HACCP Plan for a Ghost Kitchen: Delivery, Packaging and Shared Space

A HACCP plan for a ghost kitchen starts with the same core as any restaurant plan: cook food to the right temperature, cool it properly, hold it hot or cold. What changes is the end of the process. In a delivery-only kitchen, food does not go to a table. It goes into a container, onto a shelf, into a driver's bag, and across town. The plan has to follow it as far as you control it.

This guide is written for US ghost kitchens, virtual brands running out of an existing restaurant, and shared commissary kitchens that host several operators. It covers when a plan is required, the delivery-specific hazards, packaging and labeling, allergen control across brands, and the records to keep. What you write is a draft for your health department to review, since local rules for delivery-only kitchens vary.

Are ghost kitchens regulated like restaurants?

Generally, yes. A ghost kitchen that prepares food for sale to consumers is a food establishment under the FDA Food Code 2022, as adopted by your state. The same rules on cooking temperatures, cooling, holding, date marking and employee health apply. There is no separate federal code for delivery-only kitchens.

What differs is how the kitchen is set up and permitted. Some cities license each brand separately. Some license the physical kitchen once. Shared commissaries sometimes hold one permit and require each tenant to have their own. Ask your health department how they treat your setup before you write the plan, because it affects who signs what.

A written HACCP plan is required under the model code only for specific special processes and variances (sections 3-502.11, 3-502.12 and 8-201.13). If your ghost kitchen does sous vide, cures meat, uses reduced oxygen packaging, or acidifies rice, those sections apply. If not, a plan may be optional, but it is still the clearest way to show how you keep delivery food safe. See when a HACCP plan is required.

What makes ghost kitchens different

Food leaves your control

In a dine-in restaurant, food goes from the pass to the guest in a minute or two. In delivery, it can be 20 to 60 minutes before someone eats it. You cannot put a thermometer in a driver's bag, but you can control what happens until handoff and choose packaging that holds temperature.

Pickup shelf waiting time

Orders are often ready before the driver arrives. That shelf is a holding step. If food sits there long enough, it drifts out of temperature.

Several brands, one line

One kitchen may run five menus. The same chicken might be in a wrap for one brand and a bowl for another. Ingredient lists and allergen information can get out of sync.

Shared space

In a commissary, several operators share walk-ins, dish areas and sometimes equipment. Cross-contamination and storage mix-ups between tenants are real risks.

High volume, fast pace

Delivery peaks are intense. Rushed staff skip checks. The plan needs monitoring that fits into a busy shift.

Flow diagram for a ghost kitchen order

Cold items follow a shorter path: prep, cold hold, assemble, package, cold shelf or refrigerator, handoff. Draw both, and walk them during a real dinner rush to make sure they match. See HACCP flow diagram examples.

Hazard analysis for delivery-only kitchens

| Step | Hazard | Significant? | Control | |---|---|---|---| | Cook | Pathogens surviving in meat, poultry, eggs | Yes | CCP 1, Food Code cooking limits | | Batch cooling of components | Spore-former growth | Yes | Two-stage cooling, if you cook ahead | | Hot holding components | Growth below 135°F | Yes | CCP 2 | | Cold holding components | Growth above 41°F | Yes | Cold holding checks, prerequisite or CCP | | Assembly | Cross-contact with allergens | Yes | Allergen program, labels | | Pickup shelf | Temperature drift over time | Yes | CCP 3, time limit | | Handoff | Tampering | Low to moderate | Tamper-evident seals | | Shared storage | Cross-contamination between tenants | Yes, prerequisite | Labeled, segregated storage |

The CDC's food safety guidance on keeping hot food hot and cold food cold applies directly to delivery: the danger zone between 40°F and 140°F is where bacteria grow fastest. For more on how to reason through each step, see hazard analysis examples.

Critical control points

CCP 1: Cooking

Use the Food Code cooking minimums from section 3-401.11: 165°F for poultry, 155°F for 17 seconds for ground meats, 145°F for 15 seconds for whole-muscle meat, fish and eggs for immediate service. Probe the thickest part. During rushes, many kitchens probe the first item in each batch and every batch after equipment changes.

CCP 2: Hot and cold holding of components

Most ghost kitchens cook components ahead (rice, proteins, sauces) and assemble to order. Those components sit in steam wells or cold rails. Hot holding is 135°F or above, cold holding is 41°F or below (3-501.16). Check product temperatures every 2 to 4 hours as your plan sets and log them. A restaurant temperature log works well here.

If you cook ahead and cool, add cooling as a CCP with the 135 to 70 in 2 hours and 41 in 6 hours total rule. See food cooling rules.

CCP 3: Pickup shelf time limit

This is the step most specific to ghost kitchens. The Food Code does not set a delivery shelf time, so you set one in your plan. Two common approaches:

Approach A: Treat the shelf as hot or cold holding. Use a heated pickup cabinet at 135°F or above for hot orders, and a refrigerated shelf for cold ones. Monitor the cabinet temperature and log it.

