Inspection of Licensed Day Nurseries and Associated Programs

Policy

Category: Control of Infectious Diseases
Subject: Inspection of Licensed Day Nurseries and Associated Programs
Division: Health Protection
Policy Number: CA.82.01.128
Effective Date: February 26, 2016

POLICY STATEMENT

It is the policy of Wellington-Dufferin-Guelph Public Health (WDGPH), Health Protection Division (HPD), to conduct assessments of infection prevention and control policies and practices in licensed day nurseries and inspect food premises (as defined by the Health Protection and Promotion Act) located in childcare centres to:

  • ensure adherence to the Food Premises Regulation (O. Reg 562) and Food Safety Protocol;
  • ensure the use of appropriate infection prevention and control practices; and
  • assess the risk of infectious disease transmission.

This will be done through inspections, assessment, surveillance, education, consultation, evaluation, and regulatory enforcement, in accordance with the most current versions of the Infection Prevention and Control in Licensed Day Nurseries Protocol, Food Safety Protocol, and Risk Assessment and Inspection of Facilities Protocol, under the Ontario Public Health Standards and the Food Premises regulation under the Health Protection and Promotion Act

SCOPE

This policy applies to all Control of Infectious Diseases (CID) Public Health Inspectors in the HPD.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Procedure:  CA.82.02.128 Inspection of Licensed Day Nurseries and Associated Programs
CA.86.01/02.100 Food Premises Inspection – All Food Premises
CA.82.01.104, CA.82.02.104 Reportable Disease Follow Up/Outbreak Control
Food Safety Protocol
Risk Assessment and Inspection of Facilities Protocol
Health Protection and Promotion Act
Infection Prevention and Control in Licensed Day Nurseries Protocol

CONTACT FOR INQUIRIES

Manager, Control of Infectious Diseases

APPROVED BY

Director, Health Protection


Procedure

Category: Control of Infectious Diseases
Subject: Inspection of Licensed Day Nurseries and Associated Programs
Division: Health Protection
Procedure Number: CA.82.02.128
Effective Date: February 26, 2016

PROCEDURE

Risk Assessment and Frequency – Food Premises:

1. A risk assessment of the food premise unit of the premise must be completed annually, as per the Ontario Public Health Standards – Food Safety Protocol. Use the risk assessment screen in Hedgehog to obtain a risk rating for the premises as high, moderate, or low.

2. The inspection frequency for fixed food premises, as outlined in the Ontario Public Health Standards – Food Safety Protocol, is:

  • Not less than once every 4 months for high-risk food premises
  • Not less than once every 6 months for moderate-risk food premises
  • Not less than once every 12 months for low-risk food premises

3. Food premises will be inspected as per CA.86.01/02.100 Food Premises Inspection – All Food Premises.

Infection Control Inspection(s) in Licensed Day Nurseries:

Licensed day nurseries will be inspected at a minimum frequency of once per year, as per the Ontario Public Health Standards – Infection Prevention and Control in Licensed Day Nurseries Protocol and the Risk Assessment of Facilities Protocol. Additional inspections will be conducted as necessary to follow up on any issues identified during annual compliance inspections, in response to Ministry or other agency requests for inspection, and in response to outbreaks, specific complaints by members of the public, or facility requests for inspection.

Compliance Inspections and Re-inspections:

4. Upon arrival at the premises, the Public Health Inspector (PHI) shall identify him/herself to the owner/operator and state the reason for the visit. The owner/operator shall be given the opportunity to accompany the PHI during the inspection.

5. Depending on the type of premises to be inspected, inspections may be done at any reasonable time during the premises’ normal hours of operation; however, the CID Manager must approve inspections done outside of regular business hours.

6. The PHI will use the Food Inspection electronic form in Hedgehog to conduct food premises inspection as per CA.86.02.100 Food Premises Inspection – All Food Premises. Refer to the WDGPH Hedgehog Processes and Procedures Manual: Inspector Role for instructions on how to complete the form. If there is a new owner of the premises, a change in the premise name, or a change in address, the PHI may complete the inspection using a paper inspection report and transfer the inspection information to Hedgehog once the necessary changes to premise information have been made.

