Mastering the Grid: How Food Retailers Can Ace FDA Inspection Items #38 to #42
For commercial kitchens, a surprise health inspection can feel like a high-stakes exam. While “Risk Factors” like holding temperatures get the most headlines, ignoring Good Retail Practices (GRPs)Â is one of the quickest ways to tank your inspection score.
FDA Food Code Inspection Form items #38 through #42 focus entirely on the Prevention of Food Contamination. Keeping these five core sanitation areas flawless protects your customers, secures your reputation, and keeps your inspection report clean.
1. Item #38: Insects, Rodents, and Animals Not Present
Pest control is a foundational pillar of food safety. An inspector marking this item “OUT of compliance” means they spotted active signs of pests—such as mice droppings, fruit flies, or cockroach casings—or structural gaps that invite them inside.
The Fix:Â Maintain a rigorous pest control contract, seal all exterior gaps or cracks, and ensure kitchen doors remain closed.
2. Item #39: Contamination Prevented During Food Prep, Storage, and Display
Food is vulnerable at every stage of the line. This item covers structural and behavioral protections: keeping food stored at least 6 inches off the floor, using overhead shields on buffet lines, and keeping containers covered when not in use.
The Fix:Â Train staff never to leave food tubs directly on the floor and enforce strict operational boundaries between raw prep and ready-to-eat staging.
3. Item #40: Personal Cleanliness
Handwashing is a separate, major risk factor, but Item #40 catches the operational habits of your team. This includes wearing clean outer garments, effective hair restraints (nets or hats), and removing unnecessary jewelry from hands and arms during food preparation.
The Fix:Â Enforce a strict dress code. Ensure hair is tied back completely and employees wear clean aprons daily.
4. Item #41: Wiping Cloths: Properly Used and Stored
Wet wiping cloths left sitting on prep tables are prime breeding grounds for bacteria. Under Item #41, cloths used for wiping food spills must be held in an approved chemical sanitizer solution bucket (at the correct PPM concentration) between uses.
The Fix:Â Keep sanitizer buckets distributed across the kitchen. Use test strips daily to verify the chemical strength.
5. Item #42: Washing Fruits and Vegetables
Before any piece of produce is chopped, sliced, or served, it must be thoroughly washed under running water to remove soil, chemicals, and potential pathogens. Doing this in a dedicated, sanitized food prep sink is vital to avoid cross-contamination.
The Fix:Â Never wash produce in a handwashing or warewashing sink. Make sure your team thoroughly rinses all raw fruits and vegetables before processing.
What is the Point Loss in Most States?
The exact scoring mechanics vary depending on local jurisdiction, but because items #38 through #42 are categorized as Core Items or Priority Foundation Items (Good Retail Practices) under the FDA Food Code, the point loss breaks down consistently across the U.S.:
Core Violations: Items like #40 (Personal Cleanliness), #41 (Wiping Cloths), and #42 (Washing Fruits/Vegetables) usually carry a deduction of 1 point per violation.
Priority Foundation / Escalated Violations: Items like #38 (Pests) and #39 (Contamination Prevention) can escalate depending on severity. If a pest issue or storage violation poses an immediate contamination risk, it can be marked as a Priority Foundation violation, triggering a 2-point deduction (and in some strict point systems like Texas or local health matrix systems, up to 3 points if it crosses into a critical hazard).
The Takeaway: While a single 1-point deduction won’t shut your doors, racking up multiple GRP violations across items #38–42 signals a systemic lack of operational control. Clean habits build safe kitchens!
#FoodSafety #FDAFoodCode #RestaurantManagement #HealthInspection #CommercialKitchen #GoodRetailPractices #CleanKitchen