The 2022 Food Code and 2024 Supplement

Understanding Implications for Food Facilities

The 2022 Food Code represents a major update in the ongoing effort to ensure the highest standards of food safety in the United States. As a critical component of food safety regulation, the Food Code provides science-based guidelines to safeguard public health. Since its release, the FDA has issued a 2024 Supplement that incorporates additional updates based on recommendations from the 2023 Biennial Meeting of the Conference for Food Protection. Additionally, in early 2025, the FDA announced a ban on Red Dye No. 3 in food, dietary supplements, and oral medications due to cancer risk concerns. 

This article delves into the key aspects of the 2022 Food Code, its 2024 Supplement, and what these changes mean for food production and manufacturing facilities. 

A Quick History of the Food Code

The FDA first introduced the Food Code in 1993 to consolidate and update various food safety guidelines. Over the years, it has undergone several revisions to reflect new scientific knowledge and address emerging food safety challenges. Each version aims to provide a comprehensive framework for food safety practices that can be uniformly adopted by state, local, tribal, and territorial regulatory agencies. 

Key Updates in the 2022 Food Code and the 2024 Supplement 

The 2022 Food Code introduced several significant updates designed to enhance food safety in production and manufacturing settings. The 2024 Supplement further refined some of these requirements, ensuring that the Food Code remains aligned with industry advancements and public health priorities. 

Major Updates in the 2022 Food Code 

Updated Definitions and Terms 

• Ready-to-Eat Foods: Expanded to include foods requiring minimal preparation before consumption, reflecting current industry practices. 
• Food Establishment: Now includes a wider range of food operations, such as virtual kitchens and food delivery services, to account for evolving business models. 

Enhanced Allergen Control Measures

• Stricter requirements to prevent cross-contact and improve allergen labeling.
• More detailed allergen disclosures, including potential cross-contaminants, to ensure accurate consumer information. 

Strengthened HACCP Protocols 

• Additional Critical Control Points (CCPs) introduced, such as new temperature monitoring requirements for high-risk foods. 
• More frequent verification and validation of HACCP plans to ensure they effectively control identified hazards. 

Updated Sanitation Standards

• More stringent cleaning schedules, including mandatory daily sanitation of all food contact surfaces. 
• Disinfection protocols specifying approved disinfectants and their application methods for pathogen elimination. 

New Changes Introduced in the 2024 Supplement 

Updated Guidance on Date Marking for Time/Temperature Control for Safety (TCS) Foods 

• Clarified requirements to ensure uniform compliance across different food establishments. 

Strengthened Employee Health Guidelines 

• Expanded criteria for employee exclusions due to foodborne illness symptoms, reinforcing workplace health protocols. 

Enhanced Food Donation Guidance 

• New recommendations for food establishments to safely donate surplus food while complying with safety regulations. 

Ban on Red Dye No. 3 (2025 Update) 

In January 2025, the FDA announced a ban on Red Dye No. 3 in foods, dietary supplements, and oral medications due to studies linking it to cancer risk. Manufacturers have until January 2027 to comply by reformulating products that contain this artificial colorant. This decision aligns with growing concerns over food additives and consumer safety. 

The Food Code’s Impact on Food Production Facilities

The 2022 Food Code and its 2024 Supplement introduce significant changes for food production and manufacturing facilities, impacting multiple areas: 

• Manufacturing Processes: Stricter controls over manufacturing to minimize contamination risks, including enhanced monitoring and verification procedures. 
• Facility Design and Maintenance: New sanitation and structural requirements, such as ensuring proper ventilation to prevent bacterial growth and implementing Integrated Pest Management (IPM) programs.
• Employee Training and Hygiene: Increased focus on ongoing training programs to ensure compliance with updated food safety protocols. 
• Supplier Verification and Traceability: Strengthened guidelines to ensure suppliers meet international food safety standards and improve supply chain transparency. 

Challenges and Considerations for Compliance 

While these updates enhance food safety, they also present challenges for businesses: 

• Implementation Costs: Upgrading facilities and processes to meet new standards requires financial investment but can help prevent costly food safety incidents. 
• Training Needs: New training programs must be developed to ensure employees understand updated safety measures and compliance expectations. 
• Compliance Monitoring: Ongoing audits and third-party verification will be essential for facilities to maintain compliance with evolving food safety regulations. 

The 2022 Food Code and its 2024 Supplement, along with the 2025 ban on Red Dye No. 3, represent significant steps forward in strengthening food safety standards. By proactively adapting to these changes, food production facilities can ensure compliance, protect public health, and build consumer trust. As the industry continues to evolve, staying informed and implementing these guidelines will remain critical to maintaining excellence in food safety.