Amsterdam USPH Inspection in Sitka today

[Ineke]

I was taken aback when I read the report.  But then I checked the most recent report on a HAL ship with a score of 100, (the Nieuw Amsterdam in June) and found there were nearly as many items listed on the ‘perfect score of 100’ report, as there were on the July Amsterdam report, which made me realize it wasn’t nearly as alarming as first appeared.

[voyageur9]

3 hours ago, Homosassa said:

FDA,  which is the inspecting agency for this program

No. In fact, it is not. As Donald accurately notes, The United States Public Health Service - USPH, inspects foreign-flagged vessels including HAL.

[Homosassa]

10 minutes ago, voyageur9 said:

No. In fact, it is not. As Donald accurately notes, The United States Public Health Service - USPH, inspects foreign-flagged vessels including HAL.

Here we go again with people who do not understand how the Vessel Sanitation Program actually is organized or carried out.

 

Although the program is authorized originally under Part 42 of the Code of Federal Regulations, the part that covers the CDC, the actual performance of the inspection is delegated to the US Food and Drug Administration and has been rewritten as 21 CFR Parts 1240 and 1250.

 

Yes, some of the people performing the inspections may be officers in the US Public Health Service (usually holding the title of sanitarian), but many will also be regular service service employees of the FDA. Any PHS officer in the program will have a duty station in the FDA.

 

The personnel performing the inspections will be part of a cadre of people located a in the regional or district  FDA office. These personnel will be specialized and, at least for the FDA civil servants, will have have been hired for the position based upon their education, training and experience in performing inspections. The programs that will be located in this group  will be federal/state cooperative programs for milk and shellfish and inspections dealing with entities under the Interstate Travel Program. Those entities include, beside vessels, railroads, aircraft, buses and catering facilities providing food for any covered entity.

 

ITP personnel can and will inspect any of the regulated components of the ITP program. This will include any foreign craft that ports or otherwise operates within the USA.

For your convenience, I have included a link to the FDA Compliance Program that covers the ITP. Of special interest for those wishing to understand the program will be the background section that gives a history of the regulatory authority for the program and its conveyance to FDA jurisdiction. Please note that this particular program only deals with the support facilities under the ITP.  Similar programs  exist for all components of the program.

 

https://www.fda.gov/media/71681/download

 

 

 

 

[Homosassa]

3 hours ago, voyageur9 said:

I doubt HAL would want it distributed with the menus in the main dining room even if the company's cheerleaders were hanging about trying to dismiss it.

 

2 hours ago, Donald said:

FDA inspects airplanes, trains, and buses in the USA. They also inspect American flag cruise ships (the very few that still exist).

They are not allowed to inspect foreign flag cruise ships.

That responsibility goes to a sister organization - The United States Public Health Service - USPH.

USPH has a slightly different and more stringent set of rules and regulations about health and cleanliness than their colleagues at FDA.

 

Years ago I was working an an American Flag cruise ship in Hawaii. FDA came aboard for their annual inspection. They asked me if we were following the VSP Manual (Vessel Sanitation Program of the USPH). I showed them my copy of the VSP Manual. They admitted that they were not familiar with the manual, but urged me to continue following the VSP guidelines. I tried discussing some of the finer points of the VSP manual with them, but they were unwilling to get into it.

To correct some things, I am not a HAL cheerleader but someone that has thirty five years of inspection/compliance experience in the US Food and Drug Administration.  I will not try to detail my experience or that of my husband (lol- although you would find his name as an author of the food code and his signature on the certificates of training for many food managers on board ships).

 

Suffice it to say, both of us can read an inspection report and can actually assess the validity and severity of items listed.

 

As far as the VSP program, my post above does explain the delegation of the USPHS program to FDA. 

 

As far as why the investigators on board a specific ship may not have wanted to get into a discussion with an employee about the finer point of the VSP program, it is very likely that they realize a hair splitting discussion would be futile in regards to their observations.

[Donald]

20 minutes ago, Homosassa said:

Here we go again with people who do not understand how the Vessel Sanitation Program actually is organized or carried out.

 

Although the program is authorized originally under Part 42 of the Code of Federal Regulations, the part that covers the CDC, the actual performance of the inspection is delegated to the US Food and Drug Administration and has been rewritten as 21 CFR Parts 1240 and 1250.

 

Yes, some of the people performing the inspections may be officers in the US Public Health Service (usually holding the title of sanitarian), but many will also be regular service service employees of the FDA. Any PHS officer in the program will have a duty station in the FDA.

