REPORT – DISCLOSURE SYSTESM

Report – Comparison of Disclosure Systems

Olivia Van Osch

7565633

ENVR 73005

C. Egan

31 October 2019
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In today’s modern society, consumer eating habits reflect dining-out at restaurants and

ordering take-out as more popular than ever before. It can also be observed that internet

accessibility has greatly increased, allowing online information to be accessed almost anywhere

at any time. Advancement in technology allows quick and easy ways for consumers to research

establishments, such as locations, hours of operation, and contact information, before leaving the

house. While viewing this information online, consumers also have access to public disclosure

systems to help them make educated decisions about an establishment. Disclosure systems exist

as an educational tool to assist Public Health with informing the public about inspection results

of a premise in efforts to reduce the number of foodborne illness outbreaks and assist in infection

prevention and control.

Treatment of foodborne illnesses take a financial toll on the health care system and are a

significant cause of morbidity in Canada. Sources of outbreaks can be attributed to unsafe food

handling practices at food premises (Serapiglia et al., 2007, p. 54-55). The goal of an inspection

is to protect the public against any environmental risks that exist at a premise that can impact the

health of the population. While an inspection may last a few hours, inspection results are

available for 2 years after the initial inspection through the use of disclosure systems. The first

Food Premise Inspection and Disclosure Program in Canada was established in Toronto in 2001

and had the goal of “enhancing the effectiveness and efficiency of the food safety program in

Toronto” (Serapiglia et al., 2007, p. 55). By implementing public disclosure systems, Public

Health hopes to draw light on premises with critical infractions and improper practices that can

lead to future outbreaks.

Disclosure systems exist as a food safety strategy to reduce the occurrence of foodborne

illness by informing the public and allowing consumer demand to raise the bar for safe food
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handling and hygiene practices in food premises (Aik et al., 2018, Introduction Section). By

having dining establishments publicly post their inspection results and transparently give

consumers a better understanding of their food handling practices, this opens a premise up to

both confident and critical reactions of their customers, overall impacting their business. With

disclosure systems available to the public, it is in a premise’s best interest to perform well on

their inspections in order to run a profitable establishment. Inspections expose the hidden aspects

of a premise that the public cannot see such as: storage, preparation and cooking practices,

source of products and overall sanitation. The disclosure system is a tool to provide

informational cues to consumers on the things they cannot see (Filion & Powell, 2011, p. 1869).

In a way, disclosure systems allow consumers to have the “inside scoop” on what goes on behind

the closed kitchen door. The disclosure system also promotes discussions regarding good safety

issues in the food and personal service industries (Filion & Powell, 2011, p. 1869).

Simply posting inspection results to a health units’ website is not a sufficient enough way of

informing the public; however, by publicizing results in a way that is easy for consumers to

understand allows the disclosure system to be an educational tool (Choi & Scharff, 2017. p.

1188). Disclosure systems have to be easily digestible by the public and offer as much

information as needed to make informed choices, while not presenting any sort of bias or

preference of one premise over another. Visual displays of the disclosure system on the outside

of establishments are higher perceived amongst consumers because it clearly communicates

accuracy and trust (Filion & Powell, 2011, p. 1873). By posting disclosure system results so they

are visible before a customer enters an establishment, this allows for quick decision making and

acts as an incentive to operators.

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While there are different variations of disclosure systems, anything below a perfect score

such as: a yellow rating, ‘B’ grade, or less than 3 stars, an operator can perceive it as a threat to

their business (Choi & Scharff, 2017. p. 1190). With less than perfect inspection scores,

consumers may deem an establishment unsafe to dine at or receive services at, overall causing an

operator to lose business. It is in an operator’s best interest to improve the hygiene and safe

practices of their premise to become a more attractive and safe business to consumers. A survey

completed by Aik et al., (2018) in Singapore, asked over 1500 participants whether or not they

refer to disclosure systems before dining out and if the results impacted their decision. The study

concluded that 65% of participants refer to disclosure systems before hand; 85% of survey

participants would consider dining at a ‘B’ graded establishment; and only 10% would eat at a

‘C’ graded establishment (Results Section). The lower the inspection rating, presumably the less

likely an establishment is to be successful. Since the implementation of disclosure systems in

Toronto, there has been a decrease in operator noncompliance with food safety (Serapiglia et al.,

2007, p. 58). Overall, there is a clear link between disclosure system transparency and incentive

to operators.

