An offsite caterer is a caterer that prepares food in a kitchen off-site and then brings it to the service location. They serve food at a location other than the permitted location for a contracted food service event. It can also mean a business that is routinely contracted to provide food items for sale to members of another business.

The FDA does not directly regulate caterers in the United States. However, the FDA published the FDA Food Code that provides every food jurisdiction a sound technical and legal basis for regulating the retail, food service, and vending segments of the food industry.

Note that this code serves as a reference document for the state, city, county, and tribal agencies that regulate restaurants, retail food stores, vending operations, and food service operations in institutions such as schools, hospitals, nursing homes, and child care centers.

In recent times, local, state, tribal, and federal regulators have been leveraging the FDA Food Code as a model to put together or update their own food safety rules, and to be consistent with the national food safety regulatory policy.

FDA Requirement for an Offsite Caterer in 2020

Just like it was noted above, caterers in the United States are not regulated by the FDA. However, they still stipulate requirements that are necessary to ensure key health objectives are met.

These major objectives, which are the major focus of FDA regulations, include reducing infections caused by food-borne pathogens, reducing outbreaks of food-borne illnesses, improving food employee behaviors and food preparation practices that directly relate to food-borne illness in retail food establishments. Here are FDA Requirements for an Offsite Caterer.

1. Hair Net Requirement

According to the FDA Food Code, all food handlers are expected to wear effective hair restraints that cover all exposed body hair. Note that hair restraints like hair nets, baseball caps, or hats are acceptable to wear. The primary aim is to use a hair covering that will hold any dislodged hair in place so it doesn’t fall into food or onto equipment. Hair restraints also help keep you from touching your hair and contaminating your hands.

Have it in mind there are numerous types of hairnets and baseball caps that can be used. If you decide to use a disposable hairnet, then remember to throw it away once you are done or if it has a hole in it. If you have any questions about acceptable hair restraints, check with your local health department.

2. Food Temperature

According to the FDA Food Code, hot foods will have to be held at 140°F or warmer. On the buffet table, caterers are advised to keep hot foods hot with chafing dishes, slow cookers, and warming trays. Cold foods should be held at 40°F or colder.

Ensure to keep foods cold by nesting dishes in bowls of ice. Otherwise, you can use small serving trays and replace them with cold foods from the refrigerator when more food is required. Every food transport equipment is expected to be NSF compliant, and capable of maintaining required temperatures (41°F±2° for cold foods/135°F±2° for hot foods) and providing protection from contamination.

In addition, food that will be served immediately can be reheated to any temperature as long as the food was cooked and cooled properly. Have it in mind that food reheated for hot-holding will have to reach an internal temperature of 165℉ within two hours. The food needs to stay at this temperature for at least 15 seconds before serving.

3. Temp Control

Foods that grow bacteria easily are at higher risk and are referred to by the FDA Food Code as “Time/Temperature Control for Safety food” or “TCS food” – (formerly called “potentially hazardous food” (PHF)).

Note that the temperature danger zone is between 41℉ and 135℉—a temperature range in which pathogens grow well. Harmful microorganisms can grow to levels high enough to cause illness within four hours. According to the FDA Food Code, here are temp control requirements for food handlers.

  • Cold foods must be maintained at 41℉ or less.
  • Hot food must be maintained at 135℉ or above.
  • Be sure to check the temperature at least every four hours.
  • Checking the temperature every two hours would be ideal to leave time for corrective action.
  • Throw out food that is not 41ºF or lower, or 135ºF or higher.

4. Food Storage

Have it in mind that food is expected to be protected from contamination by being stored in a clean, dry location; a place where it is not exposed to splash, dust, or other contamination; and is at least 15 cm (6 inches) above the floor. Also, note that food in packages and working containers may be stored less than 15 cm (6 inches) above the floor on case lot handling equipment.

Pressurized beverage containers, cased food in waterproof containers such as bottles or cans, and milk containers in plastic crates are allowed to be stored on a floor that is clean and not exposed to floors moisture. However, food may not be stored:

  • In locker rooms;
  • In toilet rooms;
  • In dressing rooms;
  • In garbage rooms;
  • In mechanical rooms;
  • Under sewer lines that are not shielded to intercept potential drips;
  • Under leaking water lines, including leaking automatic fire sprinkler heads, or underlines on which water has condensed;
  • Under open stairwells; or
  • Under other sources of contamination.

5. Water Hose

Note that a water hose used for conveying drinking water from a water tank shall be:

  • Safe
  • Durable, corrosion-resistant, and nonabsorbent;
  • Resistant to pitting, chipping, crazing, scratching, scoring, distortion, and decomposition;
  • Finished with a smooth interior surface; and
  • Explicitly and durably identified as to its use if not permanently attached.

6. Transportation

Every food transport equipment will have to be NSF compliant or equivalent, and capable of maintaining required temperatures and providing protection from contamination. Any vehicle used for transportation will have to be constructed, equipped, and maintained in a manner that protects food, equipment, utensils, tableware, and linen from contamination. The transportation vehicle is expected to be designed so that:

  • The food can be packed in a manner that prevents excessive shifting within the vehicle.
  • The food can be strategically loaded to minimize heat exchange between hot and cold food.
  • The food can be properly stored and segregated to protect it from any source of contamination.
  • Direct transport equipment need not be powered, but if hot and/or cold holding equipment is provided by the caterer for use at the site of the banquet, the equipment must operate under power. Powered holding equipment is required if there is more than a 30-minute delay between arrival and service. An on-site hot-holding box using jellied petroleum fuels is expected to be designed for such use.

7. Administrative Requirements

Catering from a permitted catering food establishment to an event location will only warrant a permit. Caterers running a remote service site are expected to have additional permits for each remote service site. All foods provided for individual sale over the counter, including but not limited to sandwiches, cookies, bagels, or donuts will have to be individually wrapped in food-grade material or placed in an approved food container.

If sold at a remote self-service counter, all packaged food is expected to be labeled as specified in Chapter 3-602.11 of the food regulations. Although permitted restaurants are not expected to obtain a separate catering permit, they will have to notify their health department that they provide that service.

8. Hand Washing Stations

Caterers are expected to provide a self-contained hand washing station or the venue needs to have a permanently plumbed handwashing station with hot and cold water service under pressure.

A self-contained hand washing station is necessary to be third-party, sanitation-certified with ANSI/NSF standards, and be of commercial design, offering pressurized service of separate hot and cold water and is expected to be able to carry at least 5 gallons of potable water, 2.5 gallons of hot water, and 7.5 gallons of wastewater.

The handwashing sink will also have to be provided with dispenser-fed soap and paper towels and have a waste receptacle for paper towel waste.

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