For several years, food delivery (beyond the traditional pizza) has grown in unprecedented ways. Consumers have embraced the new options, but regulatory authorities and even some food industry entities haven’t always kept up with these innovations. From meal kit delivery to e-commerce websites to third-party food delivery services like Grubhub and Uber Eats, it’s become apparent that there are gaps in best practices and regulatory guidance in this area.

But where to begin? How to identify the most pressing challenges? What do these growing business models need? When I spoke with Jorge Hernandez, vice president, quality assurance, for Wendy’s, who had served on the Global Food Safety Initiative (GFSI)’s Local Working Group on e-commerce food safety in 2019, at the GFSI meeting in February 2020, he mentioned that a Conference for Food Protection (CFP) Direct to Consumer Delivery Committee had been assembled in 2018 and had recently published a document on just this topic: “Guidance Document for Direct-to-Consumer and Third-Party Delivery Service Food Delivery.”

If companies are to successfully transition to more food delivery options, especially in a postpandemic world, it will be essential to demonstrate their commitment to food safety. What follows are some practical tips to help you navigate this growing area, based on the guidance document (found in full at www.foodprotect.org/issues/packets/2020Packet/issues/III_004.html), the result of the hard work of many individuals who came together to provide their expertise in this challenging sector.

Challenges for Public Health
This document provides food safety best practices for managing or performing direct-to-consumer (DTC) or third-party delivery (TPD) services. It includes factors necessary for preventive controls, means to assess risk, validation and verification procedures, recommendations for packaging, temperature control, storage, physical and chemical contamination control, and suggestions for return of compromised and abused products. The intent of the guidance was to provide best practices for the prevention of biological, physical, and chemical contamination as well as the growth of harmful bacteria and/or formation of toxins within the food being transported.

How Can I Comply with Regulatory Requirements?
Familiarize yourself even more with the federal, state, and local regulations relevant to the transportation and delivery of food. For example, state, territorial, and local regulations modeled after the U.S. Food and Drug Administration (FDA) Model Food Code require retail food establishments to follow practices that prevent food from becoming adulterated or unsafe. Are you trying to keep hot foods hot or cold foods cold? The answer may depend on whether you hail from a retail establishment or are a meal-kit delivery service (cold), or you are a foodservice establishment that does its own delivery or depends on one of myriad third-party services out there (hot). The regulations for temperature control include establishing the maximum temperature at which TCS (time/temperature control for safety) foods must be held during storage and display. For most TCS foods, the Food Code establishes a maximum cold-holding temperature of 5 °C (41 °F) to limit the growth of pathogenic bacteria during storage and display. For TCS foods prepared for hot holding, the Food Code establishes a minimum storage and display temperature of 57 °C (135 °F). Other temperature limits may be appropriate for foods that do not require TCS but that are kept cold to preserve quality and limit the growth of spoilage organisms.
 
While retail food establishments are generally governed by local regulations, food processing and manufacturing companies are also subject to a variety of food safety authorities, depending on the nature of their operations. For example, food facilities that are required to register with FDA must generally comply with Food Safety Modernization Act (FSMA) rules. DTC food companies subject to FSMA are required to implement a food safety plan that addresses hazards and risk-based preventive controls for minimizing or preventing those hazards. But if you are subject to U.S. Department of Agriculture (USDA)’s jurisdiction and are shipping USDA-regulated food products, you need to be aware of how to do so safely (Table 1[1]).
   
Who Takes the Lead in Risk Management?
DTC or TPD models can be complex and often involve several parties in the production and distribution chain. To ensure that food is delivered safely to the end consumer, you should work together to identify when food safety risks are reasonably likely to arise, what measures are needed to control those risks, and who is responsible for implementing those measures.

If your business is involved in DTC and TPD, you should manage your risks using a Hazard Analysis and Critical Control Points (HACCP)-based approach that accounts for storage; packaging; labeling; preparation; physical retail sale; transport and delivery by employees, independent contractors, third parties, or others; and consumer communication. The approach should reflect food safety parameters and controls for risks that may arise throughout the DTC or TPD processes.

While you may determine that existing approaches, such as a HACCP or food safety plan under the FSMA Preventive Controls rule, are adequate to control risk, you may just as well determine that you need to adopt new protocols for implementing the risk-control measures agreed upon by you and your delivery partners. Regardless, all involved should clearly communicate the necessary risk-control measures and agree upon who will implement each.