In conclusion, inspections are to reduce foodborne illness outbreaks and prevent infection

and disease, while building confidence among consumers regarding food services or personal

service settings. Disclosure systems aim to act as a tool for consumers to make educated

decisions and as an incentive for operators (Filion & Powell, p. 1869). Disclosure systems are

made available to the public and are effective at not only informing the public but act as an

incentive to operators to run a safe establishment that will reflect in their inspection report. With

availability to information increasing, consumers are making more informed decisions regarding

places they choose to eat or engage in services at by using the disclosure system.
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Spotlight Classification Disclosure System – Hamilton: Food Safety Zone

The Food Safety Inspection Disclosure Program – Operator Information Guide (2013)

published by the city of Hamilton’s Public Health Services Department offers information about

their disclosure system such as the benefits and an explanation for each inspection result.

Hamilton’s Food Safety Disclosure Program applies to licensed establishments including:

general food establishments and mobile food service premises (p. 3). Each food establishment

that is inspected by an Environmental Public Health Inspector, is assigned an inspection rating

and given a Certificate of Inspection sign to display. Inspection results are also made available

online: www.foodsafetyzone.ca (p. 5). Certificate of Inspection ratings are as follows:

 Pass (green sign) – substantial compliance with the Food Premise regulation,

noncompliance is minor and the premise does not need a follow-up inspection sooner

than the regular scheduled inspection.

 Conditional Pass (yellow sign) – significant noncompliance with food safety practices,

requires a follow up inspection within 48 hours.

 Closed (red sign) – conditions observed are an immediate health hazard to the public,

premise to remain closed until health hazard no longer exists (p. 5).

Overall, the Stoplight Disclosure System is effective at quickly informing the public about

the health inspection of a premise, however, it can be assumed that most premises have a green

sign - due to the follow-up inspection that occurs if a premise is given a yellow sign. Quick

corrective actions would be taken within the 48-hour period that would grant a green sign, and

falsely advise the public that no health hazard ever existed at the premise. Similar to the Pass or
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Fail Disclosure System, a premise is either operational or closed, with the yellow sign being a

temporary state until corrective actions are taken.

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Letter Grading – Thunder Bay Health Unit: DineWise

DineWise 2.0 – Operator Education Package (2019) published by Thunder Bay District

Health Unit offers information about their food safety grade disclosure system established in

2017 called DineWise (p. 3). All food premises in the Thunder Bay District Health Unit are

subject to post the results of compliance inspections in the form of food grade signs. Food

premises are also given an opportunity to upgrade any letter grade below “A” before the next

scheduled inspection within two months (p.4). Each premise has a score of 100 at the start of an

inspection, and is deducted points based on critical (-15), major (-10) and minor infractions (-5)

(p. 6). The letter grades are established by the following scores:

 “A” Grade – score of 90 to 100

 “B” Grade – score of 75 to 89

 “C” Grade – score of 60 to 74

 “D” Grade – score of 59 and below (p. 6).

The letter grade signs are also colour-coded, with “A” and “B” scores in green, and “C” and

“D” scores in yellow (p. 5). The DineWise Disclosure System is not made available online

through TBDHU’s website. Overall, by assigning point value to infractions help communicate to

the public the seriousness of each infraction and how a minor infraction does not warrant a

premise to be unsafe. In addition to the grades, coloured signs also help indicate the risk level of

a premise and can help the public make educated decisions. The DineWise Disclosure System is

combination of the Stoplight Disclosure System as well as the Star Rating Disclosure System.

The Letter Grading Disclosure System effectively communicates in both qualitative and

quantitative values of health hazards that may exist at a premise.

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Summary/Results Disclosure System – Waterloo Region: Check it! We Inspect it.

The Region of Waterloo Public Health uses a Summary Disclosure System, called Check

it! We Inspect it (n.d.), that relies on members of the public to read the inspection history of a

premise and make educated choices based on the results (para. 1). Unlike other disclosure

systems, the Summary Disclosure System does not post a visual summary of the results in a

premise, instead it is required that all establishments post a QR Code that links to the online

database of inspection history. Inspection results are available for: restaurants, food retailers,

spas, salons, piercing and tattooing business, and recreational water facilities (para. 3).

Inspection results are posted online at: https://checkit.regionofwaterloo.ca.