Approach B: Treat it as a short internal time limit. Set a maximum time an order may wait on an unheated shelf, and remake or discard orders that exceed it. Print the ready time on the order label so the expediter can see it. This is not the same as the 4-hour time as a public health control rule in 3-501.19, which needs written procedures and covers a much longer window. An internal limit is usually far shorter and is mostly about quality, but writing it into the plan shows you thought about the hazard.

Pick one, write it down, and train staff on it. If your health department has an opinion, theirs wins.

A sample CCP summary for a ghost kitchen

Here is how the CCP table might look for a delivery-only kitchen running a chicken bowl brand and a burger brand from one line. Treat it as a pattern, not a finished plan.

| CCP | Step | Critical limit | Monitoring | Corrective action | Record | |---|---|---|---|---|---| | 1 | Cook chicken thighs | 165°F instant (3-401.11) | Probe thickest piece, each batch | Continue cooking | Cook log | | 1 | Cook burgers | 155°F for 17 s (3-401.11) | Probe one patty per grill load | Continue cooking | Cook log | | 2 | Hot hold rice and chicken | 135°F or above (3-501.16) | Probe every 2 h | Reheat to 165°F if under 2 h known, else discard | Holding log | | 2 | Cold hold toppings | 41°F or below (3-501.16) | Probe every 2 h | Chill if under 2 h known, else discard | Holding log | | 3 | Pickup cabinet | Cabinet at 135°F or above, or internal shelf time limit | Check per shift, ready time on label | Remake orders past limit | Shelf log |

Keep the summary near the line. The full procedures can live in a binder or a shared folder, but the numbers people act on should be posted where they work.

Menu choices that make delivery safer

Some decisions at the menu stage make the plan easier to follow:

• Separate hot and cold components. A bowl with hot rice and cold salsa in the same container warms the salsa and cools the rice. Pack cold toppings in a separate cup.
• Choose dishes that hold well. Braises, rice bowls and grain salads keep temperature better than thin fried items in vented boxes.
• Avoid raw or undercooked items for delivery unless you can handle the consumer advisory on every platform where the item appears. The Food Code requires a consumer advisory for raw or undercooked animal foods, and on delivery apps the wording must still reach the customer.
• Limit cook-ahead items. Every component you cook and cool in advance adds a cooling CCP. Cooking to order where volume allows keeps the plan simpler.
• Keep allergens out of shared sauces where you can. A sesame dressing used across three brands puts sesame on three menus.

Working with third-party delivery platforms

You cannot control the driver, but you can control the handoff:

• Hand orders over sealed, labeled and with hot and cold separated.
• Do not let drivers into prep areas. A pickup window or shelf near the door keeps people who are not employees away from food.
• Keep the pickup area clean and sanitized; it is a food area even if food is packaged.
• If drivers are consistently late at certain hours, adjust when you fire orders rather than letting food wait.

Some platforms let you set prep times or hold orders until a driver is close. Use those settings to cut shelf time. Write the setting you use into the plan so new managers keep it.

Packaging and tamper evidence

Packaging is a prerequisite program in most ghost kitchen plans, but it does affect safety.

• Vented containers for fried food avoid soggy texture but lose heat faster. Balance quality and temperature.
• Insulated bags help, and some kitchens supply their own sealed bags for third-party drivers.
• Separate hot and cold items in different bags so cold salads do not warm up beside hot entrées.
• Tamper-evident seals on bags show the customer that nothing was opened in transit. Some cities require them for delivery; check local rules.
• Food-contact packaging must be safe for the food and temperature. Use packaging sold for food contact.

Labeling and allergens across brands

Allergen mistakes are a serious risk when one kitchen runs several brands. FDA's food allergies page lists the nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame.

Ways to control it:

• One master recipe and ingredient list per component, shared across all brands. Brand menus pull from it.
• Allergen information on the delivery platform that matches the master list. When a recipe changes, update every brand that uses it.
• Allergy request flags on tickets printed in a way the line cannot miss.
• Clean tools and fresh gloves for allergy orders. Some kitchens use a separate color of container lid for allergy orders.
• Supplier changes trigger a review. A new brand of sauce can bring a new allergen.

Our food allergen control plan covers the full program.

Shared commissary kitchens

If you rent space in a commissary, write down:

• Which storage areas are yours and how they are labeled.
• How you separate raw meats from ready-to-eat food in shared walk-ins.
• Who cleans shared equipment and when, and how you check it before use.
• How you handle another tenant's spill or pest issue that affects your space.
• Who is responsible for each log.

If the commissary operator has its own food safety program, reference it and keep a copy. Your plan still needs to cover your own processes.

