Meal Kit Delivery Services May Be Convenient: But How Would a Recall Work?

By Brian Kellerman

The trend towards busy families and professionals utilizing meal kit delivery services to save valuable time without having to abandon the kitchen is most likely here to stay. However, one aspect of this trend that has not yet been fully considered is the relatively high level of food safety risk inherent in selling food over the internet.

Beyond the food safety issues that can arise from eating undercooked meat or raw produce, a large portion of meal kits also contain allergens, which are the most common cause of food safety recalls in the food industry. Although the FDA’s Food Safety Modernization Act (21 CFR 117) and the USDA’s HACCP regulations (9 CFR 417) clearly apply to companies that sell food over the internet, it doesn’t appear that any serious efforts are being made by either the FDA or USDA to begin regulating this subsegment of the food industry.

If a meal kit delivery service is forced to initiate a food recall, will they have the proper batch coding and sales records to track down the food they ship in a timely manner? How will customers be notified of a food recall and will it be in time to prevent consumption? These are the questions that meal kit delivery services should be asking as they build their food safety programs. For any food business, the absence of a food safety program increases the chance of a serious illness occurring, and it is unclear how prepared meal kit delivery services are to warn customers of a potential issue or to track down their shipments in the case of a food recall.

We have not yet seen a full food recall from a meal kit delivery service, but when we do, enforcement by the FDA and USDA will surely step up quickly. The day when the FDA or USDA moves to step in will arrive sooner than later, and the ramifications on small businesses will be significant. Any food manufacturer that is dependent on internet sales for their revenue, but has not registered with the FDA or USDA, would be well-advised to begin the process now of learning the food safety rules that national food businesses are required to follow, and getting your business ready for the day when the FDA, USDA (or both) ramp up enforcement over this sector of the food industry.

About the Author

Brian Kellerman has spent 17 years working in food production, most recently directing a GFSI-certified food safety and quality program for a large food factory before co-founding Kellerman Consulting, where Brian is responsible for developing food safety and quality documentation for clients, as well as assisting clients with implementing their programs. In 2017, Brian wrote over 150 food safety plans for over 100 clients in 35 states, including every type of FDA, USDA and restaurant plan.