Check it! We Inspect it is solely based online and encourages members of the public to

stay connected and regularly check the status of their preferred establishments. The Summary

Results Disclosure System requires more effort in order to come to a conclusion about the health

status of a premise, however it eliminates the perceived endorsement that comes is associated

with a visual sign posted in a premise. For example, a green sign indicating a pass, may be

perceived as a health units’ recommendation to eat there, when in fact is it only to inform the

public that no health hazards exist. The visual display of the QR code, usually displayed on the

entrance door of an establishment, can be reassuring to the public to know they are eating at a

licensed establishment in Waterloo Region but it does not give any immediate information about

a premise. Overall, the Summary Disclosure System is more long-term educational, and

establishes habit of checking inspection results and begin to understand the results rather than a

quick visual indication of a coloured sign and assuming the premise must be safe from health

hazards without knowing which one specifically may exist.

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Stoplight Classification Letter Grading Disclosure Results/Summary

Disclosure System
PROS - Quick, visual summary of
health inspection
- Easy to understand colour
system
- Hamilton’s Operator guide
informs operators on how
they are being inspected
System
- Quick, visual summary of
health inspection
- Easy to understand letter
system
- TBDHU’s Operators guide
informs operators on scoring
system and allows for
operators to be re-inspected to
upgrade their scores before
next compliance inspection
Disclosure System
- Allows public to make
their own decision about a
premise
- Saves paper resources
(does not require new QR
code after every inspection)
- Does not show signs of
endorsement via display of
inspection summary

CONS - Requires paper copy after
every inspection
- “Yellow” sign is a grey area
regarding health hazards in
the premise
- May show signs of
endorsement via display of
inspection summary
- Requires paper copy after
every inspection
- “B”, “C”, “D” grades are
grey areas regarding health
hazards in the premise
- May show signs of
endorsement via display of
inspection summary
- No current online disclosure
system (TBDHU)
- Requires checking online
disclosure system for
summary of inspection
- ROWPH does not inform
operators on how they are
being inspected

After reviewing Hamilton’ Food Safety Zone online disclosure system results on various

McDonald’s premises, I found that common infractions general sanitation and condition of the

premise. All of the different McDonald’s premises had multiple inspections, all with pass results

except for one with a conditional pass but later followed with a pass inspection result. Majority

of the actions per each inspection are education on site or follow up actions at the next

inspection. I did find it conflicting that an inspection with 5 noncritical infractions can receive

the same inspection result as an inspection with no infractions: a green pass. From an operator’s
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perspective, seeing the items that are not in compliance listed per each inspection online can be

kind of embarrassing, in a way that the public can know everything they did wrong. From the

public perspective, seeing a number of infractions and a pass result can be conflicting. It can also

be confusing to the public on which infraction is critical and which is noncritical as there is no

label or category to distinguish them without looking up the regulation. This disclosure system

does its job, but the online access can be improved upon by allowing sorting of inspections via

inspection result, and quick view of number of infractions at the last inspection. As it stands

now, the inspection results table is very basic with the only sorting options being facility name,

and most and least recent inspection date. Overall, I think that Hamilton’s Food Safety Zone and

the use of the Stoplight Classification Disclosure System is efficient at helping the public make

quick decisions about a premise, but it can be conflicting when actually looking at the results and

seeing how 1 critical infraction warrants the same result as no infractions.

Currently, Thunder Bay’s DineWise is not available online, but various news reports state

that the feature should be coming soon. One article I found entitled “Changes coming to

restaurant grading system” written by Gary Rinne, published by Thunder Bay News Watch in

January, 2019, states that during the first pilot stage of the new Letter Grade Disclosure System

in 2017, only 42% of premises received an “A” grade. However, by the end of the year, due to

public pressure, it had risen to 87% of all premises (para. 10). At the time of publication, the

following letter grades were assigned: 816 “A” grades, 79 “B” grades, 3 “C” grades, and 2 “D”

grades (para.15). Also stated, before the pilot project, per 100 inspections, there would be an

average of 30 critical infractions. After the pilot project, there is now an average of 4 critical

infractions per 100 inspections (para. 12). Based on this information, it can be assumed that the

Letter Grading Disclosure System is effective at initiating change among operators to be in

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compliance with the regulation in order to receive a better letter grade. The Letter Grading

Disclosure System is an improved version of the Stoplight system in my opinion, because it

provides more options to portray the number of health hazards that exist in a premise. The “B”

and “C” grade more accurately reflect the number of infractions a premise has without needing a

for closure order. However, with the online disclosure system lacking, accessing the results of a

health inspection is harder for the public and viewing a premises history cannot be done without

making a call to Public Health.