7. The PHI will use the Day Nurseries Inspection Report electronic form in Hedgehog to conduct the annual infection control inspection of the premise. Refer to the WDGPH Hedgehog Processes and Procedures Manual: Inspector Role for instructions on how to complete the form. If there is a new owner, a change in the business’ name, or a change in address, the PHI must complete the inspection using a paper inspection report and transfer the inspection information to Hedgehog once the necessary changes to facility information have been made.

8. If necessary, such as during inspection of large facilities with multiple classrooms, playrooms, and/or kitchen areas, the PHI may  use the assigned evidence notebook to capture inspection details observed during the inspection, which will then be transcribed into the Hedgehog inspection report prior to leaving the premises and prior to obtaining an operator signature. Refer to CA.86.01/02.103 Notebook Documentation.

9. The PHI shall document whether the inspection was scheduled or unannounced, and if the inspection was scheduled, the reason for the scheduled visit and how far ahead of the inspection the visit was scheduled.  When answering this question in Hedgehog, the PHI must select the appropriate canned comment, indicating the WDGPH policy and procedure which was followed during the inspection.

10. The PHI shall document the time at which the inspection was conducted, whether the inspection was a joint inspection with another PHI or other individual (e.g., Ministry employee, student PHI, etc.).

11. During the inspection, the PHI shall use this time to provide staff and operators with infection prevention and control education and information including fact sheets, updated signs, etc. Each inspection will vary in length according to the risk assessment category, and the premise specific issues identified during the inspection, as applicable.

12. The PHI will assist licensed day nurseries in the development, implementation, and maintenance of relevant infection prevention and control policies and procedures, as per Ontario Public Health Standards – Infection Prevention and Control in Licensed Day Nurseries Protocol and may request relevant policies and procedures for annual review.

13. The PHI will document the date the last enrolment list was submitted to WDGPH. If greater than six months, it will be noted as an infraction requiring correction.

14. The PHI will record any observed infractions on the Hedgehog inspection form. If potential infection prevention and control or environmental issues are identified, the PHI will select ‘NO’ in response to the relevant compliance question, and will select the appropriate canned comment. The PHI will also record any observations relevant to the observed infraction, the required actions to be taken by the premises, and the expected date for compliance for each non-compliant item. Deadlines for compliance will be determined in discussion with the operator and will be based on the severity of the observed infraction and realistic time frames for corrective action. Operator comments regarding anticipated completion dates and corrective actions to be taken will be documented under the operator response comment section for each relevant item.

15. The time frame for follow-up re-inspections will depend on the items to be corrected and the importance of these non-compliant items with regards to their potential to result in an infectious disease outbreak or to present a health hazard or infection control risk.  

16. The PHI will record any observed infractions that are corrected during the inspection by selecting ‘CDI’ in response to the relevant compliance question, and will select the appropriate canned comment. The PHI will also record any observations relevant to the observed infraction and the remedial actions taken by the operator to address identified non-compliance.

17. If the PHI has selected ‘NO’ to one or more questions, the PHI will select ‘Report Reviewed - Action Required’ at the end of the report.

18. The PHI will attempt to observe all applicable aspects of infection prevention and control practices that are carried out by a premise during inspection. Where a specific process is unable to be observed at the time of inspection (e.g., if no diaper changing is taking place at the time of inspection) the PHI will record the item as ‘Not Observed’ on the Hedgehog inspection form and will attempt to verify that appropriate infection prevention and control practices are followed, via discussion with the operator and/or staff. Operators may be asked questions regarding infection prevention and control practices and may be asked to describe steps that are followed during unobserved infection control practices, such as diapering, tooth brushing, pet handling, etc. Any items that are not relevant to the premises (e.g., if the premises does not perform diapering or does not have any pets onsite) will be selected as ‘N/A’. 

19. The PHI will review the completed inspection report with the operator/staff member present at the time of inspection. The PHI will discuss and explain the public health significance of the inspection, findings, violations, and requirements to comply with the Health Protection and Promotion Act and associated Public Health Standards and Protocols.

20. The PHI will advise the owner/operator of the expected dates of compliance for items observed during the inspection to be potential infection prevention and control risks.  The owner/operator will be given an opportunity to ask questions or clarify concerns. The operator will be informed of the enforcement consequences of not resolving identified non-compliant items by the deadlines indicated on the inspection report.  

21. The PHI will ask the owner/operator to sign the completed inspection report. The PHI will sign the report after obtaining the signature of the owner/operator. The PHI will indicate on the report the method by which the inspection report will be delivered to the owner/operator (e.g., fax, email, mail, hand delivery).

