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.
And food safety guidance doesn’t stand still for very long! New pathogens emerge, operational risks evolve, and foodservice environments become more complex each and every year. This is why the U.S. Food and Drug Administration regularly updates the Food Code and releases interim supplements between major editions.
In November 2024, the FDA issued a supplement to the 2022 Food Code that introduced several important updates affecting foodservice operations, employee health protocols, food defense practices, sanitation procedures, and inspection readiness.1
Pay close attention to these changes, as they aren’t merely regulatory fine print. They directly impact your daily operations, staff training, documentation, and risk management. Here’s what changed in the 2024 Supplement, and what you should focus on moving forward.
Which version of the FDA Food Code is most up-to-date?
Key changes in the 2024 FDA Food Code Supplement
Chapter-by-chapter changes to the 2022 FDA Food Code from the Supplement
How do these updates impact my establishment?
The role of the FDA Food Code
The FDA Food Code serves as a model for state, local, tribal, and federal agencies when they’re developing food safety regulations. While adoption varies by jurisdiction, the Food Code heavily influences how food establishments are inspected and evaluated across the country.
The Food Code is built around science-based best practices designed to reduce foodborne illness risks, covering areas like:
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Employee health and hygiene
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Food handling and storage
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Cleaning and sanitation
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Equipment and facility requirements
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Water and plumbing systems
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Inspection and enforcement procedures
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Food safety management systems
The FDA publishes a new Food Code every four years, with supplements issued in between to address emerging risks and clarify existing guidance.
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
Key changes in the 2024 FDA Food Code Supplement
The 2024 Supplement seems relatively brief and simple at first glance, but it includes several updates that carry meaningful operational implications for restaurants and other foodservice establishments:
Greater focus on food defense and intentional adulteration
Traditionally, food safety focuses primarily on accidental contamination. Food defense, however, addresses the intentional contamination or adulteration of food products, with the updated language now requiring the person in charge to demonstrate awareness of the steps that prevent intentional adulteration during inspections.
This includes monitoring supplies and deliveries, ingredients, production areas, finished products, or suspicious activities or unusual behavior. For many operations, this might require additional staff training and stronger operational awareness.
Food defense planning doesn’t necessarily mean implementing complex security systems. In many facilities, it starts with practical operational habits like:
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Restricting access to sensitive storage areas
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Monitoring deliveries carefully
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Verifying vendor relationships
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Training employees to report suspicious activity
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Maintaining tighter inventory controls
Updated guidance for food safety management systems
The supplements also update when a Food Safety Management System (FSMS) may be required.
More than just a written binder sitting on a shelf, an FSMS is a structured operational framework that helps facilities identify hazards, implement controls, monitor compliance, and continuously improve food safety performance.
Facilities with higher-risk processes may need stronger documentation and more formalized systems moving forward, particularly if they use specialized processing methods or serve highly vulnerable populations such as children or the elderly.
Again, this sounds like a shift in verbiage alone, but it aligns with a broader industry trend: regulators expect food safety to function as an active management system instead of a reactive checklist. Relying on verbal training, inconsistent documentation, or informal procedures may cause inspections to become more difficult over time.
Clarification around cleaning, sanitizing, and disinfection
The supplement includes clarifying language regarding the disinfection of food-contact and nonfood-contact surfaces. Many facilities still confuse cleaning, sanitizing and disinfecting, even though they serve different purposes.
As a reminder:
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Cleaning removes visible soil and debris
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Sanitizing reduces pathogens to safe levels
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Disinfecting destroys a broader range of microorganisms
Using the wrong process or using chemicals incorrectly can create compliance problems and safety risks. Therefore, the supplement encourages facilities to review the following on a regular basis (especially important for settings like healthcare or institutional foodservice where infection prevention and food safety often overlap):
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Chemical usage instructions
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Contact times
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Staff training procedures
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Labeling and storage protocols
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Cleaning schedules and documentation
New expectations for thawing oversight
The updated supplement strengthens language around thawing procedures and specifically reinforces the responsibility of the person in charge. As one of the most common food safety mistakes in commercial kitchens, improper thawing can be hazardous, as foods held in the temperature danger zone for too long can quickly become high-risk environments for bacterial growth.
