developers believe the student wants to learn and has a right to effective training?
- Is it reasonable to expect that the program, when adequately engaged in, will influence positive behavioral change?
- Does the intent of the training program align with the TDSHS objective to “reduce the risk of foodborne illness outbreaks caused by improper food preparation and handling techniques”?
Unfortunately, as currently written, the TDSHS food handler program approval guidelines do not define quality training, restricting the ability to thoughtfully evaluate the programs submitted. Simply put, if a program checks the application’s curriculum boxes, it must be approved, regardless of its efficacy in teaching food safety principles.
To illustrate this point, a comparison of two programs (which are both currently approved for use throughout Texas) has been provided below:
Both of these programs have met the curriculum requirements established by the TDSHS approval process, but one clearly does not engage in teaching the student and is little more than a “certificate mill,” allowing the student to click through a series of PDFs before issuing a certificate. Arguably, the prerogative to approve better programs for the Texas public is well within the stated objective of the TDSHS Food Handler Program, especially when the cost for a far superior learning experience is almost equivalent.
The Texas Department of State Health Services provides a framework for accrediting food safety education and training programs for food handlers.
A uniform standard governing the accreditation of food handler programs enhances the recognition of reciprocity among regulatory agencies.
How can the approval process ensure training program quality?
If statewide approval of food handler programs is intended to create a standard of reciprocity, then environmental health officials must be confident that all approved programs are reasonably expected to yield increased comprehension of food safety principles. Currently this is not the case. Fortunately there are two possible options that could ease the constraints currently faced by TDSHS officials:
- Embrace the American National Standards Institute (ANSI) ASTM 2659 accreditation for certificate programs as the standard for Texas. This accreditation process ensures that program providers are effective and ethical, taking into consideration student performance data and satisfaction feedback. This option would also reduce TDSHS overhead by eliminating the approval process currently performed by state administrators.
- Increase standards within existing statute that will empower State administrators to discriminate against programs that do not align themselves with the objectives of the TDSHS Food Handler Program. Over time, this will yield a robust selection of quality training programs for the food worker to choose from.
Finally, the State may choose to do nothing, which would inevitably result in countless more fly-by-night programs entering the marketplace and taking food workers’ hard earned money in exchange for a certificate that signifies no increase in food safety knowledge.
 Rule §229.178
 Sunset Advisory Commission, DSHS Staff Report With Final Results, 2015, Issue 3, pg. 46