HomeMy WebLinkAboutAGENDA REPORT 2014 0917 CCSA REG ITEM 10Y ITEM 10.Y.
CITY OF MOORPARK,CALIFORNIA
City Council Mooting
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MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
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FROM: David A. Bobardt, Community Development Director
DATE: September 8, 2014 (CC Meeting of 9/17/2014)
SUBJECT: Consider: 1) Proclaiming the Welcome Home Soldier Foundation's
Moonshiners Barbeque Event on October 4, 2014, and the Rotary
Club of Moorpark's Civil War Reenactment on November 8-9, 2014,
as Community Events for the Purposes of Obtaining Temporary
Food Facility Permits from the County of Ventura Environmental
Health Division; and 2) Directing Staff to Prepare a New City Council
Policy on Proclaiming Certain Public Events as Community Events
BACKGROUND
Temporary Use Permit Application No. 2014-19 was filed on July 18, 2014 by the
Rotary Club of Moorpark for a historical reenactment of the American Civil War,
including encampments, to take place on November 8-9, 2014 at the Waste
Management property east of Moorpark College. Temporary Use Permit No. 2014-26
was filed on August 26, 2014 by the Welcome Home Soldier Foundation for a
Moonshiners Barbeque Fundraising Event to take place on October 4, 2014 at the
PennyMac parking lot (6101 Condor Drive). Both of these events are open to the
public, sponsored by Moorpark-based non-profit organizations as fundraising events,
and are being held on private property. Both of these events are also seeking a
temporary food facility permit from the County of Ventura Environmental Health
Division. Because these events are being held on private property instead of public
property, the City needs to proclaim these events as "community events" in order for the
County to consider temporary food facility permits.
DISCUSSION
Retails sales of food are regulated by the California Health and Safety Code (Section
113700 et seq.), with specific regulations identified for temporary food facilities at
community events. Health and Safety Code Section 113755 defines a community
event as, "An event that is of civic, political, public, or educational nature, including state
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Honorable City Council
September 17, 2014
Page 2
and county fairs, city festivals, and other public gathering events approved by the local
enforcement agency. The County of Ventura Environmental Health Division is the local
enforcement agency for this part of the Health and Safety Code.
On May 14, 2013, the County of Ventura Board of Supervisors approved a
recommendation of the County's Environmental Health Division to define a community
event to be either be 1) a planned public gathering on public property sponsored by a
non-profit organization formed for charitable purposes or a governmental entity or 2) a
temporary event where a local jurisdiction has proclaimed it to be a community event. A
copy of the staff report to the Board of Supervisors is attached. The Environmental
Health Division would only consider a temporary food facility permit for an event that
meets one of the above definitions. It should be noted that a temporary event where
food is only served from a County-licensed mobile food facility (e.g. food truck) is
exempt from the requirement for a temporary food facility permit. A copy of the County
staff report is attached.
The Moonshiners Barbeque and the Civil War Reenactment events both meet the
State's definition of a community event for the purposes of being recognized as
temporary food facilities under the Health and Safety Code. However, because they are
being held on private property instead of public property, a proclamation from the City is
required in order for the County of Ventura Environmental Health Division to recognize
these events as community events. Staff recommends that such a proclamation be
made by the City Council.
In order to expedite the proclamation of a local temporary event as a community event
in the future, staff recommends creation of a Council policy that allows an expedited
process to proclaim certain additional types of temporary events as community events.
Such events that would be consistent with the State's definition of community event
could include:
o Temporary events open to the public operated by City of Moorpark non-profit
organizations on public or private property for which a Temporary Use Permit has
been approved.
• Temporary events open to the public in the commercial or industrial zones
authorized by Section 17.20.060 of the Zoning Ordinance (Christmas tree sales,
circuses, festivals, sidewalk sales, special events, and outdoor sales) for which a
Temporary Use Permit has been approved.
Should the City Council concur, staff could be directed to prepare such a policy for
Council consideration at a future meeting.
FISCAL IMPACT
None.