Lastly, Check it! We Inspect it by Waterloo Region and the use of the Summary

Disclosure System when comparing McDonald’s premises is very easy to understand and

navigate. More than half of the inspections for McDonald’s premises have at least 1 infraction

listed, most having to do with food storage and general sanitation of the premise. It is easy to

decipher the inspection results due to the quick view of number of infractions that is on the

inspection results table, and the separation of critical vs non critical when viewing each

individual inspection. Majority of the McDonald’s inspections required no action or education on

site. From an operator’s perspective, the results posted are informative and like Hamilton’s

disclosure system, the public is aware of which part of the regulation the premise was not in

compliance with which can draw a negative light to the establishment. From the public’s

perspective, the classification of critical vs noncritical infractions makes the results easy to

understand. Overall, by not assigning a letter, colour, or any other form of rating to an

inspection, the public may feel left in the dark about the status of an establishment if they were to

stand immediately in front of it with no access to the online disclosure system. However, it

allows the public to make educated decisions on their own without the aid of a green or red

paper. Ultimately, if the Region of Waterloo Public Health does not want to use a visual
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indication of the inspection results, food safety education should be more prominent within the

community, to help members of the public better understand the results.

In conclusion, there are benefits and drawbacks to all types of disclosure systems, and it

is up to the discretion of each Public Health Unit to decide which system is best for their

community. I think socioeconomic, education and demographic factors are important to assess

within a community to gage the level of understanding each member of the public has regarding

food safety. For example, if a more rural community lacks general understanding of food safety,

a Stoplight Classification Disclosure System may be more useful to protect the public against

foodborne illness and infections because of how easy it is to understand based on colour.

Whereas, a community with more understanding of safe food practices and best practices, the

Summary Disclosure System may work to allow members of the public gage what is safe for

them to participate in and what is not. In the end, there is no right answer for which disclosure

system works best; as long as it is understood by the community it exists in and the inspection

summary is available to the public to refer to.

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References

Aik, J., Newall, A. T., Ng, L., Kirk, M. D., & Heywood, A. E. (2018, August). Use of the letter-

based grading information disclosure system and its influence on dining establishment

choice in Singapore: A cross-sectional study. Food Control, 90, 105-112.

doi:10.1016/j.foodcont.2018.02.038

Choi, J., & Scharff, R. L. (2017, July). Effect of a Publicly Accessible Disclosure System on

Food Safety Inspection Scores in Retail and Food Service Establishments. Journal Of

Food Protection, 80(7), 1188-92. doi:10.4315/0362-028X.JFP-16-293

Filion, K., & Powell, D. (2011, January). Designing a national restaurant inspection disclosure

system for New Zealand. Journal Of Food Protection, 74(11), 1869-74.

doi:10.4315/0362-028X.JFP-11-007

Hamilton Public Health Services. (2013, September). Food Safety Inspection Disclosure

Program. Retrieved October 30, 2019, from

https://d3fpllf1m7bbt3.cloudfront.net/sites/default/files/media/browser/2015-02-

17/food_safety_guide_for_operators.pdf

Region of Waterloo Public Health. (n.d.). Public Health Inspections. Retrieved October 31,

2019, from https://www.regionofwaterloo.ca/en/health-and-wellness/public-health-

inspections.aspx

Rinne, G. (2019, January 21). Changes coming to restaurant grading system. Thunder Bay News

Watch. Retrieved October 31, 2019 from https://www.tbnewswatch.com/local-

news/changes-coming-to-restaurant-grading-system-1205425
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Serapiglia, T., Kennedy, E., Thompson, S., & de Burger, R. (2007, July). Association of food

premises inspection and disclosure program with retail-acquired foodborne illness and

operator noncompliance in Toronto. Journal of Environmental Health, 70, 54-59.

Retrieved from Retrieved October 29, 2019, from

http://ra.ocls.ca/ra/login.aspx?inst=conestoga&url=https://search.ebscohost.com/login.as

px?direct=true&db=ccm&AN=105844188&site=eds-live&scope=site

Thunder Bay District Health Unit. (2019, February). DineWise 2.0. Retrieved October 30, 2019,

from https://www.tbdhu.com/sites/default/files/files/resource/2019-

03/DineWise%202.0%20Operator%20Education%20Package.pdf