How Do I Determine Whether All Our Steps Are in Order?
Validation data for DTC or TPD foods should be obtained both before launch and any time an essential component of the delivery model is modified, such as when the delivery area is expanded or packaging is changed. Deliveries should not begin until the validation demonstrates that identified risks will be adequately controlled and deliveries do not exceed the validation parameters. Upon identification of cold chain gaps or if previous validation records are no longer available, you should perform a revalidation as soon as possible.

Temperature controls may be the most important element in DTC or TPD to validate, but other food safety measures must also be validated. Identify any other food safety risks that should be controlled and determine the appropriate measures for controlling such risks.

Verification activities may include implementing and reviewing logs or checklists to ensure that validated food safety measures are implemented as required or conducting periodic internal or external audits of your food safety program. When verification shows that risk-control measures are not being adequately carried out, corrective actions should be identified and implemented. Corrective actions will vary and should be tailored to the identified deviation; examples include conducting additional training, revising existing procedures, or developing new protocols. You and your partners should establish clear responsibilities for identifying and implementing corrective actions.

How Can We Maintain Temperature Control during Delivery?
Maintaining food at proper temperatures is critical to limiting the growth of pathogenic bacteria or the formation of microbial toxins in food. Thus, proper temperature control throughout production and delivery should be an integral part of any DTC delivery operation. You need to identify the required time and temperature parameters, validate and implement controls to meet these parameters, and verify that these controls are working effectively.

You should identify the temperature requirements throughout transport and delivery based on regulatory requirements as well as on the company’s evaluation of its products, including their unique characteristics and uses. For example, if you sell and deliver a variety of food types, you may require that perishable refrigerated products and ready-to-eat, hot-held foods are consistent with the standards specified in the Food Code. You would then conduct validation activities to identify measures that will adequately maintain required temperatures and control the microbiological risks posed by the product during all stages of production, transport, and delivery.

Temperature requirements can be met using a combination of different controls at various stages of your operation. These controls can include limiting the maximum delivery time, using appropriate types and amounts of refrigerants or coolants, and requiring a specific initial product temperature. These controls can interact to affect temperature, and it is critical that they be validated.

In conducting validation activities, you need to account for all possible variables that may compromise temperature control. With respect to transportation and delivery, for example, you may choose to conduct same-day or overnight delivery and can control the longest possible delivery time. If you find that you have less control over delivery times, you should account for this variability. Validation studies should also take into consideration the type of food, the organism(s) of concern, and the growth limit targeted. It is essential to validate contingency measures for emergency situations that may compromise temperature control, such as power outages, refrigeration equipment breakdowns, or delivery-route disruptions. Examples of potential approaches for verifying temperature controls include testing temperature profiles and packaging configurations in a simulation chamber and conducting periodic shipment tests using data loggers and trained participants in various geographical areas. One recommended best practice is to simulate worst-case scenarios and show that product temperatures are lower than the targeted temperature at the end of the longest possible time-to-receipt by the final customer. A worst-case scenario should be based on the farthest, warmest locations to which food is shipped, accounting for historical temperature data and depending on where the food originates.

How Can We Prevent Contamination?
Preventing cross-contamination is a key aspect of food safety whether these are biological, physical, or chemical contamination risks. Individual components of a delivery need to be packaged so cross-contamination does not occur during transport. The outer container of the delivery must be able to maintain integrity during transport. Sealing may be used to prevent intentional adulteration. Items being delivered need to be transported in a clean and sanitary manner and transported so the food product does not become contaminated.

Any materials used for wrapping and packaging should not be a source of contamination. These materials should be stored so they do not become contaminated. Any packaging operations should be carried out in a manner where contamination of the food is prevented. Where prepackaged foods are delivered to the consumer, integrity of the container’s construction should be ensured. When raw meats are present in a package, appropriate measures should be taken to prevent leakage and cross-contamination to other foods or packaging materials.

Proper packing also serves to prevent chemical and physical contamination of foods. Your delivery partners should be aware of the chemical and physical risks posed by delivering nonfood items together with food items. Food delivery companies should be aware that allergens constitute a chemical hazard to be managed. You should provide a mechanism for the consumer to identify any food allergies during ordering. Care should be taken to ensure unpackaged food items do not come into contact with any potential allergen sources prior to, during, or after packaging the food items for delivery. Such instructions for proper segregation should be directly communicated (by training and in writing) to your delivery partners.

