Happy National Food Safety Month! Did you know that there’s a FDA Food Code supplement that came out in 2024, requiring restaurants in states that adopt it to document a food safety management system?

That’s right, on Nov. 4, 2024, the FDA released a Supplement to the 2022 Food Code, which permits a state or county regulatory authority to require food establishments to develop a written Food Safety Management System (FSM System) within four years. The FSM System must include written procedures, training plans, and monitoring mechanisms. It must be implemented continuously, and documentation must be made available to regulatory inspectors upon request.

Hal King, Ph.D.“This will affect all foodservice — restaurants, retail with prepared foods, buffets, cafes, catering, schools — everyone will fall into this regulation over time,” says Hal King, Ph.D., managing partner of Active Food Safety, a food safety consultancy. “The design of facilities is likely going to change as a result of this new supplement. Now everyone will really need to focus on the flow of food for food safety — and how a facility design enables a food safety management system. I also expect plan review processes of a facility design to change based on this new requirement.”

The Retail Food Safety Regulatory Association Collaborative notes 10 states have adopted the most recent food code from 2022. King, however, expects this to grow. “Some restaurant chains with national presence won’t wait for states to adopt the code, they’re making changes now to their operations and facility designs to be prepared nationwide,” he says.

The growing popularity of online ordering will only lead to more changes in design to promote food safety. “Digital transformation has changed our industry, and kitchens are doing a whole lot more than they were designed to do,” King says. “We have to think about food safety differently, too, in both new projects and in redesigns.”

For example, digital ordering can lead an operation to have accommodate more meals than its design intended. “Capacity hasn’t grown, but volume has. When this happens risk rises unless the flow of food and separation zoning accommodate it,” King says. “Many chains create a separate make line just for digital food prep orders so they can manage that capacity safely.”

Here’s a look at the five critical areas that often come when taking a zoned approach to food safety design.

Handwashing Zones

“Washing hands and proper glove use are the two most critical parts of preventing cross-contamination,” King says. “Hand sinks should be zoned with the flow of food. You don’t put it by the back door and hope people walk to it — you put it where the transition happens from raw to ready-to-eat food prep.” This is especially important if the same person is preparing raw meat or poultry and then prepping and serving cooked food, which is more common these days as labor shortages continue.

King recommends placing hand sinks next to every workstation, at kitchen entries and exits and between raw and ready-to-eat prep areas. He also encourages the use of stainless-steel splash guards when sinks sit near food prep areas, ice or beverage zones.

Job aid signage can play an important role in promoting food safe practices in these zones. “You want to treat job aids like road signs,” King says. “Put the right sign at the right place in the flow — what to do at receiving, at the cook line, at the hand sink — not just one sign that says, employees must always wash hands, and that’s it.” Rather, more detailed signs that say things like “employees must wash hands when finishing preparing raw food” or “no raw food in this space” help reinforce proper food safety practices.

Dishwashing Zones

The dish room represents another big risk area for foodborne illness outbreaks and food safety breakdowns, King says. “What I see most is no designed storage for dirty and clean dishware — that’s a huge cross-contamination risk,” he says. “There needs to be ample room to segregate dirty dishware, then store clean, sanitized items that are properly dried — and, if space allows, a designated drying area so dishware isn’t stacked when still wet or gets too close to the flow of dirty dishes.

“If dish flow isn’t well designed, people will stack dishware on the ground or grab a container used to hold raw chicken and do a ‘quick dip’ in the sink and then use it to hold prepared chicken salad or salads when they’re rushed,” King continues. “Good dish room design doesn’t just consider plates and utensils but also containers used to store and hold food that will serve hundreds of customers.”

Cold Storage Zones

“It’s best to separate raw and ready-to-eat products in separate coolers or freezers or at the very least, on clearly segregated sides or shelves, with raw always below ready-to-eat food,” King says.

King also recommends designing racking and sightlines for easy date labels and “use-first” access, even making space for donation items so they don’t reenter production. “This reduces cross-contamination risk and supports rotation, lowering both hazards and waste,” he says.

Hot-Holding Zones

“Holding — not cooking — is where we see a lot of outbreaks,” King says. “Equipment choice and how it’s used in that facility are critical. Temperature control also has to be built into the footprint of a design.”

King recommends allocating enough space and power for blast chillers and rapid-cooling processes, and he recommends keeping hot-holding near service and away from raw food prep areas. Also consider investing in space and equipment for dedicated reheating, rather than using the same equipment for raw cooking and reheating food.

Food safety design and use is not limited to the back of the house. It also applies at the point of service. “People think a cold well is holding at 41 degrees F but if pans are overfilled or warm food is added to the cold food during service and sit eight hours, it’s not really holding temp,” King says. “Equipment design and proper use matter too.”

Fortunately, King says he’s seeing a lot more thoughtful equipment design where there might be a cooling element from the top down or max lines indicating where to stop filling product in a holding unit.

Pest Control Zones

Good food safety design means building in ways to keep pests out, as well as ample surveillance. “Don’t design drop ceilings without proofing — that’s where rodents nest, and then they’ll come down from there to look for food in the kitchen.”

What’s more, King says, “Traps need to be where rodents actually travel, not just thrown around on the floor. And cleanability matters — if floors and areas are greasy, they’ll eat that, not your bait.” Placing equipment on castors, elevating and protecting wiring and ensuring proper drainage makes it easier for staff to clean floors on a daily basis.