To: Board of Health
Through: Jennifer Ludwig, Public Health Director, Arapahoe County Public Health
Prepared By:
prepared
Josh Skeggs, Environmental Health Supervisor (Consumer Protection), Public Health
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presenter
Presenter: Josh Skeggs, Environmental Health Supervisor (Consumer Protection), Public Health
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Subject:
title
Shakhruz LLC d/b/a Tandoori Deli Halal, 4034 S Parker Rd, Aurora, Colorado Retail Food Safety Enforcement and License Revocation Hearing
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Purpose and Request:
recommended action
The purpose of this hearing is to inform the Board of Health (BOH) about violations related to a Retail Food Establishment operated by Shakhruz LLC, d/b/a Tandoori Deli Halal, located at 4034 S Parker Rd in Aurora, Colorado, 80014, located within Arapahoe County. Due to ongoing and repeated food safety violations, Arapahoe County Public Health (ACPH) formally requests that the Board of Health review this case and authorize revocation of the Retail Food Establishment License. This action is requested to protect public health and prevent further noncompliance.
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Background and Discussion: Foodborne illness in the United States is a major cause of personal distress,
preventable illness and death, and avoidable economic burden. It is a shared responsibility of the food industry and the regulatory authority to ensure that food provided to the consumer is safe and does not become a vehicle in a disease outbreak or in the transmission of communicable disease. This shared responsibility extends to ensuring that consumer expectations are met and that food is unadulterated, prepared in a clean environment, and honestly presented.
A hearing is requested and presented before the Board of Health in response to numerous, ongoing, and pervasive severe violations of the Colorado Food Protection Act, Colorado Revised Statute (C.R.S.) §25-4-1601 et seq. (herein referred to as ‘the Act’), and of the Colorado Retail Food Establishment Regulations, 6 CCR 1010-2 (herein referred to as ‘the Regulations’). The owner and operator was served the Notice of Hearing (Exhibit A) via mail sent to the listed ownership address (4034 S Parker Rd, Aurora CO) as well as via email of the registered agent, Shakhruz Erkinov (eShakhruz@gmail.com <mailto:eShakhruz@gmail.com>).
Arapahoe County Public Health (ACPH) has conducted inspections at Tandoori Deli Halal under the ownership of Shakhruz LLC. Attached below is a Table of Contents of the exhibits presented by ACPH. They comprise the inspection reports for the restaurant inspections conducted since March 2025 to present (Exhibits B through DD), in chronological order. The Table of Contents also includes comments to summarize the outcome of each inspection. Each inspection report includes an Observation section where the inspector summarized their observations and identified the specific Food Code violation. Through regulation, Colorado has adopted the 2022 Recommendations of the United States Public Health Service/Food and Drug Administration as published by the U.S. Department of Health and Human Services, Public Health Service, Food and Drug Administration, referred to as the “Food Code.” Colorado Retail Food Establishment Regulations, 6 CCR 1010-2, available at <https://drive.google.com/file/d/1kEtv4f6YciFXXzLEu6amUc9Anu9uWGYn/view>.
ACPH has conducted 29 inspections at Tandoori Deli Halal since March 2025 (Exhibits B through DD), where most retail food establishments average 1 inspection each year. Of these 29 inspections, 18 were regulatory routine or re-inspections to identify food safety risks, 8 were inspections to re-open the establishment after closure/license suspension, and 3 were educational compliance assistance-specific site visits. Of the 18 regulatory inspections, 6 resulted in a “Pass” rating, 4 in a “Reinspection required” rating, while 8 have resulted in a “Closure” rating, meaning that unsanitary conditions resulting in a closure due to imminent health hazards. A total of 197 Food Code violations were observed, an average of 10.94 per inspection, and 163 of the 197 violations were repeat violations, which are violations that the facility had already been instructed to correct on prior inspections. Most of these violations fall within five major risk factors that national epidemiological outbreak data repeatedly identify as contributing to foodborne illness, which includes:
• Improper holding temperatures, such as not keeping food hot or cold enough,
• Inadequate cooking, such as undercooking raw poultry,
• Contaminated equipment, such as not properly sanitizing dishes and equipment,
• Food from unsafe sources, such as prepared at a private home, and
• Poor personal hygiene, such as improper handwashing or working with open wounds.
Review of the inspection reports details that most of the repeated violations found are “Priority items” or “Priority Foundation items.” The Food Code defines a “Priority item” as a Food Code provision whose application contributes directly to the elimination, prevention or reduction to an acceptable level, hazards associated with foodborne illness or injury and there is no other provision that more directly controls the hazard. A “Priority Foundation item” is defined a Food Code provision whose application supports, facilitates or enables one or more Priority items. <https://drive.google.com/file/d/1kEtv4f6YciFXXzLEu6amUc9Anu9uWGYn/view> at page 40 of 186.
ACPH emphasizes education as the primary means of achieving compliance. Routine inspections and reinspections are used to identify food safety risks, inform operators of those risks, and provide instruction on corrective actions necessary to protect public health. In addition, ACPH has offered voluntary compliance-assistance inspections to provide further education and support in correcting risky operational practices. When educational efforts and compliance interventions fail to achieve sustained compliance with the Regulations, the Act authorizes ACPH to pursue enforcement actions necessary to protect public health and mitigate ongoing risks associated with facility operations.
To date, ACPH has issued two civil penalties (Exhibits EE and FF) to Shakhruz LLC, both arising from repeated inspections that resulted in ratings of "Reinspection Required" or "Closed." ACPH has also suspended (and therefore closed) the Retail Food Establishment License on 8 occasions since March 2025. All 8 of those suspensions (closures) were due to high inspection points that indicated an imminent health hazard, and in 2 of those occasions (Exhibits Y and AA), suspension was also justified as punitive enforcement actions for the establishment having multiple non-passing consecutive inspections.
Despite these enforcement actions, as well as the education and compliance assistance provided by ACPH during every inspection, Tandoori Deli Halal has failed to demonstrate sustained compliance with applicable food safety requirements. The facility has continued to engage in operational practices that pose a risk to public health, despite repeated opportunities to correct violations and achieve compliance. Tandoori Deli Halal also acted willfully and deliberately by operating without a valid Retail Food Establishment License after having had their license suspended for operating with an imminent health hazard. Tandoori Deli Halal was instructed, on multiple occasions, to remain closed after their license was suspended pending written approval to open from this Department, and was found open and operating without a valid license. This willful and deliberate act resulted in the Public Health Order (Exhibit GG) to be issued, requiring the establishment to remain closed until a hearing could take place before the Board of Health.
Fiscal Impact: N/A
Staff Recommendation: Based on the documented history of numerous, persistent, and pervasive severe food safety violations, ACPH staff recommends that the Board of Health revoke the Retail Food Establishment License issued to Tandoori Deli Halal, owned and operated by Shakhruz LLC.