The coronavirus pandemic that began in 2019 and continues to progress in 2021 has devastated the restaurant and foodservice industry and has changed food industry businesses for years to come. Restaurant and foodservice losses in sales were reported by the National Restaurant Association to have surpassed $185 billion between March and August 2020.¹ One business model to address these losses is the more rapid expansion of off-premises sales. This business model includes the preparation of food for immediate consumption and home meal kits for pickup, delivery, drive-through, curbside, and even packaged food sales. Before the pandemic, off-premises sales were primarily pursued for the convenience of the customer (e.g., delivery) and as a means for a foodservice business to grow sales beyond restaurant visits, with cost being an ever-present limiting factor. However, now, during this pandemic, off-premises sales are driven primarily by public health as well as by a need to recapture lost sales due to in-restaurant dining restrictions.

What Are the Food Safety Considerations?

Two food safety concerns of off-premises sales are the food safety risks associated with food preparation (generally caused by the hazards associated with foods prepared and served to customers for immediate consumption) and the additional risk of keeping the food safe after it has been prepared, including holding (e.g., keeping food hot or cold to prevent growth of pathogens), handling (e.g., preventing tampering with the food), transporting (e.g., preventing contamination of the packaging), and delivering the food to a customer (e.g., ensuring that the customer is not exposed to an infected delivery person). Because customers are ordering from a mobile app or website, they also may be at a higher risk for allergens due to the lack of avoidance messaging that is normally part of the in-restaurant ordering process.

One of the more probable food safety concerns in off-premises sales is from contaminated environmental surfaces that play a critical role in the indirect (secondary) transmission of pathogens. For example, the virus that causes stomach flu, norovirus, can survive on surfaces for many days, with even greater persistence at cold temperatures. Norovirus can be transmitted not just by a food handler during food preparation² but also simply by contamination of items reused to carry foods, including reusable food storage and delivery equipment and bags.³

“One of the more probable food safety concerns in off-premises sales is from contaminated environmental surfaces that play a critical role in the indirect (secondary) transmission of pathogens.”

The Future of Off-Premises Sales—Potential for Continued Growth

A previous study⁴ reported that off-premises formats (e.g., drive-through, takeout, and delivery) already represented 38 percent of total restaurant food and beverage sales prepandemic. At this time, per the National Restaurant Association,⁵ customers were found to be most receptive to consumer-facing technologies such as drive-through enhancements, order accuracy tracking, and frictionless mobile ordering. Key areas of growth were reported to include:

• 92 percent of consumers used drive-through at least once a month.

• 34 percent of consumers utilized delivery more often than a year ago.

• 79 percent of consumers used restaurant delivery (53% use third-party) at least once a month.

In a more recent report compiled in the midst of the pandemic, 66 percent of 1,000 adults surveyed by the National Restaurant Association in November 2020⁶ stated they ordered takeout or delivery for dinner in the last week, 47 percent ordered lunch in the last week, and interestingly, 35 percent ordered a breakfast meal or beverage in the last week (a high since March 2020). When compared with past surveys, the percent of off-premises dining was found to be consistently higher than before the pandemic between March and November 2020. One trend that may sustain off-premises sales when the pandemic is over may be the growth of ghost-kitchen foodservice models (expected to grow by 42% in 2021), where the food is prepared and delivered only for off-premises dining. Although many of these business models are similar to other traditional restaurants that have stopped in-restaurant dining (due to state requirements or business operations safety decisions), ghost kitchens also include mobile (e.g., food trucks) and temporary “kitchen vessels” set up inside shipping containers that can be staffed to prepare and distribute an existing foodservice business’s delivery-only menu.⁶ This model allows a foodservice business to expand delivery sales with lower upfront cost than a traditional restaurant facility.

Regulatory vs. Public Health—Which Is Which?

The U.S. Food and Drug Administration (FDA) Food Code does not specifically address regulations for off-premises sales of food except in the packaging and selling of packaged foods by permitted restaurants and foodservice businesses and by mobile foodservice locations. Thus, there are significant gaps between what the food industry and third-party delivery businesses are doing and what should be more closely regulated. A major safety concern with the transporting and delivery process may be with the third party (normally not a restaurant or foodservice employee) who picks up and delivers the food. Neither FDA nor most states regulate which delivery service can pick up food from a restaurant or foodservice business and deliver that food to a customer. These unregulated third-party delivery services that are not required to work with the restaurant or foodservice business to ensure safety could increase risk by providing incorrect menus and ingredients (allergen-avoidance risk), failing to ensure the quality of the food upon delivery, or not following personal hygiene and safe transport of food guidelines—all of which could also hurt a restaurant’s reputation. Some states are moving forward with regulations before the FDA Food Code is updated. California’s Fair Food Delivery Act, passed in September 2020, requires food delivery platforms to obtain an agreement from restaurants “expressly authorizing” them to take orders and deliver meals. In defending the change, the bill points out that California law already generally requires various businesses that prepare or otherwise provide food to the public to comply with uniform health and sanitation standards.⁷ We can probably expect future updates to the FDA Food Code to address off-premises sales as a recent set of guidelines were recently published by the Conference for Food Protection⁸ and reviewed against best practices that retail foodservice business can use for application.⁹

