ServSafe Manager · Safe Receipt, Storage, Transportation and Disposal of Food · 8 min read
Labeling, Date Marking and Refrigerated Storage
- Establish compliant labeling and date-marking standard operating procedures for working containers, retail packages, and ready-to-eat TCS foods.
- Apply active managerial control to refrigerated storage, including temperature monitoring, airflow maintenance, FIFO rotation, and corrective actions.
- Implement the vertical storage hierarchy in refrigeration units to prevent cross-contamination based on minimum internal cooking temperatures.
Food Labeling in the Operation and for Retail Sale
As a food service manager, clear labeling is one of your primary defenses against accidental misidentification and allergen exposure. When food is removed from its original manufacturer packaging and placed into working containers, managers must ensure staff clearly label the container with the food's common name. The only exception granted under the FDA Food Code is when the food item is readily and unmistakably recognizable, such as dry spaghetti. If there is any potential ambiguity between dry white powders, grains, or sauces, a clear label displaying the common name is mandatory.
Labeling requirements become significantly more stringent when an operation packages food on-site for retail sale, such as grab-and-go salads or house-made deli items. Active managerial control requires managers to verify that retail labels include the common name of the food or an identification statement, along with the net quantity of the food. If the product contains two or more ingredients, the label must display a complete ingredient list with items arranged in descending order by weight.
In addition to basic ingredient information, retail packaging labels must declare the presence of any major food allergen defined by law. The label must also explicitly identify any artificial colors, artificial flavors, and chemical preservatives used in the product. Managers must ensure the package includes the name and place of business of the manufacturer, packer, or distributor, and nutrition labeling when required by applicable labeling law. Establishing a checklist for these retail requirements protects guests and ensures regulatory compliance across all sales displays.
| Container Type | Mandatory Label Elements | Exemptions / Conditions |
|---|---|---|
| Working Container (Removed from original packaging) | Common name of the food. | Not required if the food is readily and unmistakably recognizable (e.g., dry spaghetti). |
| On-Site Packaging for Retail Sale | Common name or identification statement; net quantity; ingredient list in descending order by weight (if 2+ ingredients); artificial colors, artificial flavors, and chemical preservatives; major food allergens; name and place of business of manufacturer, packer, or distributor. | For food packaged on-site for retail sale, managers must check the applicable Food Code and labeling laws; ingredient lists, allergen declarations, and disclosures of artificial colors, artificial flavors, and chemical preservatives are required when applicable, not for every product. |
Common mistakes
- Assuming unopened, intact commercial packaging allows raw meats to be stored on shelves above ready-to-eat food in a refrigerator.
- Restarting the 7-day date marking clock after frozen ready-to-eat TCS food is thawed, rather than counting the remaining unused days.
- Relying solely on external unit thermometers or air temperature readings instead of measuring the actual internal food temperatures.
- Covering refrigerator wire shelves with cardboard, sheet pans, or aluminum foil, which blocks cold air circulation and raises food temperatures.
Key points
- Working containers of food removed from original packaging require a common-name label unless their contents are readily and unmistakably recognizable; food packaged on-site for retail sale must bear all applicable label information, including nutrition labeling when required.
- Unless an exemption applies, refrigerated ready-to-eat TCS food prepared on-site or commercially processed and opened for use must be date marked if held longer than 24 hours and used, sold, or discarded within 7 days at 41°F (5°C) or lower, counting preparation or opening as Day 1.
- Combining RTE TCS ingredients requires using the earliest ingredient discard date, and freezing pauses the 7-day timeframe without resetting the clock upon thawing.
- FIFO procedures require training staff to place items with the earliest discard or safety use-by dates in front and monitoring staff to ensure front inventory is pulled first.
- Managers must keep refrigerated TCS food at 41°F (5°C) or lower, use a unit air- or simulated-product-temperature device accurate to ±3°F (±1.5°C) in the unit’s warmest area, and check food temperatures with a food thermometer accurate to ±2°F (±1°C).
- Food must be stored at least 6 inches (15 cm) off the floor in designated food storage areas, never in mechanical, locker, or toilet rooms.
- In a shared refrigerator, managers should protect ready-to-eat food from raw-food drips and arrange raw animal foods to prevent cross-contamination, placing chicken and turkey requiring 165°F (74°C) below foods with lower cooking requirements; ratites are an exception to the stated poultry cooking temperature.
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