By Addie Zuniga, EHS2
An important duty of the person-in-charge (PIC) is to ensure the integrity and proper sourcing of food products received. This includes reviewing invoices, examining packaging, and verifying proper internal temperatures of Time-Temperature Control for Safety (TCS) foods as it comes into the facility. It’s the duty of the PIC to make sure packages are examined at the time of receipt, in order to reject any items that may appear damaged or tampered with, or TCS foods that are outside the safe temperature range. But what about key drop deliveries?
Many food distributers run overnight routes, and this allows facilities the option of overnight deliveries. This is known as a “key drop delivery” – when food deliveries are dropped off in a kitchen, often inside a walk-in cooler, while the business is closed. This can be a convenient set-up, but how would the PIC maintain active managerial control over these deliveries when employees may not arrive at the facility for several hours after the truck has left? The PIC must designate someone to look for damaged packaging or recalled products upon arrival, allowing those to be set aside for return and not served. However, temperature abuse can be hard to identify, especially if the TCS foods have already been in a walk-in cooler for a long period of time since delivery. For example, there would be no way for the PIC to know if the refrigeration in the delivery truck had failed and that the TCS foods were transported for several hours in the temperature danger zone overnight, thereby posing a significant food safety risk. Therefore, it is not enough that a PIC simply verify internal temperatures of TCS foods when they arrive at the facility after a key drop delivery.
If a facility is considering key drop delivery, they must establish procedures with the distribution company, that the delivery drivers would be required to follow. There should be a written agreement in which the drivers are tasked with verifying and documenting the internal temperatures of a sample of TCS foods at the time of delivery, for the PIC to review. This is most often achieved by the driver noting the temperatures of various items on the invoice which is then left behind with the delivery. These procedures may vary, but they should be detailed in the agreement. The PIC should maintain the right to reject these products, even after the driver has left, if they are not satisfied with documented temperatures or other conditions. This policy provides the PIC with the information they need to maintain managerial control over these products, and to know that they are safe for service.
This contract and procedure between the facility and the distributor must be approved by the health authority prior to key drop deliveries being implemented. The PIC should also keep a copy of the signed contract, as well as a recent sample of documented delivery temperatures, onsite for review during each health inspection. This documentation indicates to the health inspector that the PIC is maintaining active managerial control, and that foods are arriving safely and from approved sources. If you are interested in key drop deliveries, please review the Key Drop Deliveries guidance document produced by Georgia Department of Public Health and our website for additional information.