Consumer Communication
As mentioned in Table 1, you should identify the food safety information that should be included within a package and/or in other communication channels, including on a product website or via email. This may include product information as well as consumer instructions for communicating feedback and concerns. If food safety labeling is included on the outside of a package, you should ensure it is not obscured, including by any labels a third-party carrier may affix to the package.

Products for delivery should be labeled according to applicable regulatory requirements. All partners should work together to ensure all relevant food safety information provided at the point of sale, including on product websites or mobile applications where orders may be placed, is accurately communicated.

Sourcing challenges may also require changes to the allergen information required for a product, so you should ensure suppliers have processes in place to communicate updated allergen information to consumers when needed.
Product information may also include instructions for safe use, such as information about any raw product or raw ingredients that may pose a health risk and are intended to be consumed raw (e.g., raw milk cheeses or sushi-grade fish). Companies may also choose to provide consumers with guidance on safe food storage, handling, and preparation.

Best Practices for Managing a DTC Delivery Food Safety Program
As a critical component of a food safety program, a comprehensive monitoring system helps verify food safety policies and systems are being applied consistently and sustainably, and identifies continuous improvements or corrective actions.

In designing a monitoring approach, you should consider the following:

•    Which validated food safety measures should be monitored

•    Where monitoring will occur, whether in production, transportation, and/or upon delivery

•    How monitoring will be conducted for each food safety measure

•    How the monitoring system will be described and communicated

•    How often each monitoring tactic will be implemented

•    Who will be responsible for conducting monitoring

•    How deviations will be addressed

•    How monitoring results will be recorded

•    What consumer inquiries and complaints have been received

A monitoring system should be based on the validated measures that you have determined are needed to control its food safety risks. Each validated risk-control measure should be evaluated to determine the best approach for monitoring, considering the type of data to be gathered, how the data will be used, how frequently the control measure should be evaluated, who should gather and/or interpret data, which key performance indicators should be used, and how monitoring results should be reported.

Once a system is in place to monitor the key components of a food safety program, you should establish processes to address noncompliance and improve risk management. These processes should include expectations for communicating nonconformances and performance metrics. For example, including an escalation process to relay nonconformances to the appropriate individuals and departments can help ensure issues are addressed promptly. You should ensure qualified individuals have the authority to take corrective actions.

As part of your efforts toward continuous improvement, you should also continually research the most current food safety innovations and technologies in the manufacturing and retail food industries. Remaining up to date on industry trends can help an organization become aware of the best available food safety tools to be more efficient, respond faster to alerts, take corrective actions, and adjust food safety procedures.

When developing corrective and preventive control plans, you should consider the following:

•    Engaging stakeholders (e.g., representatives from food manufacturer/food establishment, product delivery/transportation company, or external auditing firm)

•    Establishing requirements for communicating nonconformances, including timing protocols based on potential risk

•    Determining what parties must be notified and level of escalation based on risk

•    Identifying who is responsible for implementing the plan

•    Monitoring corrective and preventive actions to ensure they are effectively implemented

•    Incorporating root-cause analyses to assist with corrective actions and adjustment of protocols as needed

•    Conducting targeted training for personnel to identify and correct errors in the food safety management program

•    Using accountability models (e.g., number of higher-risk occurrences triggering escalation)

•    Reassessing studies or procedures to determine whether improvements are needed to resolve operational or behavior-related occurrences

Additional Considerations for TPD Guidance
While much of the guidance for DTC applies to TPD, there are additional challenges that must be met. All parties engaging in TPD should understand the relevant food safety risks and define roles for such parties to help minimize those risks. The parties to the business agreement should clearly identify the responsible party during each stage of the flow of food, from preparation to staging to delivery.

How Do I Select a Delivery Partner?
First, do your homework. Not all delivery services are created equal. Unilever has posted great tips for how to navigate this process:

1. Pick partners with the right delivery processes
Food delivery companies seem to work in the same way—a customer places an order, and their rider goes to pick it up and deliver it. But there’s much more. Find out how their delivery riders handle the orders. How is the food kept? What’s the maximum delivery duration? Does the company have an efficient delivery tracking system?

2. Ensure high food packaging integrity
No matter the weather, delivering food can be a challenge, affecting the quality and food safety of your delivered meals. Use practical, quality food packaging such as thicker, biodegradable materials that can hold moist food well for a longer period. Most importantly, ensure that your food delivery company uses insulated bags to keep your food warm and fresh during delivery.