The FDA’s “New Era of Smarter Food Safety” blueprint¹⁰ recognizes the risk of food safety in new business models like off-premises sales to meet consumers’ and industry’s needs now during the pandemic and in the future (as many third-party delivery services were already growing rapidly) to ensure the safety of food delivered by new business models. Establishment of educational materials for consumers on handling foods delivered to their homes is specifically called out in the proposal. Until more guidance is published in the FDA Food Code, it is recommended that both foodservice and third-party delivery businesses utilize these best practices as they develop their policy and procedures to ensure consumer safety.

“…there are significant gaps between what the food industry and third-party delivery businesses are doing and what should be more closely regulated.”

Best Practices to Ensure the Safety of Off-Premises Sales and Maintain Your Customer Loyalty

1. Ensure safety in the kitchen – Establish active managerial control of all foodborne illness risk factors to ensure prepared foods start their journey to the customer safe.¹¹

2. Ensure safety beyond the kitchen – Ensure your third-party delivery (if not your staff) is approved to sell and deliver your menu and make certain you both follow the guidelines,⁸ which include inspection of the delivery vehicle to ensure cleanliness, ensuring drivers are using proper disinfection protocols, confirming drivers are trained on proper food handling risks (keeping hot foods hot and cold foods cold), and establishing personal hygiene expectations and wellness screens for drivers (not driving and delivering foods while sick with symptoms of coronavirus disease or foodborne illnesses). Operators are also encouraged to order from their menu while at home to see firsthand the off-premises experience (Is the food properly hot or cold, not spilled, are tamper-evident seals intact, etc.?).

3. Go the extra mile to gain loyalty (i.e., the customers continue to reorder) – Provide educational materials and reminders for the consumer to enhance their trust of the food, its sanitary transportation, and allergen safety (avoidance messaging), and get feedback from them about their experience (e.g., Will they reorder?), especially if they report a negative experience.

4. Show the customer what you are doing to protect them – Providing hand-sanitizing wipes with each order for both third-party delivery persons and guests demonstrates a commitment to safety. For example, placing the wipes on the outside of the packaging signals guests to clean their hands before eating.

Before the coronavirus pandemic, ordering takeout was not thought of as a risky decision, and the restaurant and foodservice industry used off-premises sales for a customer’s convenience. Now, during this pandemic, off-premises sales may be the lifeline for saving a business and facilitating long-term recovery and growth, even once the pandemic has subsided. Therefore, some of the most important actions a restaurant must take are around off-premises dining, not only offering customers the opportunity to purchase food with reduced risk of exposure to the pandemic virus but also treating off-premises dining as a meaningful representation of the restaurant, its quality, and its safety practices. This also includes, above all, remaining committed to practices that ensure food safety, especially those measures related to the risk areas introduced into the equation via the off-premises operation.

References

1. https://restaurant.org/articles/news/consumers-respond-to-new-off-premises-options.

2. https://ww2.gojo.com/NoroHotSpot.html.

3. https://europepmc.org/article/med/22573873.

4. https://www.technomic.com/available-studies/multi-client-studies/navigating-new-off-premise.

5. https://restaurant.org/off-premises-report.

6. https://restaurant.org/articles/news/consumers-to-continue-using-takeout-and-delivery.

7. https://restaurant.org/articles/news/find-the-ghost-kitchen-model-thats-right-for-you.

8. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200AB2149.

9. http://www.foodprotect.org/issues/packets/2020Packet/attachments/III_004_content_c.pdf. Note: These Conference for Food Protection guidelines have not been voted on for approval by the conference due to the delay in meeting during the pandemic. However, these are very good best practices for the restaurants and foodservice businesses currently.

10. https://www.fda.gov/food/new-era-smarter-food-safety/new-era-smarter-food-safety-blueprint.

11. https://www.food-safety.com/articles/6809-whos-managing-the-safety-of-food-delivery.