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when operators cross state lines. For Maumee Valley Vend - ing Co. in Defiance, OH, it has been a challenge to meet changing and strict regulations in its home state, and then varying requirements in nearby Indiana and Michigan. "When we first started, we proactively worked with the health department to come up with food safety require- ments such as wrapping fruit that didn't have a peel, installing automatically locking coolers, etc.," said Terry Miller, general manager at Maumee Valley Vending Co. However, two years ago, the micro markets were reclas- sified to be a level one restaurant, which increased the license cost and requirements significantly. Now Maumee Valley Vending Co. has to submit a 20 page plan review per market that includes things like lighting charts. "It's more requirements than are necessary and it seems to be a problem with education," indicated Miller. He recalls a health department director coming to a scheduled inspec- tion at a new micro market installation. "The director got there, looked around and said 'Is this it?'" said Miller. He knew that the director had not fully understood the concept of the micro market and that it lacked the food preparation and cooking areas restaurants and conve- nience stores have which increase foodborne illness risk. In neighboring states, Miller has few, if any, require- ments, but he ensures he is staying proactive with those health departments as well. "It requires vigilant, good relationships and education. They need to understand what our business is and what it is not," said Miller. Common sense guidelines The recommended guidelines from the Conference for Food Protection are fairly straight forward and address the three main areas of food safety concerns: food spoilage due to high temperature/equipment failure, illegal food tampering and potential cleanliness issues that arise when no person is present. Food spoilage happens when the temperature at which food is kept rises. This is addressed in the guideline by requiring an automatic self-locking cooler/freezer, either built-into by the manufacturer or a retrofit device added afterwards. The mechanism needs to lock the cooler or freezer, preventing a consumer from purchasing potentially spoiled food in the event of a power failure or equipment malfunction that causes the tem- perature to rise to unsafe levels. The food could start to develop bacteria growth at dangerous levels that can cause illness. NAMA has already established a certification process for these mechanisms, and lists companies with approved models on its website (vending tab > certified companies). The Public Health and Safety Organization, NSF, also recently added language to its standard to cover unattended units that would be used in micro markets. "If you want to sell food, you might as well buy the [right] unit," said Eils who warns that most provided cool- ers from suppliers are not intended for food, but bever- ages. Eils also doesn't see any stricter regulations in the works, meaning operators can reasonably guarantee that if they invest in locking coolers now, even before their local health department has regulations, the technology they buy will meet the regulations once the health depart- Take action to protect micro markets The U.S. Food and Drug Administration will want to know how micro market operators can ensure food safety, especially in regards to preventing food tam- pering. If the industry can prove that video surveil- lance reduces incidences of theft through data, this can also show that surveillance will reduce tampering. Look for an upcoming survey or information requests from NAMA to collect this information, which could be instrumental in proving micro markets are a safe way to provide food and should be included legally in the food code. 32 Automatic Merchandiser VendingMarketWatch.com October/November 2016 R E G U L A T I O N S A N D L I C E N S I N G