Ghost Kitchen Food Safety – Who Is Responsible?

With the rising trend of using commissary kitchens as ghost kitchens, it is important to know the benefits and pitfalls associated with this mode of kitchen operation. As a licensed food business, you must understand your responsibility for ensuring food safety when operating out of a commissary kitchen. In addition, obtaining a food license is essential in keeping up with regulatory requirements and your customers safe while they consume the food.

What is Ghost Kitchen?

A ghost kitchen is a kitchen where food is prepared and served by a separate entity other than the restaurant that sells the food.

There are many benefits to using a commissary kitchen as a ghost kitchen, including increased efficiency, lower costs, and increased product quality.

Food safety is always an important consideration when working with food. It is important to understand who is responsible for ensuring this safety and what you need to be careful about.

Getting a food license can be difficult if you work out of your commissary kitchen, but there are ways to achieve this goal. One way would be to partner with another business that already has the appropriate licenses in place. You should also remember that some province requirements do not allow direct-to-consumer (DTC) operations, such as those involving kitchens serving only prepped or cooked meals from within the same facility. These setups would fall under the category of “ghost restaurants” and could present legal challenges if done without proper licensing or compliance measures in place.

1. The Pros of using a commissary kitchen as a ghost kitchen

Two primary reasons businesses use commissary kitchens are cost savings and convenience.

A commissary kitchen is perfect for businesses that want to start a food business without investing money into purchasing equipment or rentals and without all the need to renovate a kitchen. The commissary kitchen is typically managed by a management company, which means the facility is equipped with basic kitchen tools such as stoves, ovens, cleaning and sanitation for the common areas and pest control programs.

As the commissary kitchen is equipped with the basics of commercial food facilities, getting the city’s food safety license becomes easier. Commissary kitchen users would need to only worry about their food safety program and do not need to worry about the floor plan and layout of the facility for licensing purposes.

Most commissary kitchens are properly set up and ready for most new business owners to start building their food safety plan and apply for the food license.

2. The Cons of Using a Commissary Kitchen as a Ghost Kitchen

Operating a commissary kitchen can be an interesting and lucrative business venture, but it is not without its challenges. A few drawbacks should be considered when using a commissary kitchen as a ghost kitchen. The biggest drawbacks of a commissary kitchen are cross-contamination and uncontrolled food safety hazards.

The Commissary kitchen can host multiple business owners working on different types of products, sharing the facility’s areas. Unavoidably, this situation increases food safety hazards risk and potential for cross-contamination.

It is important to consider cross-contamination hazards such as sanitation cross-contamination, allergen cross-contamination, and raw and cooked product cross-contamination. Consideration must be given to the ability for the food production activities to be properly segregated or have enough spacing or barrier to prevent cross-contamination.

In addition, food security must be considered, as all commissary kitchen users have access to the food ingredients and products in the common areas.

3. Who is responsible for ensuring food safety when working out of a commissary kitchen?

This is a very important question. You need to understand who is responsible for food safety in the commissary kitchen -the distinction between your responsibilities as the business owners and the commissary managers.

Food safety requirements at a commissary kitchen should be no different from the food safety program at the food manufacturing facility. The differences are the Good Manufacturing Practices responsibilities at a commissary kitchen. In a food manufacturing facility, designated food safety managers ensure that food safety programs and procedures are followed. In the commissary kitchen environment, the food safety requirements are typically simple and handed to the business owners to manage and train their employees for food safety.

Due to the different levels of food safety training and management skills for each business owner, compliance with Good Manufacturing Practices may vary significantly.

P/s: if you are a commissary kitchen, please reach out. Ask us for our free GMP training for the commissary kitchen program to give back to our community.

Further, the commissary management is typically responsible for maintaining the general areas and leaves the “following and establishing food safety procedures” responsibility back to the commissary users. Then, it depends on the commissary users to ensure their food safety. If you are curious about who is responsible for food safety in the commissary kitchen, remember to seek the answers with your commissary kitchen.