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Honorable City Council
September 17, 2014
Page 3
STAFF RECOMMENDATION
1. Proclaim the Welcome Home Soldier Foundation's Moonshiners Barbeque Event
on October 4, 2014, and the Rotary Club of Moorpark's Civil War Reenactment
on November 8-9, 2014, as Community Events as defined by Section 113755 of
the California Health and Safety Code for the purposes of obtaining temporary
food facility permits from the County of Ventura Environmental Health Division;
and
2. Direct staff to prepare a new City Council policy on proclaiming certain public
events as community events to be incorporated in the next update of the city
Council Policies Resolution.
Attachment 1: May 14, 2013 Staff Report to Board of Supervisors
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RESOURCE MANAGEMENT AGENCY
Environmental Health Division
William C. Stratton
Director
May 14, 2013
Board of Supervisors
County of Ventura
800 South Victoria Avenue
Ventura, California 93009
Subject: Receive and File presentation regarding Community Events,
Temporary Food Facilities and Mobile Food Facilities; authorize staff
to recognize an event as a Community Event based on the proposed
criteria; authorize continuation of fee waivers and reductions in the
Temporary Food Facility program; and authorize permit
requirements for Mobile Food Facilities.
Recommended Actions:
1. Receive and file a presentation regarding Community Events, Community Event
Organizers, Temporary Food Facilities, and Mobile Food Facilities programs
regulated by the Environmental Health Division.
2. Authorize the Environmental Health Division to designate an event not previously
recognized by the Division as a Community Event using the criteria discussed in
this Board letter.
3. Authorize staff to continue the fee waiver and reductions for non-profit and for
profit Community Event Organizers and Temporary Food Facility operators; and
implement regulatory oversight of Community Events and Temporary Food
Facilities as described in this Board letter.
4. Authorize the Environmental Health Division to offer a one year grace period to
vehicles that do not meet state code requirements as Mobile Food Facilities and
allow these vehicles to obtain a permit as a Temporary Food Facility effective
July 1, 2013. After July 1, 2014 vehicles must obtain a permit as a Mobile Food
Facility or cease operating in Ventura County.
JA 5 3 13 G:\Admin\BOARDL TR\MFF _ TFF _CE_Board_Ltr_5_ 14_ 13v4.docx Page 1 of 8
800 South Victoria Avenue, Ventura, CA 93009-1730 (805) 654-2813 FAX (805) 654-2480
CC ATTACHMENT 1 457
Board of Supervisors
May 14, 2013
Page 2 of 8
Fiscal/Mandates impact:
1. Mandatory:
2. Authority:
3. Source of Funding:
4. Funding Match Required:
5. Impact to Other Department(s):
Environmental Health Division
Revenue
Costs:
Direct
Indirect-Dept.
Indirect-County CAP
Net County Cost
Recovered Indirect Cost (Department and County
CAP)
Yes
California Health and Safety Code,
(California Retail Food Code), Section
113700 et seq.
Permit fees; Board Cost Reduction.
No
None.
FY 2012-2013
$3,375,513
$3,339,204
$16,476
$19,833
0
$36,309
FY 2013-2014
$3,779,281
$3,504,430
$196,378
$78,473
0
$274,851
·--·-
FY 2012-13 Budget Projection for Org 4754 -Environmental Health Division
Community Services
Adopted Adjusted Budget Projected Budget Estimated Savings
Budget (Deficit)
ApproQriations $3,661,669 $3,679,626 $3,570,333 $109,293
Revenue $3,573,786 $3,573,786
1
$3,586,436 ($12,650)
Net Cost $87,883 $105,840 ($16, 103) $121.943
Sufficient revenue and appropriations are available in the current year's Adjusted
Budget and will be included in the FY14 Preliminary Budget
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Board of Supervisors
May 14, 2013
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DISCUSSION:
Executive Summary:
The Centers for Disease Control (CDC) estimates that each year roughly 1 in 6
Americans or 48 million people will get sick, 128,000 will be hospitalized and 3,000
people will die from foodborne diseases. The CDC also estimates that between the
years 2000 and 2008 there were 7 4 7 confirmed cases of food borne illness from 20
outbreaks associated with fairs, festivals and temporary mobile food services in
California. It is noteworthy that no foodborne illness outbreaks or significant
enforcement activities concerning Temporary Food Facilities have occurred at
Community Events in Ventura County over the past 12 years.
