U.S. consumers used a food delivery service over a one-month period, according to a 2023 report from DoorDash (doordash.com). “Meal kit services have grown in tandem with the overall trend toward food delivery and consumption at home,” says Paul Bradley, senior director of product marketing at TraceGains, a supply chain solutions company in Broomfield, Colo.
Social distancing measures initiated during the COVID-19 pandemic accelerated the adoption of meal kit and food delivery services as consumers aimed to reduce their exposure to crowded places such as grocery stores and restaurants. After the pandemic, meal kits remained popular in light of busy lifestyles, a preference for convenience, and a desire for a wide range of recipes that cater to various dietary preferences and restrictions, says Rachel Fogle, PhD, associate professor of biological sciences, program lead for environmental science and sustainability, and director of aquaponics and hydroponics initiatives at Harrisburg University of Science and Technology in Harrisburg, Penn.
Meal kit and food delivery services also offer a convenient solution for many urban dwellers, especially in food deserts, considering transportation constraints and the proximity of grocery stores with healthy, fresh produce, Dr. Fogle says. Smartphones and mobile apps have simplified the process of ordering food and meal kits.
With the popularity of food delivery services and meal kits growing so quickly, however, food safety regulators have given little guidance regarding best practices for direct-to-consumer (DTC) or third-party delivery (TPD) services. In food delivery, this “last mile,” the means by which food is transported from a producer and packager to an actual consumer, presents unique challenges for maintaining food safety.
“Whether food is being carried by a delivery driver or conveyed by a package delivery service or other means, situations can arise in which food can be handled unsafely,” Bradley says. “In particular, concerns exist around perishable food items that must be held within safe temperature ranges, as many delivery methods don’t account for temperature verification and other traditional food safety process controls.”
Regarding meal kits, issues can surface when using non-traditional delivery channels such as mail or package delivery systems, which typically aren’t designed to provide the kinds of checks and controls required by safe food handling guidelines, Bradley says.
Greatest Safety Concerns
Due to limited regulations for DTC and TPD, as well as a lack of understanding of risks posed by these services, concerns have mounted. When food is placed in a box for shipment, it’s no longer under that establishment’s control, and delivery companies such as the U.S. Postal Service, UPS, FedEx, aren’t regulated by food safety agencies, says Donald W. Schaffner, PhD, distinguished professor, extension specialist, and current chair of the department of food science at Rutgers University in New Brunswick, N.J. Even if these companies do guarantee delivery times, they use unrefrigerated vehicles and therefore don’t have the capacity or ability to guarantee delivery temperatures.
Temperature control of perishable goods is a top concern, says Martin Bucknavage, MS, MBA, senior food safety extension specialist in the department of food science at Penn State University in University Park, because it can result in quality issues related to spoilage and contamination by organisms such as Listeria and Staphylococcus aureus, along with the spore-forming pathogens Clostridium botulinum, Clostridium perfringens, and Bacillus cereus.
Temperature abuse becomes problematic when a shipped product doesn’t get to a consumer in a timely fashion, which could occur to a shipment being mailed to the wrong address or a consumer not being present when a product is delivered. Even if coolants are used, in some cases they may not compensate for delivery delays, Bucknavage says.
“There may be sporadic cases of foodborne illnesses from food delivery services due to one-off bad actors, but with meal kit delivery, the possibility of large outbreaks exists,” says Mitzi D. Baum, MSc, CEO of Stop Foodborne Illness in Chicago. “Studies have shown that the ingredients in meal kits don’t always stay at a safe temperature. Harmful bacteria can grow quickly in meats and seafood if left sitting on a porch, and consumers may not realize it. Refrigerated items can only be left out at temperatures above 40°F for a maximum two hours, which includes transport time.”
Tampering with food during the delivery process is another concern, Dr. Schaffner says. The platform-to-consumer delivery method introduces increased opportunities for food tampering and contamination due to additional touchpoints in the delivery process. To address this concern, more restaurants have implemented tamper-evident closures; however, studies show that using tamper-evident seals might send the wrong message to consumers (Int J Hospital Manag. doi: 10.1016/j.ijhm.2022.103315). “When consumers see these seals, it might send a signal raising the possibility that tampering could occur,” he says.
Personal hygiene of the individuals preparing and handling the food, as well as those delivering the food, is another concern. Most states require all restaurant workers to have a food handler’s license; however, delivery companies don’t explicitly state on their websites that any kind of food handling experience or license is required, Baum says.
