Food truck HACCP plan

Does a food truck need a HACCP plan?

The FDA Food Code doesn't treat mobile units differently on HACCP: you need a plan when you need a variance (curing, smoking as preservation, acidified rice, ROP outside §3-502.12) or when you do ROP, cook-chill or sous vide under §3-502.12. In practice, many local health departments require mobile food units to submit a plan of operation that looks a lot like a simplified HACCP plan: menu, flow, where each item is prepped, how temperatures are controlled. A structured HACCP draft answers those questions too.

What does a food truck process flow look like?

1. Receive at the commissary (cold TCS food at 41°F or below)
2. Cold storage at the commissary
3. Prep and par-cook at the commissary
4. Cool at the commissary (CCP)
5. Transport in coolers or refrigerated units at 41°F or below
6. Cold holding on the truck (CCP)
7. Cook or reheat to order (CCP)
8. Hot holding (CCP)
9. Serve; discard or return leftovers to the commissary under temperature control

Which CCPs matter most on a truck?

Cold holding (§3-501.16(A)(2)). 41°F or below. Small reach-ins on trucks struggle on hot days and when the door opens constantly. Monitor at least every 2 to 4 hours during service and at opening. Corrective action: move food to a working unit or ice; discard food above 41°F for an unknown or excessive time.

Cooking (§3-401.11). 165°F for poultry, 155°F for 17 seconds for burgers and other ground meat, 145°F for 15 seconds for steaks, pork chops and fish. Monitor each batch or a set number of items per hour.

Hot holding (§3-501.16(A)(1)). 135°F or above. Steam wells and chafers on generators can drop when power fluctuates. Check every 2 hours at minimum; food below 135°F for less than 2 hours can be reheated to 165°F; otherwise discard (a common industry corrective action: the Food Code leaves corrective actions to your plan).

Reheating (§3-403.11). Food cooked and cooled at the commissary must reach 165°F for 15 seconds within 2 hours before going into hot holding.

Cooling (§3-501.14). 135°F to 70°F within 2 hours, and to 41°F within 6 hours total. Use shallow pans, ice baths and a blast chiller if the commissary has one, and keep a cooling log.

What about water, power and handwashing?

These aren't CCPs, but they are the prerequisites inspectors check first. Your plan should say how you supply potable water, keep the handwashing sink stocked and usable, dispose of wastewater, and what you do if power or water fails: usually stop serving TCS food until it's restored.

Which records should a food truck keep?

Keep a temperature log on the truck for cold and hot holding, a cooling log at the commissary, a receiving log, and a cleaning and sanitising log. Bring the last few weeks of logs with you: inspectors often check them during field inspections. The free temperature log works on a clipboard in the cab.

How do I build a food truck plan?

Choose "Food truck" as the business type in the builder, then select cook-to-order, hot holding, cold holding and cook-chill as needed. The draft will include the commissary steps and the limits above.