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
- "ME Refilling Returnables Policy 2021, Page 2, Section II "Variance"" (1) (2021)
- "Plymouth MA Mitigating Use of Plastics 2019, Page 1, Bullet 2" (2) (2019)
- "CA Bring Your Own Container Act vendor fact sheet 2019, Page 1 "rent"" (3) (2019)
- "Philly Zero Waste Guide Food Establishments 2021, Page 4" (4) (2021)
- "WA State Retail Food Code, 2022, page 38, Section 03348, (2b)" (5) (2022)
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 |
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 |
heather@zerowastewashington.org |