A commissary or “Central Kitchen” is a hybrid food manufacturing operation. On one hand, because it serves to supply food to its own “satellites” (retail or foodservice stores), it is considered a retail operation. On the other hand, the new Food Safety Modernization Act – Preventive Controls For Human Foods (FSMA PC) does not consider commissaries as “retail exempt”. Therefore commissaries are regulated by the FDA as any other food manufacturer. This means that school and prison commissaries must be FSMA compliant (or demonstrate an exemption).
What if one store makes food for others? Is it a commissary? No. If a store makes food for other stores it is subject to the 50% rule. If more than 50% of the food is to go to other stores it is a commissary. If less than 50% it is a retail operation.
To further complicate matters, the USDA may claim oversight for commissary meat production. There is no clear guidance here from USDA. The CFR’s do state that any interstate third party shipped meats MUST come from a USDA inspected facility. However, if a commissary truck staffed with a commissary employee delivers the meat, it may not need USDA inspection. If meats are produced for sale to outside retailers, then that product is subject to USDA inspection.
Seafood production in the commissary IS specifically exempted from Seafood HACCP 21 CFR 123. Although, food safety of commissary seafood must still be controlled under FSMA PC.
In the food safety world, commissaries are often supervised by former foodservice or retail production staff. These staff members are familiar with the US FDA model Food Code and NOT with FSMA PC. It is very important to bring in education and training for these staff members regarding food safety and sanitation principles on a large scale. Outside of food safety; staff, supervisors, and administration must understand the economies of scale that manufacturers use. Reconsider purchasing ingredients in small sizes, eg. No. 10 cans. It might take 40-50 cans for a batch of food.
In the food safety world, we talk about controlling all of the hazards “under our control”. That usually means from ingredient receiving to food product sale. However, the commissary is often its own distributor or transportation company. In this case the process under control is from ingredient receiving to food product to delivery. Therefore, all aspects of delivery have to be controlled usually including safe temperatures and prevention of cross contamination.