NOTE: The signature of the owner/operator is not required for completion of the inspection form(s). If the operator refuses to sign the report or is unavailable to sign the report once the inspection is completed, this must be documented under the closing comments section of the report.

22. If a re-inspection of a premise is required in order to address non-compliant items from a previous inspection, all items that were in compliance at the time of the original inspection will be selected as ‘Not Observed’ at the time of re-inspection. Any items that are not relevant to the premises (e.g., if the premises does not perform diaper changing) will be selected as ‘N/A’. 

23. If non-compliant items from the original inspection are observed to still be not in compliance at the time of re-inspection, enforcement through the issuance of a Section 13 order by a PHI under the Health Protection and Promotion Act  (HPPA) or  referral to the relevant County or Ministry representative will be considered, in discussion with the Program Manager/Supervisor.

24. The PHI will review the details of the re-inspection report with the owner/operator. 

Enforcement Actions under the HPPA:

25. Non-compliance where a health hazard (as defined by Section 1 of the HPPA) is deemed to exist will result in the issuance of a Section 13 order by a PHI under the HPPA. The Section 13 order may require the closure of a premise, a “cease and desist”, or action taken that is deemed necessary by the PHI to minimize or prevent the health hazard from occurring. The PHI will issue a verbal order for the item(s) in question at the time of inspection and will document any enforcement actions on a separate inspection report. The PHI will follow-up the verbal order with a written order as soon as possible, which will state the time frame for compliance with the order. Where the PHI recommends the closure of a premise, this will be determined through consultation with the Program Manager/Supervisor and Director of HPD.

26. Non-compliance where a communicable disease (as defined by Section 1 of the HPPA) is concerned may result in the issuance of a Section 22 order by an MOH under the HPPA. The Section 22 order may require taking or refraining from taking any action deemed necessary by the MOH to decrease or eliminate the risk of a communicable disease or a communicable disease outbreak.

27. The PHI, MOH (or designate) will review the details of the order with the owner/operator at the premises. The PHI, MOH, or designate will ensure the owner/operator understands that failure to comply with the order may result in a legal charge under the HPPA. The PHI, MOH, or designate will ensure the owner/operator is aware of the right to appeal the order and the procedure to be followed in the event of an appeal.

28. Additional enforcement or legal actions (such as the issuance of a summons under Part III of the POA) or referral to the relevant County or Ministry representative will be considered after discussion with the Program Manager/Supervisor and HPD Director.

Complaints and Other Investigations:

29. All complaints received about food handling, infection control practices, or other concerns will be entered into Hedgehog as a CSR and investigated within 24 hours as per CA.82.02.113 Infection Control Complaints and CA.80.02.107 Food Premise, Food-Related, and Food Product Complaint Investigation.

30. The PHI will conduct an on-site investigation in response to all food-related and food product complaints as per CA.80.02.107 Food Premise, Food-Related and Food Product Complaint Investigation, and will document any relevant observations and/or actions taken in an inspection notebook, CSR, and/or Hedgehog inspection report, as applicable. The CSR complaint must be cross-referenced in the facility’s Excelicare file.

31. If complaints associated with suspect food-borne illness are received, these will be followed up as per CA.82.02.115 Suspect Food-borne Illness Community Food-borne Illness. Where the taking of food samples is deemed necessary as part of a suspect food-borne illness or outbreak investigation, this will be done as per CA.86.02.101 Food Specimen Collection.

32. If complaints associated with a suspect water-borne outbreak are received, these will be followed up as per procedure CA.82.02.107 Waterborne Outbreak Investigation.

33. When inspection of a food premises is required due to a product recall, this will be done as per CA.86.02.108 Food Recall in Institutions and Daycares.

34. When inspection of a food premises involves or suspects non-commercially processed foods, investigation of these foods will be conducted as per CA.80.02.114 Non-Commercial Processed Foods.

35. Where photographs are taken as part of a complaint investigation, these will be taken as per CA.86.02.104 Collecting Photographic Evidence, and documented as per CA.86.02.103 Notebook Documentation.

36. Following the investigation of a food-related complaint, findings will be reported to the complainant as per CA.80.02.107 Food Premise, Food-related, and Food Product Complaint Investigation. Following the investigation of an infection control complaint, findings will be reported to the complainant as per CA.82.02.113 Infection Control Complaints.