 

The personnel performing the inspections will be part of a cadre of people located a in the regional or district  FDA office. These personnel will be specialized and, at least for the FDA civil servants, will have have been hired for the position based upon their education, training and experience in performing inspections. The programs that will be located in this group  will be federal/state cooperative programs for milk and shellfish and inspections dealing with entities under the Interstate Travel Program. Those entities include, beside vessels, railroads, aircraft, buses and catering facilities providing food for any covered entity.

 

ITP personnel can and will inspect any of the regulated components of the ITP program. This will include any foreign craft that ports or otherwise operates within the USA.

For your convenience, I have included a link to the FDA Compliance Program that covers the ITP. Of special interest for those wishing to understand the program will be the background section that gives a history of the regulatory authority for the program and its conveyance to FDA jurisdiction. Please note that this particular program only deals with the support facilities under the ITP.  Similar programs  exist for all components of the program.

 

https://www.fda.gov/media/71681/download

 

 

 

 

As luck would have it, I spoke with the lead Commander of the Vessel Sanitation Program today.

She assured me that my Bahamas flagged cruise ship can only be inspected by two or more of the 11 USPH Officers (Commanders, Lieutenant Commanders, and Lieutenants) currently assigned to the VSP Offices in Fort Lauderdale and Atlanta. There are currently 2 open Inspector positions at VSP. If you know anyone who is qualified, they are hiring.

[Homosassa]

53 minutes ago, Donald said:

As luck would have it, I spoke with the lead Commander of the Vessel Sanitation Program today.

She assured me that my Bahamas flagged cruise ship can only be inspected by two or more of the 11 USPH Officers (Commanders, Lieutenant Commanders, and Lieutenants) currently assigned to the VSP Offices in Fort Lauderdale and Atlanta. There are currently 2 open Inspector positions at VSP. If you know anyone who is qualified, they are hiring.

Good lord, I can see why the FDA people refused to get into it with you on the VSP manual.

 

Those two locations are an FDA resident post and a regional office.

Those PHS officers are assigned to FDA as their duty station.

 

But hey, what do I know about the FDA and its programs or the jobs of coworkers involved in those programs.

 

And those positions will be filled as they usually are with internal applicants (either FDA civilian (consumer safety officers) or PHS officers in the sanitation series).

[Donald]

2 minutes ago, Homosassa said:

Good lord, I can see why the FDA people refused to get into it with you on the VSP manual.

 

Those two locations are an FDA resident post and a regional office.

Those PHS officers are assigned to FDA as their duty station.

 

But hey, what do I know about the FDA and its programs or the jobs of coworkers involved in those programs.

 

And those positions will be filled as they usually are with internal applicants (either FDA civilian (consumer safety officers) or PHS officers in the sanitation series).

Actually the FDA Inspectors in Hawaii were not able to tell me from memory the required cooking temperatures and holding temperatures that are listed in the VSP Manual - and are required knowledge for every food preparation employee on a foreign flag ship. (Lack of this knowledge is a 3-point deduction with VSP).They were also unaware of potable water and recreational water requirements and regulations that every hotel engineer on every cruise ship is required to follow. (That's another 3-point deduction). Their public health knowledge was not complete enough to allow them to even be employed in my floating hotel. On every issue I asked about their only reply was, "just follow whatever the VSP Manual tells you". The American steamship we were on was very old with many deficiencies. We would have been very lucky to pass at all with VSP. The FDA gave us a perfect 100 score and congratulated us on the excellent condition of the vessel !! When I signed this perfect inspection report, the inspectors and I were in the galley, standing in a pool of stagnant water that was leaking out of a bulkhead - a major health violation, and a 5 point deduction.

Very sad really.

[chengkp75]

My experience is the same as Donald's, as I've mentioned before on other threads, regarding the difference between  USPH and FDA inspections.  The document that Homosassa linked states:

 

"Under ITP, FDA is charged with enforcement of the PHS Act and the Food Drug & Cosmetic Act (FD&C). A major objective under ITP is to prevent the introduction, transmission, or spread of communicable diseases from one state or U.S. Territory to another (interstate traffic) via conveyances. The terms “conveyance” and “interstate traffic” are defined in sections 21 CFR 1240.3"

 

When you go to  21 CFR 1240.3 for the definition of "interstate traffic" you find:

 

"(h) Interstate traffic. (1) The movement of any conveyance or the transportation of persons or property, including any portion of such movement or transportation which is entirely within a State or possession,

(i) From a point of origin in any State or possession to a point of destination in any other State or possession, or

(ii) Between a point of origin and a point of destination in the same State or possession but through any other State, possession, or contiguous foreign country.