In Ventura County, Community Events and the Temporary Food Facilities (TFFs) that
operate at these events have evolved into an extremely popular way of raising funds for
various non-profit and for-profit organizations. As the local enforcement agency, the
Environmental Health Division (Division) is responsible for issuing health permits to
Community Event organizers and TFFs, and for conducting inspections of these
facilities to ensure that state safe food handling standards are being met. A significant
increase in the number of Community Events has resulted in an increase in demands
for TFF permits. This increase coupled with the Board-authorized waiver and reduction
of permit fees for Event organizers and TFFs have presented challenges to maintaining
regulatory oversight of the TFFs operating at these events. Additionally, the growth of
the gourmet food truck industry has raised significant questions related to the types of
permits the Division issues to Mobile Food Facilities (MFFs) operating in Ventura
County.
Today, to address these challenges and to ensure that state code requirements are
uniformly applied we are seeking your Board's guidance as to: 1) the type of event that
should be considered a Community Event; 2) the continued waiver or reduction of TFF
permit fees authorized by your Board, and the effect this will have on the regulatory
oversight of TFFs by this Division; and 3) the administration and type of permit the
Division should issue for MFFs that do not meet state code requirements.
Community Events:
The first item for which the Division is seeking direction from your Board is to identify
what types of events the County wants to formally recognize as a "Community Event".
More specifically, the Division is seeking direction on whether an event not previously
designated as a Community Event should be considered a Community Event based on
the following criteria: if the event is: 1) held on public property and the organizer or
sponsor is a non-profit organization; or 2) formally recognized by a local jurisdiction
adopted proclamation or resolution designating the event as a Community Event.
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Board of Supervisors
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Currently, the California Health and Safety Code (state code) defines a Community
Event as:
An event that is of civic, political, public, or educational nature, including state and
county fairs, city festivals, circuses, and other public gathering events approved by the
Local Enforcement Agency.
This definition is very broad and clearly reflects the legislature's intent to provide the
local enforcement agency wide latitude to determine which types of events qualify as a
Community Event. Moreover, the code does not differentiate between events hosted or
put on by non-profit or for-profit organizers, nor does it specify whether these
community events should be held on private or public property. The only criteria in the
code are that the event must be of a "civic, political, public, or educational nature". As
such, the Division has used a very expansive definition and, not surprisingly, the
number of events has grown over the years. In 2001 there were approximately 39
Community Events held in Ventura County, and by 2012 the number had grown to 457
events.
Over the years, the Division has attempted to clarify what types of activities should be
considered a Community Event by requiring that the event: 1) be a planned public
gathering on public property; and 2) be sponsored by a non-profit organization formed
for charitable purposes or a governmental entity. In practice this approach presumes
that because the event is held on public property and is run by a non-profit or
governmental organization, the event is de facto a Community Event. It does not
address or specify how the event is of a civic, political, public, or educational nature.
The determination of what constitutes a Community Event is extremely important not
only to the event organizers but also to the individual TFFs. The importance stems from
the State statutes which allow TFFs to operate only at Community Events, and further
limits non-profit charitable TFFs to operate at no more than 4 events per year.
In recognition of the importance of fund raising events; and to accommodate the
numerous organizations and other fund raising events, the Division has taken a very
expansive interpretation of what types of events should qualify as Community Events.
In an effort to further clarify how this determination can be made, the Division introduced
an option whereby a local jurisdiction could formally recognize an event through a
declaration or proclamation identifying it as a Community Event. In simple terms, for
example, if a City Council adopted a resolution recognizing an event as a Community
Event, the Division accepted the designation. The notion here is that the City Council
represents the "community" and as such should be the entity determining whether an
event is a Community Event or not.