In fact, some reports have highlighted concerns regarding food safety knowledge and practices among food handlers and delivery workers (PLoS One. 18(10): e0293004). “Proper hygiene practices, including hand washing and sanitization, are essential to mitigate the risk of foodborne illness,” Dr. Fogle says.
Ensuring the cleanliness of delivery vehicles is yet another aspect to address because spills and food residue can cause contamination, Dr. Fogle says. Regular cleaning can reduce this risk.
“Clearly, many companies have mastered the home delivery channel—showing that it can be done safely with great success,” Bucknavage says. “But because of lower barriers to entering the delivered meal space, some providers of home delivery meals can fly under the radar, away from inspection or other oversight. It’s up to regulators to constantly search for these less-than-compliant operations.”
Ignorance can also play a role. Some start-up businesses that have a good meal kit idea simply may not know about state, federal, and local laws and how to meet their standards, says Benjamin Chapman, PhD, department head, professor, and food safety specialist in the department of agricultural and human sciences at North Carolina State University in Raleigh.
“Addressing these concerns mandates collaboration among meal kit companies, food delivery services, regulatory bodies, and consumers to establish and enforce strict standards and protocols for the safe handling, packaging, and delivery of food,” Dr. Fogle says.
Guidance Document Contains Best Practices
Although few regulations regarding DTC and TPD exist, in 2022 a Conference for Food Protection committee drafted a voluntary guidance document on best practices for food safety for these service lines. It includes advice pertaining to preventive controls, mechanisms to assess risk, recommendations for proper packaging, temperature controls, physical and chemical contamination controls, and allergen controls. The document was drafted by the Conference for Food Protection Direct to Consumer Delivery Committee, chaired by Dr. Schaffner. Committee members included representation from grocery stores, restaurants, food processors, delivery companies involved in these new delivery models, consumer and academic representatives, and state and local public health officials. Following is some insight on each practice.
Preventive controls. Food companies that include “last mile delivery,” whether DTC or TPD, should conduct thorough hazard analyses to identify potential food safety hazards at each stage of the delivery process, Dr. Fogle says. Regular verification activities, including inspections, testing, and recordkeeping, are essential to ensure the adequacy and effectiveness of preventive controls. It’s important to establish procedures for taking corrective action in response to deviations from established controls. Proper training of employees and delivery personnel are crucial for ensuring compliance with preventive control regulations and maintaining food safety standards.
Mechanisms to assess risk. Managing food safety risks requires leveraging both internal and external resources. Internal resources include self-assessment, flexibility, and response capabilities, Dr. Fogle says. Regular internal assessments—conducted through daily checklists, shift-based logs, internal reviews, and the use of third-party auditing firms for independent audits—enable companies to proactively identify and mitigate food safety risks.
Third-party auditing firms can conduct independent audits to ensure safe food practices. External experts offer impartiality during assessments, providing unbiased insights and recommendations to improve food safety practices, Dr. Fogle says. These professionals often possess specialized training in inspection techniques and root-cause investigations, facilitating thorough assessments of food safety risks. Additionally, external resources can supplement internal teams by aiding in program design, updating educational materials, and developing standard operating procedures, thereby strengthening overall food safety protocols.
Recommendations for proper packaging. Attention to each layer of packaging—outer packaging, coolant selection, and dunnage—is vital for ensuring food safety and quality during transit and delivery, Dr. Fogle says.
Outer packaging serves as insulation to maintain temperature control and prevent contamination. Companies must ensure its integrity, conduct crush tests, and provide handling instructions. Reusable packaging requires defined collection logistics and proper cleaning procedures.
Coolants, such as ice packs or dry ice, are chosen based on scientific principles and data, considering factors like transit time and temperature fluctuations. Dunnage fills voids, aids insulation, and protects contents during transportation. It shouldn’t insulate food from coolant and must maintain sanitary quality.
Temperature control. Perishable ingredients like meats, dairy, and certain vegetables must be stored at specific temperatures to prevent bacterial growth, Dr. Fogle says. During transportation, inadequate refrigeration or insulation can lead to excessive temperature fluctuation, risking food safety.
According to the guidance document, “A DTC delivery company should identify the temperature requirements throughout transport and delivery based on regulatory requirements as well as the company’s evaluation of its products, including their unique characteristics and uses … a company should account for all possible variables that may compromise temperature control. With respect to transportation and delivery, for example, some businesses conduct same day or overnight delivery and can control the longest possible delivery time (e.g., by restricting delivery ZIP codes). Companies with less control over delivery times should account for this variability.”