3. Use long-lasting ingredients to avoid spoilage
Consider having a line of dishes created especially for delivery. You can also use better quality, long-lasting ingredients and ready-to-use, stable sauces to prepare your already-popular meals for delivery.

4. Run inspections for consistent, optimal food safety
The last thing any food operator wants is to deliver spoiled or tainted foods that may harm customers or create a PR disaster. Hire staff dedicated to perform quality checks or train your existing team in a certified food handling course to ensure food safety standards are met.

5. Make the use of sanitizers, gloves, and hairnets compulsory
Keeping the kitchen clean is the first step toward maintaining good food safety. Small practices like using hand sanitizers, gloves, and hairnets can go a long way. You can also place signs in the restroom to remind employees to wash their hands with soap after each visit. These are all cheap and easy ways to protect your food from being contaminated before delivery (see “Food Delivery PPE”).

The choice of a delivery partner depends on a range of factors, including the size and weight of packages, availability of service, general reliability, historic performance, and commercial viability. Specialized delivery services utilizing refrigerated transport may be appropriate. Since some carriers may not deliver 7 days a week, some companies may choose to ship only certain days of the week to ensure timely delivery.

Some TPD services offer the option of signature release (i.e., requiring a signature for delivery). This has the advantage of ensuring someone is immediately available to receive and refrigerate the food upon receipt. It presents the challenge of delaying delivery if a signatory is not available.

A nondelivery may occur if the carrier cannot find the delivery address, for example. Any process for nondeliveries should be agreed to by the carrier. Some carriers may have specific requirements regarding packaging and labeling related to nondeliveries.

It is prudent to check out the websites and corporate communications from those services you are considering. This step can be very enlightening. For example, when querying whether a specific TPD service is responsible for the food safety of its delivered products, the following results were obtained:

1.    Only a lawyer would be able to decipher Grubhub’s response. Someone wanting to deliver for this service would not be able to figure out what, if anything, they were supposed to do to ensure the safety of the delivered food from the restaurant to the customer.[2]

2.    Both Uber Eats and DoorDash had easy-to-read and -follow steps for what delivery personnel should do to ensure food safety. Uber Eats recommends an insulated bag but also states that it’s not required unless mandated by law. It also discourages tampering with the food.[3]

3.    DoorDash was the most comprehensive of the three, actually providing a list under the heading “What are DoorDash’s food safety handling requirements?”[4] Even so, more can be done. Stipulate what you need these services to do and offer to help train their employees. After all, they are delivering your food. If a customer gets sick, will they blame the driver or you?

What Are the Basic Requirements for TPD?
Preventing Contamination
Preventing contamination is a key aspect of food safety. Food establishments and food shoppers should minimize contamination risks by determining which items will be segregated and how items should be packaged. An added challenge in TPD is that various food and nonperishable food products may be delivered together. Best practices are to (a) separate ready-to-eat foods from raw proteins, (b) separate chemicals and nonfood products from food products, and (c) separate glass and other fragile food products to reduce breakage risks. Separation options may include separate bags or the use of another barrier.

You should have processes to determine whether food deliverers may prepare beverages, collect accompanying utensils, napkins, or condiments, or package foods.

Time/Temperature Control
Temperature control should be considered when delivering food to the consumer through a TPD service. However, time as a public health control is also acceptable for limiting pathogenic bacterial growth. A wide variety of transportation vehicles are used to provide delivery services. A refrigerated or freezer vehicle may be ideal in maintaining temperature control. If the transport vehicle does not have a mechanism to control the ambient temperature of the vehicle, food deliverers should address all relevant food safety concerns and hazards when transporting the food. Food deliverer procedures may include the use of insulated delivery bags, containers, or coolers, or use of coolants to keep foods hot or cold.

For foodservice establishments using food ordering platforms, you should issue guidelines to your delivery services to deliver orders safely and in accordance with relevant safety standards, and to follow any food establishment delivery guidelines that are meant to promote food safety and compliance with applicable regulations.

You should hold foods in a staging area at proper product temperatures prior to pick-up and delivery by the TPD service. A temperature-monitoring process for staging foods may be needed to ensure food is maintained at the proper temperature until ready for pickup and delivery to the consumer.

