Applies to all US food trucks and mobile food vendors regardless of state
FDA Food Safety Plan for Mobile Food Operations
FDA-compliant food safety plan covering hazard analysis, preventive controls, and sanitation for mobile food preparation with limited workspace and storage.
What this document covers
The FDA Food Safety Modernization Act (FSMA) shifted the focus from responding to contamination to preventing it. Food trucks that manufacture, process, pack, or hold food are subject to the Preventive Controls rule under 21 CFR 117. Your food safety plan must address the unique challenges of mobile operations — limited refrigeration capacity, variable water supply, cross-contamination risk in confined prep areas, and temperature control during transport between commissary and service locations. This plan documents your hazard analysis, preventive controls, supply chain program, recall plan, and monitoring procedures tailored to mobile food service.
Key sections included
- Hazard analysis for mobile food preparation
- Preventive controls (process, allergen, sanitation, supply chain)
- Monitoring procedures for mobile environment
- Corrective actions and corrections
- Verification activities
- Supply chain program for mobile vendors
- Recall plan
- Associated records and documentation
Frequently asked questions
Does FSMA apply to food trucks?
Yes. If your food truck manufactures, processes, packs, or holds food, you are subject to FSMA Preventive Controls under 21 CFR 117. Very small businesses (under $1M average annual sales) have modified requirements but are not exempt.
Is this different from a HACCP plan?
Yes. FSMA Preventive Controls replaced mandatory HACCP for most food facilities (except seafood, juice, and low-acid canned food). Preventive Controls are broader — covering process, allergen, sanitation, and supply chain hazards. However, many food trucks maintain both for thoroughness.
How often must I update my food safety plan?
You must reanalyze your plan at least every three years, or whenever a significant change occurs — such as a new menu item, new supplier, equipment modification, or change in operating locations.
Document details
- Legal basis
- 21 CFR Part 117 (Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls); FDA Food Safety Modernization Act (FSMA), Public Law 111-353
- Enforced by
- U.S. Food and Drug Administration (FDA)
- Penalty for absence
- FDA Warning Letter, import alerts, injunction, or seizure of food products. Civil monetary penalties up to $10,000 per violation per day. Criminal prosecution for repeated or willful violations with fines up to $250,000 and/or imprisonment.
- Category
- Food Safety
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FDA Food Safety Plan for Mobile Food Operations
Legal Reference
21 CFR Part 117 (Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls); FDA Food Safety Modernization Act (FSMA), Public Law 111-353. Enforced by U.S. Food and Drug Administration (FDA).
1. Hazard analysis for mobile food preparation
2. Preventive controls (process, allergen, sanitation, supply chain)
3. Monitoring procedures for mobile environment
4. Corrective actions and corrections
+ 4 more sections...
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