(2) Interstate traffic does not include the following:

(i) The movement of any conveyance which is solely for the purpose of unloading persons or property transported from a foreign country, or loading persons or property for transportation to a foreign country."

 

Note that "interstate traffic", which is correctly the purview of the FDA requires that the transportation be via a "contiguous" foreign country, of which there are only two:  Canada and Mexico.  

[chengkp75]

2 hours ago, Donald said:

Actually the FDA Inspectors in Hawaii were not able to tell me from memory the required cooking temperatures and holding temperatures that are listed in the VSP Manual - and are required knowledge for every food preparation employee on a foreign flag ship. (Lack of this knowledge is a 3-point deduction with VSP).They were also unaware of potable water and recreational water requirements and regulations that every hotel engineer on every cruise ship is required to follow. (That's another 3-point deduction). Their public health knowledge was not complete enough to allow them to even be employed in my floating hotel. On every issue I asked about their only reply was, "just follow whatever the VSP Manual tells you". The American steamship we were on was very old with many deficiencies. We would have been very lucky to pass at all with VSP. The FDA gave us a perfect 100 score and congratulated us on the excellent condition of the vessel !! When I signed this perfect inspection report, the inspectors and I were in the galley, standing in a pool of stagnant water that was leaking out of a bulkhead - a major health violation, and a 5 point deduction.

Very sad really.

I had similar experiences with the FDA inspectors, and when our ship transferred back to USPH jurisdiction (US flag but making foreign voyages to Fanning Island), the USPH were especially hard on us, as they felt the FDA inspectors were very lax.

[AncientWanderer]

Does anyone know if they also test for air quality throughout the ship?  The reports I looked at all seemed to focus on food cleanliness.  I've always been curious about that, as my allergies always seem to be less active when I'm on a cruise ship.  

[Donald]

VSP does not test for air quality on  ships.

But most modern cruise ships do have quite good air filtration systems.

[chengkp75]

After some reflection, I understand what Homosassa is saying, and agree with some of it.  Because the FDA has field offices in places like FLL, and the CDC does not, it makes sense that the USPH inspectors would be assigned to the FDA "duty station", though it could have been any other government agency that was convenient, meaning their office space is under the FDA and they draw logistic support from the FDA, much like the US Navy assigns medical corpsmen to the USMC, but in neither case are the USPH inspectors, nor the Navy corpsmen, part of the organization that is their "duty station".  So, while the USPH officers may operate out of an FDA office, the FDA does not (from what I, and apparently Donald, have been told personally by USPH officers) operate the VSP, non-USPH officers cannot inspect foreign flag ships, and from my personal experience, and apparently Donald's as well on the old Indie, the FDA inspectors who do inspect US flag cruise ships doing strictly coastwise voyages, do not necessarily follow the VSP, but use FDA guidelines which are somewhat similar.  As I have noted in other threads, and as Donald has noted here, both the USPH inspectors and FDA inspectors have acknowledged the different jurisdictions of the two organizations.

 

As for the statement:

10 hours ago, Homosassa said:

Good lord, I can see why the FDA people refused to get into it with you on the VSP manual.

I see nothing in Donald's statements that would indicate that he was in any way "getting into it" with the FDA inspectors about the VSP manual, and I have found the USPH inspectors very willing to discuss areas that aren't fully understood, or that the crew would like clarification on the justification of the requirement.

 

As I stated in the other thread, the CDC answered my query by stating that the VSP is operated out of their National Center for Environmental Health, and I have just sent a query on the topic to the FDA media office as well.

[chengkp75]

4 hours ago, AncientWanderer said:

Does anyone know if they also test for air quality throughout the ship?  The reports I looked at all seemed to focus on food cleanliness.  I've always been curious about that, as my allergies always seem to be less active when I'm on a cruise ship.  

 

3 hours ago, Donald said:

VSP does not test for air quality on  ships.

But most modern cruise ships do have quite good air filtration systems.

The USPH inspectors will check the condition of ventilation filters, and inspect some ducting for cleanliness, and will inspect physically and by records the status of disinfectant pads in the condensate pans of the AC air handlers (the wet location where most bacterial and viral organisms breed in AC systems).