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To date, only the following events have been formally recognized by local jurisdictions
as being Community Events:
• Events open to the public held at the Hummingbird Ranch -private
property -City of Simi Valley.
• The WAV -art events open to the public held at the artists' colony -City
of Ventura.
• Harvest Month -Heritage Valley -October 2010 -Board of Supervisors.
o Downtown Ventura Organization
• Simi Town Center
The code identifies circuses, state and county fairs, city festivals, swap meets and
certified farmers markets as Community Events. It appears that the legislature
considers large events with broad social and demographic appeal to be Community
Events. Clearly these events are meant to be a benefit to the community in which they
will be located and as such the local jurisdiction is in the best position to determine if the
event is of a civic, political, public, and educational nature. The five events listed above
are recognized by local jurisdictions as Community Events and are consistent with the
types of Community Events recognized in the state code.
This approach creates a more transparent decision making process and provides
flexibility to local jurisdictions to determine the civic, political, public, and educational
nature of an event that may be unique to their communities.
Events could be added to this list if the event is held on public property and the
Community Event organizer is a non-profit organization formed for charitable purposes,
or the event is held on private property and the local governmental jurisdiction issues a
proclamation or resolution designating the event as a Community Event. Events that do
not meet these criteria will not be considered Community Events. Although TFFs would
be prohibited at such events, prepared foods could still be available to the public from
mobile food facilities (MFFs) provided they possess a valid annual permit from the
Environmental Health Division.
Temporary Food Facilities -Permit Fee Waivers:
The second item in which we seek direction from your Board, concerns whether your
Board wants to continue the practice of waiving permit fees or offering a reduced permit
fee to Community Event organizers and TFFs.
The California Health and Safety Code (state code) defines a TFF as:
A food facility approved by the enforcement officer that operates at a fixed location for
the duration of an approved Community Event or at a swap meet, only as part of the
Community Event or swap meet.
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In Fiscal Year 2001/02, in an effort to reduce permit fees to TFFs and Community Event
Organizers (organizers), your Board authorized the Division to waive the entire permit
fee for non-profit TFFs and organizers, and provide a 50% fee reduction to any for-profit
organizers and TFFs, provided they completed an annual Food Handlers Training class
offered by the Division. The rationale for this action was that TFF operators and event
organizers who successfully completed this course would be more familiar and operate
in conformance with state standards concerning the design, maintenance and operation
of these types of transient food facilities, thereby reducing the Division's staff regulatory
oversight of these facilities.
Although we expected our oversight to decrease after the organizers and TFF
operators successfully completed the annual training class, our field observations during
these events revealed that many operators failed to comply with minimum code
requirements during the set-up and operation of their TFFs. This in turn led to an
increase, not a decrease, in EHD staff oversight at these events. In 2001 there were
approximately 400 TFFs operating at Community Events in Ventura County. In 2012
this Division inspected and issued permits to approximately 2, 167 TFFs.
The increase in the number of Community Events and TFFs operating at these events
has created operational problems within the Community Services program. In 2001, the
Division was able to provide training, inspect all TFFs operating at Community Events,
and absorb the cost without significantly impacting its overall Food Facility inspection
program. This has not been. the case over the past several years.
Due to the increase in the number of Community Events and TFFs operating at these
events, coupled with limited revenue as a result of fee waivers, the Division can no
longer absorb these costs or provide the same level of regulatory oversight as we have
in the past. A further impact to the program is that a majority of Community Events take
place after hours and during the weekend, and in order to maintain regulatory oversight
at these events Division staff have been diverted from their normal inspection duties,
which has prevented them from maintaining the Board-directed inspection frequency at
our fixed location facilities.
Since 2001/02, partial cost recovery for this waiver program has been accomplished
through fee adjustments authorized by your Board to all fee categories in the EHD retail
food program. The remaining costs are reflected in the EHD budget as net County cost.
The Division estimates the revenue shortfall in fiscal year 2012-13 for the TFF program
will be $251,353, of which approximately $180,000 represents waived fees.