This is an important reminder that as a commissary user, you must be aware of your food safety and operations hazards and risks as they impact your food safety and quality. You must be aware of your surroundings and environment as the type and level of food safety hazards may change with changes in food products being made along with your food products. Remember that we are sharing space and, therefore, are exposed to each other’s hazards.

We recommend that food business owners fully understand food safety risks and hazard levels to monitor the potential for cross-contamination and the introduction of new hazards. Whenever possible, operating the production activities during the non-peak period, such as in the evening or at night.

Ask us about our introductory HACCP training for commissary business owners, and we can help you understand how to prevent or manage cross-contamination and other food safety risks.

4. What are the requirements for getting and maintaining a food license when operating out of a commissary kitchen?

Depending on your geographical distribution areas and type of products, a provincial-based food license may be sufficient for most businesses. If you are selling the product beyond your local province or exporting the product, a Safe Food for Canadian license (SFC license) may be required. Review your requirements through our SFC license guidance article. It is important to ensure that you have all the licenses you need to meet regulatory purposes to avoid your business receiving CFIA complaints and/or CFIA investigations.

Provincial based food license would require a simple food safety plan to ensure that you can identify the critical food safety limits and have the plan to maintain the cleaning and sanitation of your equipment, tools and facility.

The SFC license expands beyond the provincial food safety plan. The SFC license calls for a Preventive Control Plan (PCP) based on the HACCP program. The PCP plan is more comprehensive than a simple food safety plan and incorporates procedures to maintain food safety based on HACCP pre-requisite programs.

To assist with compliance with SFCR procedures, SFPM Consulting has developed a template solution that you can use to build compliant SFCR procedures.

For a limited time, the template also comes with free food safety consultation to help you build your food safety program.

5. Can I get a HACCP certificate in a commissary kitchen?

Many small food business owners ask, “Can we get a HACCP certificate if we work from a commissary kitchen?”. The quick answer is yes. Obtaining a HACCP certification in a commissary kitchen is possible.

However, there are a few requirements that you need to be aware of.

First, HACCP certification is specific to food products and companies. That means the HACCP certification will not apply to the entire commissary kitchen unless the facility manager chooses to do so.

The cons are you will have most users that are not HACCP certified, and you must perform a risk assessment every time you share the space.

To fully comply with the HACCP certification requirements, you must be trained with HACCP training. You must understand how to perform the food safety risks, what other products are made at the commissary kitchen and how it would impact the safety of your food products.

HACCP requirements can be extensive beyond the documentation that the commissary manager can support you. You must be able to have both the procedures and documentation to prove that your HACCP program is working. It is a huge undertaking.

Our SFPM Consultant helps you build the program and understand your HACCP certification process, so you know how to navigate a commissary’s challenging HACCP certification situation.

In addition, you must be aware that not all certifications can apply to the commissary. For example, cross-contamination may not be possible for gluten-free certification. Other certifications such as Halal, Kosher, non-GMO, or organic certification may also be challenging if you share the equipment with commissary users.

Is working in a commissary kitchen worth it?

As you can see, using a commissary kitchen as a ghost kitchen has its pros and cons. Considering the ghost kitchen food safety for your business, it’s important to weigh all the factors carefully before making any decisions. Make sure to have a plan in place for food safety and compliance with other regulations. And don’t forget—you’ll need an adequate food license (and HACCP certification, if requested by your client) to grow your business.

Building a ghost kitchen HACCP program or the SFCR program can be challenging for business commissary users. At SFPM Consulting, we have the right solutions that help commissary managers plan for HACCP compliance for commissary users. Similarly, our SFPM Consultant helps commissary users plan and obtain their HACCP certification at a commissary kitchen.

Book  a complimentary call so we can help you plan your way for HACCP certification and grow your business.

We know how important HACCP certification is to a growing food brand, and we are here to support our local business owners grow and market their food products.