Under the revised guidance, the person in charge must help make sure that food handlers properly maintain temperature and time controls during thawing. This creates additional accountability for operational leadership, not just frontline staff.
As such, facilities should now revisit their thawing procedures for:
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Refrigerated thawing
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Running water thawing
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Microwave thawing
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Thawing as part of the cooking process
More importantly, managers should confirm employees understand not only what procedures to follow, but why those procedures matter.
Expanded restrictions on toxic chemical containers
There are now additional restrictions related to reusing containers that previously held toxic chemicals.
Previously, guidance focused primarily on food storage, but the updated language broadens the prohibition to include the storage of equipment, utensils, linens, single-service items, and single-use articles. It closes potential loopholes and reinforces the importance of chemical safety throughout the facility.
Even containers that appear clean may still pose contamination risks if they originally held hazardous substances. Because of this, facilities should evaluate storage practices carefully, especially in maintenance areas, utility rooms, and back-of-house storage spaces where repurposed containers often appear.
Additional protection from water-based fire systems
Another operationally important update addresses storage near water-based fire protection systems. The supplement now specifies that food, equipment, utensils, linens, and disposable items may not be stored near leaks or condensation from these systems.
While this may sound minor, condensation issues are common in older facilities and can create contamination risks that are easily overlooked during daily operations.
Facilities should assess:
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Ceiling leaks
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Sprinkler condensation
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Moisture accumulation
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Storage placement
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Water intrusion risks
Again, another good reminder that facility maintenance and food safety are deeply connected.
Changes to employee illness reinstatement
The supplement adds culture-independent diagnostic tests (CIDTs_ as an accepted method for reinstating employees diagnosed with certain illnesses, including Shiga toxin-producing E.coli (STEC), Shigella, and nontyphoidal Salmonella.
Employee health policies need to be reviewed to confirm that they align with updated reinstatement guidance and other local regulatory requirements.
Chapter-by-chapter 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.
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Newly Defined Terms |
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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. |
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Food Defense |
The effort to protect food from acts of intentional adulteration or tampering.4 |
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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
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Section |
Section Details |
Additional Information |
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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 |
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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. |
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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.
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Additions to Chapter Eight: Section 8-201.15 |
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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). |
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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
What to do now
The 2024 Supplement presents a great opportunity for facilities to reassess their overall food safety systems, rather than simply updating isolated policies here and there.
Some tips? Do the following:
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Review current SOPs against the updated supplement
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Update employee training materials
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Reinforce active managerial control practices
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Evaluate sanitation and disinfection procedures
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Review thawing and temperature control processes
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Conduct internal mock inspections
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Strengthen food defense awareness
And remember: food safety programs are most effective when they function as part of everyday operations, rather than compliance exercises performed only before inspections are scheduled to take place.
Food safety standards will continue to evolve, largely because foodservice risks keep evolving, too. The operations that adapt successfully are the ones that treat food safety as an ongoing operational discipline, not a once-a-year compliance task.
Need help strengthening your food safety culture? Trust20 offers practical training designed for real-world foodservice environments. If your team is reviewing Food Code updates or preparing for upcoming inspections, explore our products to learn how we can help support safer, stronger operations.
FAQ
What is the FDA Food Code?
The FDA Food Code is a science-based model used by state and local agencies to develop food safety regulations for foodservice operations and retail food establishments.
Is the 2024 supplement a completely new Food Code?
No. The 2024 Supplement updates and clarifies portions of the 2022 FDA Food Code until the next full edition is released.
Do all states automatically adopt FDA Food Code changes?
No. States decide which portions of the FDA Food Code they adopt and when implementation occurs.
What is food defense?
Food defense focuses on protecting food from intentional contamination or adulteration, including deliberate acts that could harm public health.
Why are thawing procedures emphasized in the supplement?
Improper thawing creates significant foodborne illness risk because bacteria can rapidly grow when foods remain in unsafe temperature ranges.
What is a Food Safety Management System?
A Food Safety Management System (FSMS) is a structured operational approach that helps facilities identify food safety hazards, implement controls, monitor compliance, and improve food safety performance over time.
How often is the FDA Food Code updated?
The FDA typically publishes a new Food Code every four years, with interim supplements released as needed.
Sources:
- FDA: Supplement to the 2022 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