The Community Services Fee Resolution, which will be before the Board next week
(May 21, 2013), includes a proposed 4% fee increase in our food facility permit fees,
which include the TFF fees. This proposed ~ncrease will help recover a small portion of
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Board of Supervisors
May 14, 2013
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the TFF program costs, and will allow us to increase hours for our two part-time
weekend staff. This will help resolve some of the staffing issues, but will not completely
address the demands of the TFF permitting and inspection program.
If your Board continues the current fee waiver program, the Division wilt accelerate
efforts to reduce its TFF permit and inspection oversight to ensure inspection frequency
targets at fixed facilities are met. We will look at expanding our annual permit program
for qualified TFF operators, and focus our oversight efforts on periodic inspection of
TFFs that present the greatest potential for the transmission of foodborne illness based
on the types of potentially hazardous foods they prepare and provide to the public.
Finally, for the non-profit charitable TFFs and TFFs that only sell pre-packaged non-
potentially hazardous foods, the Division will no longer conduct routine monitoring
inspections. Instead the Division will conduct inspections only as part of a complaint
investigation.
Mobile Food Facilities:
The final area where the Division seeks direction from your Board concerns the permit
requirements and continued operation of Mobile Food Facilities (MFFs).
In recent years the "Gourmet Food Truck" industry was launched and the gourmet food
truck craze found its way to Ventura County. Community Event organizers jumped on
the gourmet food truck craze by inviting trucks from Los Angeles County to participate in
their event with the hope of attracting larger crowds. Many of the trucks from Los
Angeles County are older vehicles that had been wrapped in colorful artwork but did not
meet current code requirements, and therefore were unable to obtain a permit and
operate as a MFF in Ventura County.
The state code defines a Mobile Food Facility, in pertinent part, as:
Any vehicle used in conjunction with a commissary or other pennanent food facility
upon which food is sold or distributed retail. Mobile food facility does not include a
transporter used to transport packaged food from a food facility, or other approved
source to the consumer.
The code goes on to describe the design and operational requirements that must be
met before a permit from the local enforcement agency can be issued. In summary the
state code requires these vehicles must have mechanical refrigeration, three
compartment sinks with hot and cold running water, mechanical ventilation, and waste
water holding tanks sized in conformance with code requirements. Typically, the older
MFFs do not have the appropriate equipment to maintain proper food temperatures
when these vehicles remain stationary for long periods of time, as they often are at
these gourmet food truck events.
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The state code requires that a health permit for a MFF can only be issued if all design
requirements have been met. As a result, the Division was unable to issue health
permits to older vehicles that did not meet the design requirements, many of which were
from Los Angeles County and had permits from that county issued under the previous
guidelines. Due to the increasing popularity of these Gourmet Food Truck events, and
the influx of older vehicles from Los Angeles County, in addition to vehicles from within
Ventura County that could not be permitted as MFFs, the Division made an effort to
accommodate the event organizers and allow these vehicles to operate with a TFF
permit. However, under the law TFFs may only operate at Community Events.
The design and operational requirements for a MFF are much more stringent than
requirements for a TFF. Thus, the Division's attempt to create an accommodation has
had an unintentional effect of creating an uneven playing field in that vehicles that
cannot meet requirements as a MFF are now operating as TFFs with reduced
requirements and permit fees, while permitted MFFs must meet more stringent design
and operating requirements and pay a higher permit fee.
Given the inequities associated with the current MFF permitting process, the Division
believes it is no longer viable to issue TFF permits to vehicles which should meet MFF
standards. To this end, the Division recommends that your Board authorize a one year
grace period in which non-code conforming MFFs will be allowed to operate as TFFs to
give them time to meet the code requirements as a MFF. The Division will notify the
vehicle owners and operators about this grace period and will work with them if they
choose to go through the plan check process to upgrade their vehicles and come into
compliance with the code requirements as MFFs.
The County Executive Office, Auditor-Controller's Office, and County Counsel have
reviewed this matter. Please call me at 654-2818 or Betty Huff at 654-2814 if you have
any questions.
William C. Stratton, Director
Environmental Health Division
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