FDA FSMA Compliance for Food Trucks
Food trucks occupy an interesting regulatory middle ground under FSMA. Many food trucks are classified as 'retail food establishments' and fall primarily under state and local health department jurisdiction — not FDA's preventive controls rule. However, food trucks that also manufacture or process foods for wholesale distribution must comply with FDA's full FSMA requirements.
Regulatory Authority: 21 CFR Part 1.227 (retail food establishment exemption); 21 CFR Part 117 if non-exempt
Penalty Range: State penalties vary; FDA: warning letters, mandatory recall; civil penalties up to $500/day
Penalty Range: State penalties vary; FDA: warning letters, mandatory recall; civil penalties up to $500/day
Key FDA/FSMA Requirements for Food Trucks
- Determine regulatory status: retail food establishment (state-regulated) vs. food facility (FDA-regulated)
- State/local health department permits and regular inspections
- If FDA-regulated: written Food Safety Plan with hazard analysis and preventive controls
- Safe food handling: proper temperature logs, handwashing stations, sanitizer testing
- Allergen disclosure on menu for top 9 allergens
- Supplier records for high-risk ingredients (under Food Traceability Rule)
Common Violations & Pitfalls
- Operating without current health department permit
- Improper temperature control during service (hot food below 140°F, cold above 41°F)
- No handwashing station or inadequate water supply
- Missing allergen information on menu items
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