Conference for Food Protection

2023 Biennial Meeting

Issue View | Council I | 2023 Biennial Meeting

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Issue Number: Council I 026

Issue History

This is a brand new Issue.

Title

Add off-site warewashing facilities for multiuse articles to Food Code

Issue you would like the Conference to consider

The language in the Food Code does not provide adequate guidance surrounding off-site cleaning of multiuse utensils, tableware, take-home food containers and take-out beverage containers (multiuse articles). While some jurisdictions approve variances (see supporting attachments) for the use of off-site warewashing facilities for multiuse articles, the Food Code does not explicitly address or allow this, creating a confusing patchwork of regulations amid increasing public concern over single-use articles.

Public Health Significance

While the Conference for Food Protection is currently creating a definition for consumer-owned reusable containers and the appropriate handling of Time/Temperature Control for Safety Foods when sold in reusable containers (Safe Use of Reusable Container Committee (Issue 2020-I-024)), not all consumers will want to bring their own container. Food handling regulations must accommodate the need for off-site warewashing and associated transportation of multiuse articles to reduce waste and excess packaging. Reducing uncertainty in the language of the regulation encourages nonhazardous time/temperature controlled practices that are safe, convenient and sensitive to the beliefs and desires of many consumers.

Updates to the Food Code will have benefits for state regulatory agencies who rely on federal synthesis of these pertinent issues. Significant time and resources can be saved with the adoption of guidance that is clear and uniformly enforceable, removing the need for individual local variances. Consensus on off-site warewashing standards and associated transportation for multiuse articles is critical for agencies and industry, along with public health and environment.

Recommended Solution: The Conference recommends...

that a letter be sent to the FDA requesting Part(s) 3-3, 4-4, 4-6, 4-7, 4-9 and/or Annex 3 (whichever portions FDA deems appropriate) of the most current edition of the Food Code be amended (using applicable language developed by FDA) to clarify how to safely use off-site warewashing facilities for multiuse utensils, tableware, take-home food container and take-out beverage container cleaning.

Supporting Attachments

Submitter Information 1

Name Kelley Dennings
Organization Center for Biological Diversity
Address 1411 K Street NW
Ste 1300
Washington, DC 20005
Telephone 919-355-8102
Email kdennings@biologicaldiversity.org

Submitter Information 2

Name Heather Trim
Organization Zero Waste Washington
Address 816 2nd Ave
Ste 200
Seattle, WA 98104
Telephone 206-441-1791
Email heather@zerowastewashington.org

Word File

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