Understanding the Rules of the PA Food Code

Chester County Health Department’s Food Code (modeled after the PA Food Code) has closely paralleled the FDA Food Code for several years. To a food facility operator, it may seem that some of the rules and regulations are random, bureaucratic rules that exist just to exist. Not true. The Food Code is based on research, and evidence-based practice. Understanding the reasoning behind the rules can help motivate food operators to follow the rules and to keep food safe.


So, what is the reasoning behind some of the regulations in CCHD's Food Code? Here are some examples:

EXAMPLE 1

46.922(d)
:  A toilet room located on the premises of a food facility shall be completely enclosed and provided with a tight-fitting and self-closing door.

REASON
Toilet room doors must remain closed except during cleaning operations to prevent insect and rodent entrance and the associated potential for the spread of disease. Flies and rodents that enter a toilet room can carry pathogens back to the food preparation area.

EXAMPLE 2


§46.151(a)
  1. An employee may not eat, drink or use any form of tobacco unless the use occurs in designated areas where the contamination of exposed food; clean equipment, utensils and linens; unwrapped single-service and single-use articles; or other items needing protection cannot result.
  2. Exception for closed beverage containers. A food employee may drink from a closed beverage container if the container is handled to prevent contamination of the following:
    • employee’s hands
    • containers
    • exposed food; clean equipment, utensils and linens; and unwrapped single-service and single-use articles

REASON

Smoking or eating by employees in food preparation areas is prohibited because of the potential for hands, food, and food-contact surfaces to become contaminated by hand to mouth contact. Food preparation areas such as hot grills may have elevated temperatures and the excessive heat in these areas may present a medical risk to the workers as a result of dehydration. Consequently, in these areas food employees are allowed to drink from closed containers that are carefully handled.

EXAMPLE 3

§46.304(b) Cloths used for wiping food spills shall be one of the following:
  1. Dry and used for wiping food spills from tableware and carry-out containers.
  2. Wet and cleaned as specified in § 46.751(b)(4) (relating to requirement and frequency of laundering), stored in a chemical sanitizer at a concentration specified in § 46.674(a) (relating to warewashing equipment: mechanical or manual), and used for wiping spills from food-contact and non-food-contact surfaces of equipment.

REASON

Soiled wiping cloths, especially when moist, can become breeding grounds for pathogens that can potentially be transferred to food. Any wiping cloths that are not dry (except those used once and then laundered) must be stored in sanitizer solution at all times, with the proper sanitizer concentration in the solution. Wiping cloths soiled with food debris can overcome the effectiveness of, and neutralize, the sanitizer. The sanitizing solution must be changed as needed to minimize the accumulation of organic material and sustain proper concentration. Proper sanitizer concentration should be ensured by checking the solution periodically with an appropriate chemical test kit.

EXAMPLE 4 

§46.692(b)(1): Single-service and single-use articles may not be reused.

REASON
Articles that are not constructed of multiuse materials cannot be reused because they are unable to withstand the rigors of multiple uses and repeated washing and sanitizing. This includes plastic utensils, salad or sour cream containers, and pickle buckets. Certain materials allow harmful chemicals to be transferred to the food which could lead to foodborne illness. Also, reused containers and plastic utensils can affect the taste of food. Surfaces that are unable to be routinely cleaned and sanitized because of the materials used could harbor bacteria. Deterioration of surfaces such as pitting may make it difficult to adequately clean, opening the door for potential contamination of food that is prepared on the unclean surface.

Hopefully, understanding the reasons behind some of our regulations will help ensure that these requirements are met by food operators and their employees. As always, if there are any questions regarding the regulations, feel free to contact the Environmental Health Specialist for your establishment.

For a full description, read the Public Health Reasons / Administrative Guidelines