Oregon Department of Agriculture has had some recent poor reviews regarding it’s maintenance of inspections in recent years.

In December 2014 in response to a public records request from the Statesman Journal, they quickly worked to get caught up on several grocery store inspections before releasing the report.

The backlog received a more formal review from the Secretary of State in 2016, where the extent of the backlog was further teased out, as well as a lack of review of metrics. Here were the highlights:

There were 2841 firms late for an inspection (out of ~12,000 total)

They identified that there is currently no proactive method to capture establishments that never reach out to ODA to get a license in the first place

They had no idea how long it had been since they visited their “overdue” firms

“…the program has not been keeping track of these data and is unable to say how many firms were past due a year ago or five years ago”

So I was curious, of the ones who haven’t been inspected recently, how long has it been? And with inspectors scattered around the state, are there any correlations to be drawn between locations?

A public records request from ODA on 12/29/17 and I had a PDF with every firm currently licensed in Oregon, their address, and date of last inspection. The number of firms (a few were removed from the dataset for incomplete/corrupted data from the transfer) represented was approximately 1600.

Kudos to Oregon for now being able to pull this data so quickly! It shows they fixed the problem of being able to tell when a firm became past due. However, has the state been using this new tool to catch up on firms that haven’t been visited in a while? Or are they still visiting the same facilities?

That’s still a lot of inspections that were more than 40 months ago…Lets break this down in a few ways.

The Best and Worst

Note: while medians may have been a more representative average for areas with lots of inspection data, in order to make sure I could compare all cities equally I opted to use averages.

Averaging months since last inspection by city, we can see that the vast majority of cities are hitting less than 2 years as an average.

This is good, overall for the most part ODA is making sure that the majority of facilities are inspected at least every other year. The statewide average time since last inspection was 13.9 months.

So what cities were the worst at backlogged inspections?

(only cities with 3 or more facilities represented here).

City Average months since last inspection Oakland 46.7 Elkton 35.9 Aurora 33.1 Cornelius 33.0 Monroe 30.3 Boring 28.2 Mt Angel 26.2 Dayton 26.1 Cloverdale 25.5 Gold Hill 24.0 Brookings 23.5 Gaston 23.2 Culver 22.9 Milton Freewater 22.6 Keizer 22.1 Phoenix 21.2 Rickreall 21.0 Yamhill 20.6 Dallas 20.5

And the best?

City Average months since last inspection South Beach 3.2 Baker City 6.3 Lake 6.4 Gold Beach 6.8 White City 6.8 Cottage Grove 7.3 Enterprise 7.5 Oregon City 7.9 Gresham 8.2 Grants Pass 8.3 Mosier 8.9 Rogue River 8.9 Klamath Falls 9.0 Roseburg 9.5 Madras 9.7 Depoe Bay 9.9 Ontario 9.9 Redmond 10.3 Tigard 10.4

Unfortunately this doesn’t tell us much except that because the spread is so large, some areas must get more attention than others. To explore this, I charted out the office/assignment locations of all of ODA’s food safety inspectors in Oregon, then charted cities who averaged >18 months between inspections.

As I guessed there were some rural locations that may be overrepresented by having few facilities, but this data didn’t really look telling until I charted the opposite.

Given that every single ODA office fell within one of the high-performing cities, it appears that there is a correlation between general proximity to an ODA inspector and a higher likelihood of staying off of the inspection “backlog.”

This makes sense, as ODA inspectors see these facilities in their hometowns every day, they stay in their minds, and any changes in the business may make it their way via local coverage/discussion. They’re also simpler (low travel time) targets for inspectors who want to knock out multiple inspections in a day, should numbers be a factor or they’re being encouraged to make the most of their time.

This also demonstrates that ODA’s system isn’t currently setup (as indicated in the secretary of state report) to push inspectors to inspect facilities at their assigned interval or by “most overdue”. Instead the system permits discretion that leads to this distribution, ultimately creating areas that fall way behind the state average, and areas where some firms are inspected like clockwork regardless of their associated risk or past performance.

A more fascinating analysis would necessarily include a review of which facilities have problems and whether that encourages or discourages a more recent inspection, and the intervals between inspections for each firm. Unfortunately, I did not have the necessary data to perform that analysis.

To tackle the backlog, ODA responded to the report and released statements that they plan to take on fewer FDA contract inspections (which were represented in this report) in order to catch up the backlog. Given the large number of over-performing cities, it also seems that a backlog-driven inspection schedule could also assist the state in getting caught up by reassigning labor away from inspector’s backyards and towards rural Oregon. That would take care of the long tail anyway.

It’s complicated though. FDA inspections can take the place of state inspections while also providing a valuable source of revenue, something ODA has been requesting since 2014 to keep up with Oregon’s rapidly expanding food, beer, and now cannabis industries. FDA inspections are also much more timely and will continue to become more intensive as FSMA rules come under enforcement for smaller and smaller firms.

Ultimately, I don’t think this data demonstrates any particular failure on ODA’s part; however, it does show that there’s potential for unequal enforcement in rural areas. Making this information public allows us to understand the amount of food safety education and enforcement makes it to our communities, while also holding our state government accountable for getting them done. We want people to pay for food safety, both in taxes and business investment, that means they need to see the results of that investment.

I’m not done with this data just yet! If you have any ideas as to how it should be analyzed let me know and I’ll see if it can be teased out, or you can email me and I’m happy to share the source data.

Relevant literature:

Filion, Katie, and Douglas A. Powell. “The use of restaurant inspection disclosure systems as a means of communicating food safety information.” Journal of Foodservice 20.6 (2009): 287-297.

Filion, K. and Powell, D.A. 2011. Designing a national restaurant inspection disclosure system for New Zealand. Journal of Food Protection 74(11): 1869-1874 .