New Premises:

New licensed day nursery premises will only have an opening inspection after floor plans have been reviewed and approved by WDGPH. The floor plans should clearly identify all plumbing fixtures and identify separate hand basins to be used for hand washing, sinks/equipment to be used for utensil cleaning and sanitizing, and the location of washrooms, food preparation, and food storage areas. CA.80.02.106 Approving Plans for New or Renovated Food Premises will be followed when the daycare also has a licensed food premise.

City of Guelph Business License By-law:

The PHI shall respond to requests by the City of Guelph for business license inspections. The PHI will look up the last compliance inspection conducted at the premise, and if the inspection was within the last frequency period required (e.g., within the previous four months for a high-risk premise) the PHI may approve the premise for licensing as long as the inspection records indicate no critical infractions. If the last compliance inspection of the premise was not within the required frequency period (e.g., greater than four months previously for a high-risk premises) the PHI must conduct a new inspection of the premises within four weeks of the request. All premise licensing approvals or non-approvals will be forwarded to the City of Guelph Licensing Coordinator by the relevant Program Assistant (PA) on a monthly basis, or at a frequency based on request by the City of Guelph.

RESPONSIBILITIES

Management will:
  • Ensure CID PHI staff are oriented to all related policies and procedures; and
  • Are equipped with tools/resources to safely and thoroughly complete food safety and infection control inspections in daycares.
 Employees will:
  • Conduct assessments of infection prevention and control policies and practices within licensed day nurseries;
  • Provide written information to licensed day nurseries explaining the required reporting process of cases and outbreaks of reportable infectious diseases to the Medical Officer of Health;
  • Assist in outbreak management as required;
  • Annually review outbreak management plan with licensed day nurseries;
  • Collect current enrollment lists and immunization records from licensed day nurseries to be kept on file for review in the event of an outbreak;
  • Assist licensed day nursery operators in implementing infection prevention and control policies, programs, and practices such as:
  • Communicable disease control
  • Hygiene and disinfection practices
  • Hand hygiene
  • Diapering and toileting practices
  • Surveillance
  • Communication with parents and staff
  • Maintenance of immunization records of enrolled children
  • Required reporting of cases and outbreaks of reportable diseases
  • ​Management of and response to infectious diseases
  • ​​Exclusion of sick children, staff, parents, or volunteers from the day nursery;
  • Provide educational resources to licensed day nursery operators regarding infection prevention and control policies and practices; and
  • Provide an annual in-service education on appropriate current infection prevention and control practices to licensed day nursery operators and staff.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Policy CA.82.01.128 Inspection of Licensed Day Nurseries and Associated Programs
CA.80.02.103 Special Events
CA.80.02.106 Approving Plans for New or Renovated Food Premises
CA.80.02.107 Food Premise, Food-Related, and Food Product Complaint Investigation
CA.80.02.114 Non-Commercial Processed Foods
CA.80.02.180 Food Condemnation
CA.82.02.104 Reportable Disease Follow Up/Outbreak Control
CA.82.02.107 Waterborne Outbreak Investigation
CA.82.02.113 Infection Control Complaints
CA.82.02.115 Suspect Food-borne Illness Community Food-borne Illness
CA.86.02.100 Food Premises Inspection – All Food Premises
CA.86.02.101 Food Specimen Collection
CA.86.02.102 Rural Food Premises Water Samples
CA.86.02.103 Notebook Documentation
CA.86.02.104 Collecting Photographic Evidence
CA.86.02.108 Food Recall in Institutions and Daycares
Child Care and Early Years Act, 2014
Control of Gastroenteritis Outbreaks in Long-Term Care Homes
(MOHLTC, as current)
Food Safety Protocol
Health Protection and Promotion Act
Hedgehog Processes and Procedures: Inspector/PHN Role
(as current)
Infectious Diseases Protocol (as current)
Ontario Public Health Standards – Food Safety Protocol
Ontario Public Health Standards – Infection Prevention and Control in Licensed Day Nurseries Protocol

Ontario Regulation 562 – Food Premises
Provincial Offences Act
Risk Assessment of Facilities Protocol

CONTACT FOR INQUIRIES

Manager, Control of Infectious Diseases

APPROVED BY

Director, Health Protection