Cleaning and sanitizing on a fast line

Ghost kitchens run hard during peaks, and cleaning slips. Build cleaning into the shift:

• Sanitizer buckets at each station at the concentration on the label, checked with test strips and logged.
• Food-contact surfaces cleaned and sanitized at least every 4 hours during continuous use, as the Food Code generally requires for many surfaces, or more often if they are used for different foods.
• Dedicated cutting boards for raw proteins.

See our sanitation SOP guide.

Receiving and storage in a busy delivery kitchen

High-volume kitchens receive often and store tightly. Check TCS deliveries at the door: cold items at 41°F or below, with the Food Code exceptions for milk and shellstock received at 45°F and cooled, and hot items at 135°F or above. Reject anything out of range and note it. Store raw meats below ready-to-eat food, poultry on the lowest shelf. Our receiving temperature log guide has a ready layout.

Employee health and hygiene

High volume often means many short shifts and part-time staff. Have every new hire acknowledge the employee health policy, which requires reporting certain symptoms and illnesses. Handwashing for at least 20 seconds, gloves for ready-to-eat food, and no bare-hand contact apply as in any restaurant. A certified food protection manager is required by the Food Code (2-102.12) for most establishments.

Records for a ghost kitchen

| Record | Frequency | Owner | |---|---|---| | Cooking temperatures | Each batch or per plan | Line cook | | Hot and cold holding | Every 2 to 4 hours | Shift lead | | Cooling log | Each batch cooled | Prep cook | | Pickup cabinet temperature or shelf time checks | Each shift, or per plan | Expediter | | Sanitizer concentration | Each new bucket | Line cook | | Allergen recipe updates | Each change | Manager | | Thermometer calibration | Weekly or per plan | Shift lead | | Corrective actions | When needed | Person on duty |

Download printable logs from free logs.

Corrective actions

• Cooking temperature low: keep cooking.
• Hot holding below 135°F: check time. Reheat to 165°F if your plan allows it and the time is known to be short, otherwise discard.
• Cold holding above 41°F: check time, discard if unknown.
• Order past the shelf limit: remake and discard the old order.
• Allergen error found before handoff: remake the order, find the cause.
• Allergen error found after delivery: contact the customer, document, review the master list. If someone reports a reaction, follow your incident procedure and your local reporting rules.

See HACCP corrective actions examples for more.

Verification

• Weekly log review by a manager.
• Test a delivery: order from your own kitchen, measure temperature at arrival, and record it. This gives real data on how your packaging performs.
• Review the plan when you add a brand, a menu item with a new process, or new packaging.
• Review after customer complaints about temperature or quality, which can be early signs of a holding problem.

HACCP verification and record keeping explains a monthly review routine.

Writing your HACCP plan for a ghost kitchen

Put it together in this order:

1. Description of the kitchen, brands, delivery partners and service hours.
2. Process list: cook and serve, cook and hold, cook and cool, cold prep.
3. Flow diagrams for each process, including the pickup shelf.
4. Hazard analysis tables.
5. CCP table with limits, monitoring, corrective actions and records.
6. Prerequisite programs: packaging, allergens, shared space, cleaning, health and hygiene.
7. Record forms and training sign-off.

The HACCP plan template gives you the structure, and the HACCP plan for restaurants guide covers the core that every kitchen shares.

Training for delivery-focused teams

Delivery staff turn over often, so training should be short, visual and repeated. Post the pickup shelf limit at the shelf. Post holding temperatures at the steam table. Show new cooks the allergen flag on a ticket and what to do with it. Keep a sign-off record for each person. Our HACCP training post has a simple format.

Build your ghost kitchen plan

The HACCP builder covers cooking, cooling, reheating, hot holding, cold holding and time control, with Food Code limits and section numbers filled in. You can add each brand's menu items under the processes they use and print the logs your team will fill in. The first process is free; the Plan Pack covers all processes for a one-time price. Like every plan, it is a draft for your health department to review and approve.

Frequently asked questions

Do ghost kitchens need a HACCP plan?

Ghost kitchens are licensed food establishments, so the same rules apply as for restaurants. Under the FDA Food Code, a written HACCP plan is required for certain special processes and variances, not for every kitchen. Some local health departments ask for one for delivery-only operations.

How long can delivery food sit before pickup?

The Food Code does not set a delivery-specific limit. Hot food must stay at 135°F or above and cold food at 41°F or below, or be held under time as a public health control. Many ghost kitchens set a short internal limit for the pickup shelf and remake orders that exceed it.

Who is responsible for food safety during delivery?

The ghost kitchen controls the food until handoff. Third-party drivers control the delivery leg, but you choose the packaging and the hold times that give the food the best chance. Your local rules may say more; ask your health department.

How do I handle allergens across several virtual brands?

Keep one master ingredient list per recipe, shared across brands, and print allergen information from that list. Train staff that the same item may appear under different names on different brands.