With the Centers for Disease Control (CDC) estimating that there are approximately ten million cases of foodborne illnesses in the United States each year, the guidance of the U.S. Drug and Food Administration’s (FDA) Food Code is more important than ever.
The FDA Food Code is updated every four years and provides retail and foodservice establishments with best practices to ensure food safety.1 In the interim, a Supplement to the current Food Code comes out every two years to provide the industry with necessary edits and updates. Most local, state, and tribal regulators use the FDA Food Code as a model for developing or updating their own rules.
The FDA published the Supplement to the 2022 Food Code in November 2024. As of March 2025, the 2022 Food Code and the Supplement are the most updated guidance.
With the release of the latest Supplement, some important changes have been made to the 2022 FDA Food Code. It’s crucial to familiarize yourself with these updates to stay informed about the most current food safety science and prepare to adhere to any regulatory changes headed your way.
Read on to review some of the major updates found in the FDA’s Supplement to the 2022 Food Code.
Which version of the FDA Food Code is most up-to-date?
What are the most important changes to the 2022 FDA Food Code?
How do these updates impact my establishment?
Which version of the FDA Food Code is most up-to-date?
The 2022 FDA Food Code, combined with the 2024 Supplement, is now the most up-to-date version of the federal government’s food safety guidance.
The FDA Food Code is considered a model rather than a set of legal requirements, meaning the FDA recommends that state and local jurisdictions follow the most updated version, but ultimately, local authorities are not mandated to update their regulations with each edition of the federal Food Code.
For example, Pennsylvania uses the 2022 FDA Food Code, but Kansas uses the 2017 FDA Food Code as a model for the Kansas Food Code that went into effect in 2023.2
What are the most important changes to the 2022 FDA Food Code from the Supplement?
Throughout the Supplement, the FDA introduced several key revisions and updates related to food safety. Since the changes are spread across three chapters, we have organized a summary of each chapter’s updates for you to easily reference.3
Chapter One: Purpose and Definitions
In the Supplement to the 2022 FDA Food Code, the FDA added many new terms to chapter one, including three directly related to food safety.
|
Newly Defined Terms |
|
|---|---|
|
Active Managerial Control |
The purposeful incorporation of specific actions or procedures by industry management into the operation of their business to attain control over foodborne illness risk factors. *This definition identifies a preventive rather than reactive approach to food safety through a continuous system of monitoring and verification. |
|
Food Defense |
The effort to protect food from acts of intentional adulteration or tampering.4 |
|
Food Safety Management System |
A specific set of actions taken to prevent the occurrence of foodborne illness risk factors based on the type of operation, type of food preparation, and foods prepared within the food establishment. *These actions include written procedures, training plans, and monitoring records to control specific operational steps in a food establishment contributing to foodborne illness. |
Chapter Two: Management and Personnel
The FDA introduced new duties related to a person in charge (PIC), or the person present at a food establishment who is responsible for the operation at the time of an inspection.1
|
Section |
Section Details |
Additional Information |
|---|---|---|
|
Section 2-102.11 |
Outlines how the PIC will “demonstrate knowledge.” Subparagraph (C) 18 adds food defense as a required area of knowledge for PICs. |
Subparagraph (C) 18 notes that the PIC shall demonstrate knowledge by: “Explaining the steps taken to prevent intentional adulteration by consumers, employees, or other persons including monitoring operations, ingredients, supplies, and finished products for unusual or suspicious activities, or other food defense activities.” *Adulteration here refers to the deliberate alteration of food quality.5 |
|
Section 2-103.11 |
Outlines the duties of the PIC. This subparagraph was amended to include the term active managerial control. |
The amendment made to this section reads as follows: “The PIC shall maintain active managerial control of foodborne illness risk factors by ensuring that…” This amendment implies that the PIC is expected to be able to demonstrate a more preventive approach, rather than a reactive approach, when it comes to food safety and their responsibilities. |
|
Section 2-103.22 |
Outlines the duties of the PIC. Subparagraph R adds an additional responsibility for the PIC to ensure staff are trained in food defense practices. |
Subparagraph R reads as follows: “(R) Employees are aware of food defense, such as signs of intentional acts of adulteration as it relates to their assigned duties, and report suspicious activities to the PIC.” |
Chapter Eight: Compliance and Enforcement
In the Supplement, the FDA added an entirely new section to chapter eight of the 2022 FDA Food Code regarding what is required of a food safety management system.
|
Additions to Chapter Eight: Section 8-201.15 |
|
|---|---|
|
It is up to each “regulatory authority” (i.e., state or county) to adopt this provision. When or if they do, food establishments will have four years to develop a written food safety management system. |
A food safety management system should include written procedures and policies that ensure compliance with requirements in Section 2-103.11 (i.e., duties of the PIC). |
|
This section applies to all food establishments except those deemed by the regulatory authority to “pose minimal risk” of causing or contributing to foodborne illness. |
The food safety management system must be implemented during all hours of operation, and the written procedures must be made available to the regulatory authority upon request. |
How do these updates impact my establishment?
Whether or not the updates the FDA introduced in the Supplement to the 2022 FDA Food Code will impact you and your establishment depends on which version of the Food Code your state or territory follows.
As mentioned, some states have adopted older versions of the Food Code, while others adhere to the current version. For example, Florida, Texas, and North Dakota use the 2017 Food Code, while Colorado, Puerto Rico, and Pennsylvania use the 2022 Food Code. If your local health department is holding you to the standards of the 2022 Food Code, updates from the Supplement may impact you sooner than later. You should check your local and state health departments for information about any upcoming regulation changes.
Even if you are not required to update your processes to stay compliant, it is important to be aware of changes to food safety science so you are prepared to make informed decisions about how to train your team, choose your suppliers, and adjust your internal processes.
You can always check your state or territory’s Food Code adoption status with the FDA’s guide if you’re unsure how these new updates may apply to your establishment.6
Updated recommendations improve food safety for everyone
With the U.S. Department of Agriculture’s (USDA) Economic Research Service estimating that foodborne illnesses cost Americans $75 billion each year, improvements to our food safety standards and practices are essential. The FDA encourages state, local, tribal, and territorial regulators to adopt the current guidance outlined in the 2022 FDA Food Code and its Supplement. Whatever role you play in the food industry, familiarizing yourself with the updates made to the FDA Food Code can only help improve your food safety practices, your establishment, and the food industry as a whole.
Sources:
- FDA: 2022 FDA Food Code
- Pennsylvania Department of Agriculture: Food Code Supplement Notice
- FDA: Supplement to the 2022 Food Code
- FDA: Food Defense
- National Library of Medicine: Mechanisms and Health Aspects of Food Adulteration: A Comprehensive Review
- FDA: Adoption of the FDA Food Code by State and Territorial Agencies Responsible for the Oversight of Restaurants and/or Retail Food Stores
