85 12.9: Food Code Operating Procedures for Sewage Backup

12.9 Food Code Operating Procedures for Sewage Backup

A sewage backup in a foodservice operation is considered an imminent health hazard and requires immediate action to protect public health and comply with food code requirements. Below are the essential procedures to follow, based on food safety codes and public health guidance:

Immediate Actions

Cease all food operations and close the facility if there is ongoing sewage overflow or backup until the issue is resolved, and the facility is properly cleaned and disinfected.

Post a “Closed” sign to prevent entry by customers and staff.

Notify the local health department immediately and follow their instructions regarding closure and reopening.

Block off affected areas to prevent tracking of sewage to other parts of the facility.

Assessment and Containment

The person-in-charge must assess the scope of the backup, including which equipment, fixtures, and areas are affected, and the duration of the event.

Stop using any plumbing fixtures (toilets, sinks, dishwashers, etc.) that are not draining or are contributing to the backup.

If all toilets or handwashing sinks are non-functional and no approved alternatives are available, discontinue operation.

Cleanup and Disinfection

• Contact a licensed plumber or remediation service to repair the backup and remove obstructions.
• Thoroughly clean all affected areas with a detergent solution, followed by a disinfectant effective against pathogens such as norovirus.
• Use personal protective equipment (PPE) such as gloves, masks, goggles, and boots during cleanup.
• Discard any food, single-use items, or equipment that may have been contaminated by sewage or cannot be properly cleaned and sanitized.
• Equipment and utensils that have come into contact with sewage must be cleaned, disinfected, and then properly washed, rinsed, and sanitized before reuse.

Alternative Procedures (If Approved by Health Department)

• For handwashing, if sinks are inoperable, use chemically treated towelettes or set up a temporary handwashing station with clean, warm water, soap, and disposable towels, ensuring wastewater is disposed of properly.
• Use alternative restrooms if available and accessible; otherwise, cease operation.
• Use only unaffected equipment and areas for food preparation.

Key SOPs – Sewage Backup Response

Documentation and Reopening

Document all actions taken, including cleaning, disinfection, and disposal activities, for health department review.

After repairs and cleaning, contact the health department for inspection and approval before reopening.

Preparedness

Maintain a contact list for plumbers, remediation services, and the local health department.

Have a written emergency action plan and cleaning/disinfection procedures available for staff.

Following these procedures ensures compliance with food safety regulations and helps protect the health of customers and staff during a sewage backup incident.

12.10 Food Code Operating Procedures for Flooding

Immediate Actions During Flooding

Assess whether the facility can remain open. If any food storage, preparation, or service area is at risk of contamination and cannot be quickly corrected, the establishment must close until it is safe to reopen.

Isolate any small flooded area using barriers to prevent customers and employees from exposure and to stop the spread of contamination.

Notify relevant authorities and professionals:

Contact the city building inspector to assess structural safety.

Call utility companies to ensure gas, electric, and water safety.

If using a well, arrange for testing and disinfection if it has been flooded.

Notify your local health department for guidance on cleanup and reopening.

Food Handling and Disposition

Discard all foods and packaging that have been submerged in floodwaters unless the food is in a hermetically sealed, undamaged metal can or retort pouch.

Discard foods in porous packaging (paper, cardboard, plastic, cellophane), as well as any containers with screw tops, snap lids, pull tops, crimped caps, corks, or twist caps, since these are not waterproof and can be contaminated by floodwaters.

Discard all fresh produce, bulk foods, and exposed ready-to-eat foods that have come into direct contact with floodwaters-they cannot be adequately cleaned and sanitized

Discard refrigerated and frozen foods if power has been off for more than four hours or if they have been immersed in floodwaters.

Inspect canned foods and discard any with swelling, leakage, punctures, holes, fractures, deep rust, or severe dents.

Salvaging Canned Foods

Only undamaged, commercially canned foods and retort pouches that are hermetically sealed can be saved if completely soaked. Remove labels, wash with soap and clean water, rinse in a detergent solution, scrub around lids and seams, soak in unscented bleach solution for 15 minutes, and air dry for one hour before opening. Relabel with a permanent marker including all required information.

Water Safety

Use only water from a safe source for drinking, washing, or food preparation. Bottled water not exposed to floodwaters is preferred.

If bottled water is unavailable, boil water for at least one minute or disinfect with unscented household bleach (1/8 teaspoon per gallon, let stand 30 minutes).

If your well has been flooded, do not use the water until it has been tested and disinfected.

Cleaning and Sanitizing Procedures

Remove all mud, silt, and solids from hard surfaces. Clean with detergent and water, rinse, then disinfect with an approved sanitizer (e.g., 200 ppm ammonium solution or another approved sanitizer).

Discard porous, soft, absorbent, or uncleanable items that have been contaminated.

Wash or discard linens, mops, and apparel used during cleanup.

Ensure pest control by removing pests and sealing openings to prevent future entry.

Employee Safety During Cleanup

Employees involved in cleanup should wear N-95 masks if mold is present, as well as eye protection, rubber boots, gloves, and protective clothing.

Wash hands thoroughly after working in contaminated areas.

Before Reopening

After cleanup and sanitization, contact the local health department for a pre-opening inspection to ensure the facility is safe for operation.

“If in doubt, throw it out.” This applies to any food or packaging that may have been contaminated by floodwaters (FDA).

These procedures are based on FDA, CDC, and local health department guidelines and should be incorporated into emergency operating plans for all food establishments.

SUMMARY

Active managerial control (AMC), HACCP, and crisis management are foundational concepts in food safety systems, each addressing distinct aspects of risk mitigation.

Active Managerial Control (AMC) refers to a proactive, systems-based approach where food establishment managers implement specific procedures to prevent foodborne illness risks. Defined by the FDA Food Code, AMC involves monitoring critical limits (e.g., time/temperature standards) and verifying compliance with sanitation protocols to control hazards like pathogen growth or cross-contamination. It emphasizes continuous oversight rather than reactive corrections, aligning with FDA’s emphasis on preventive measures in retail and food service.

HACCP (Hazard Analysis Critical Control Points) is a USDA-mandated framework for meat, poultry, and egg production, focusing on identifying biological, chemical, or physical hazards and establishing control points to mitigate them. Its seven principles include hazard analysis, critical limit setting, and corrective actions, ensuring systematic risk management at each production stage. For example, cooking temperatures to eliminate pathogens or chilling protocols to inhibit bacterial growth are typical CCPs regulated under USDA guidelines.

Crisis Management involves preparedness and response strategies for emergencies impacting food safety, such as natural disasters or contamination events. The USDA’s Emergency Response Framework outlines coordination with agencies like the FDA and CDC to isolate affected products, deploy laboratory networks, and restore supply chain integrity. Effective plans include predefined roles for crisis teams, communication protocols, and regular drills to maintain operational resilience during disruptions.

Together, these concepts form a layered defense: AMC ensures daily preventive controls, HACCP targets process-specific hazards, and crisis management addresses systemic threats, collectively safeguarding public health across food systems.

Additional Resources:

What is HACCP?

Creating a HACCP Plan

Crisis Management

Business continuity and Recovery

Food Safety Management Introduction