Physical and chemical contamination control. Materials used for packaging shouldn’t introduce contamination and should be stored in a way that maintains cleanliness. Measures should prevent leakage and cross-contamination, particularly for packages containing raw meats. Food delivery companies must be cautious when delivering non-food items alongside food items and acknowledge allergens as chemical hazards, Dr. Fogle says.
Allergen control. Providing mechanisms for consumers to identify allergies during ordering is essential. Precautions should ensure that unpackaged food items remain free from potential allergen contact throughout packaging and delivery, Dr. Fogle says. Resources such as the FDA model Food Code offer additional information on allergens and associated risks, including appendices on food allergen labeling and food allergens as food safety hazards.
More to Chew On
Additional guidance on transporting food safely can be found in FDA’s New Era of Smarter Food Safety blueprint, an initiative that focuses on leveraging technology, data analytics, and collaboration across the food industry to enhance food safety practices. This includes addressing challenges specific to meal kit and food delivery services, such as traceability, transportation, supply chain transparency, and real-time monitoring of temperature and sanitation, Dr. Chapman says.
A key component of New Era is FDA’s final rule on requirements for traceability, often referred to as FSMA 204, because it implements section 204(d) of FDA’s Food Safety Modernization Act (FSMA). “The essence of FSMA 204, which becomes effective in 2026, is to enact strong requirements for both forward and backward traceability for certain food items, with a goal of enabling much faster outbreak response if a serious food safety event occurs,” Bradley says.
Alongside existing FDA and USDA guidance on recalls, this regulation establishes an expectation that meal kit and delivery services should maintain a trace-forward capability inclusive of last-mile consumer delivery. “Put simply, the job of meal kit providers doesn’t end when a product is handed off to a carrier or delivery driver, which has meaningful implications for record keeping and process management going forward,” Bradley says. “The industry will have some work to do in order to create the kind of transparent supply network required to meet it.”
Furthermore, the third of four core elements in the New Era blueprint, “New Business Models and Retail Modernization,” focuses on tech-enabled traceability and recognizes an evolution in the way food is produced and delivered to consumers. “FDA seeks to protect foods from contamination amid the expansion of e-commerce and other new business models,” says Sara Bratager, senior food safety and traceability scientist at the Institute of Food Technologists in Chicago.
To achieve this, FDA outlines several key initiatives in the blueprint, such as collaborating with regulatory partners, and educating delivery services and consumers on proper food handling practices, and promoting the adoption of technology to monitor risk factors and drive safe product innovation.
Shortly after the release of the New Era blueprint, FDA held a summit on e-commerce to gain insight into how foods are sold through business-to-consumer e-commerce models in the United States and worldwide. Continued efforts are illustrated through the Core Element 3 web page.
In October 2021, FDA convened an e-commerce summit. “It represented a snapshot of current understanding and best practices,” Dr. Schaffner says. “It’s still a useful resource for companies looking to quickly get up to speed with this area of the food system.”
“FDA is clearly aware of food safety issues with respect to these novel delivery mechanisms,” Dr. Schaffner continues. “But, to a certain extent, its hands are tied because they must operate under the current regulatory structure, which has some gaps with respect to these innovations.”
The Beef Industry Food Safety Council has also established best practices for DTC sales. “It’s recognized that risk is influenced by the type of product being considered and suggests that re-evaluating risk should occur each time a product profile changes,” Dr. Fogle says. “Expectations of packaging and distribution need to consider temperature control, allergens, and traceability.”
Thoughts on Proceeding
Looking ahead, Bratager has identified several areas to focus on to improve the safety of food delivered by DTC and TPD services. Existing regulations for registering food businesses often categorize e-commerce alongside traditional brick-and-mortar retail establishments. “While this classification may be suitable for some businesses, it fails to address the nuances of all e-commerce actors,” she says. “Operations such as meal kit fulfillment centers, which involve more handling and processing akin to manufacturing facilities, may fall through regulatory gaps,” she says.
Additionally, point-of-sale labeling requirements designed for in-store operations don’t adequately address the responsibility of online-to-consumer businesses to provide essential information to consumers at the point of sale, Bratager says. Clarification and guidance are needed to bridge these regulatory gaps and safeguard public health.
Furthermore, current foodborne illness tracking systems largely overlook business to consumer e-commerce categories, which limits the understanding of the risks posed by DTC and TPD services, Bratager says. For instance, the CDC’s National Outbreak Reporting System dashboard includes some restaurant settings but omits crucial categories such as “restaurant delivery” and “online grocery.” “Integrating these significant categories into foodborne illness reporting practices is essential for accurately assessing their risks and informing risk-based regulatory measures,” she concludes.
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