Packaging
Packaging protects and separates products from contamination, the external environment, and physical damage. Packaging design and using multiple layers of packaging, including primary, secondary, and tertiary, minimize the risks associated with contaminants and food safety hazards. Primary and secondary packaging, such as foil wraps, direct food contact containers, and plastic bags, directly protects the food. Tertiary packaging or outer packaging, such as delivery bags or coolers, provides protection from the external environment, including extreme temperatures, direct sunlight, weather, road debris, and animals and pests.

You should not reuse primary and secondary packaging. The tertiary or outer packaging should be constructed of durable and easily cleanable materials for reuse to transport food during deliveries. The U.S. Environmental Protection Agency has created a guide for foodservice on reducing food waste and packaging that you may wish to consult.[5]

Work with your TPD services to determine correct storage (e.g., upright) and amount of food to be packaged during transportation to avoid crushing of food or damage to primary food containers that could potentially contaminate other food or lead to unclean delivery bags.

Food Tampering
Prevention of food tampering activities occurs through packaging design and tamper-evident devices. You may utilize primary packaging that cannot be resealed, such as tear strips, and secondary packaging, such as bags or boxes, with tamper-evident tape, stickers, or seals to deter food tampering activities during food delivery and maintain food safety and integrity.

TPD services should not remove food products from the secondary or tertiary packaging until delivered to the consumer. Food deliverers and food shoppers should not open, alter, tamper with, or change the primary or secondary packaging.

Delivery Bag Usage, Maintenance, and Cleanliness
Food deliverers may use insulated delivery bags that help minimize food temperature fluctuations and/or help maintain food temperatures during delivery to the consumer. In addition to insulated delivery bags, food deliverers can add other refrigerants or coolants, such as ice and/or gel packs, that may help reduce the rise in product temperatures during extended delivery times.

Delivery durations, ambient temperatures and conditions, and intended food temperatures at delivery may help food deliverers identify the need to use insulated delivery bags. Delivery bags can be designed and manufactured to support a variety of business needs. The materials, construction, and design of the bag can be customized to maintain food hot or cold and can be designed with pouches to separate cold food from hot food.

Some TPD entities offer personal shopping services in addition to delivery services. Food shoppers might also utilize bags during selection and packing of products and should ensure bags are clean and in good repair.

Vehicle Cleanliness and Inspections
A variety of vehicles or transportation methods (e.g., walkers, cars, motorcycles, bicycles, autonomous vehicles, or drones) may be used to transport food, depending upon the delivery location and accessibility. Vehicles should be clean and free from odors, pests, animals, and any other materials that could adversely impact food safety. Food deliverers should inspect vehicles frequently to ensure that interiors are clean and free from debris. Food ordering platforms should provide food deliverers with information on maintaining their vehicles in safe conditions, such as vehicle cleanliness and maintenance.

Recall Preparedness
Work with your TPD services to (a) provide trace-forward information to track where recalled product was delivered to (e.g., consumer information) and (b) provide traceback information to track where recalled product originated from (e.g., distributor, supplier, manufacturer, farm).

Best practices for DTC food delivery companies and TPD services (e.g., food ordering platforms and retail food establishments) are to have processes related to trace-forward and traceback actions developed and to have appropriate records to manage potential recalls.

Summary
We’ve come a long way from simple pizza delivery. Consumers can order everything from shelf-stable ingredients to perishable produce and meat and poultry to prepared meals and meal kits. Food orders can be placed online, via a website or mobile app. How we move forward to ensure the safety of the food supply chain is for all partners to work together and take ownership of each step from the farm to the consumer. A good place to start is with guidance like that offered by the CFP DTC Delivery Committee that identifies the most pressing challenges and provides sound, science-based tips to migrate industry best practices into this expanding market.   

Barbara VanRenterghem, Ph.D., is the editorial director of Food Safety Magazine.

References
1. www.fsis.usda.gov/wps/portal/fsis/topics/food-safety-education/get-
answers/food-safety-fact-sheets/safe-food-handling/mail-order-food-safety/CT_Index.
2. www.grubhub.com/legal/terms-of-use.
3. www.uber.com/us/en/safety/uber-community-guidelines/food-safety/.
4. help.doordash.com/dashers/s/article/What-are-DoorDash-s-food-safety-handling-requirements?language=en_US.
5. www.epa.gov/sites/production/files/2015-08/documents/reducing_wasted_food_pkg_tool.pdf.

Resources
www.cdc.gov/foodsafety/communication/food-safety-meal-kits.html.
PPE info: Tronex International; tronexcompany.com.