Master the Food Code: How to Ace FDA Inspection Items #43 to #46
Maintaining a flawless kitchen isn’t just about delicious food—it’s about passing your health inspection with flying colors. Among the most common pitfalls for commercial kitchens are the “Good Retail Practices” (GRPs), specifically Items #43, #44, #45, and #46 on the FDA Food Code Inspection Form.
While these items focus on the proper use and storage of utensils and gloves, ignoring them can quickly tank your inspection score and compromise diner safety. Here is a comprehensive breakdown of what health inspectors look for and how to ensure your kitchen stays compliant.
🛑 Breaking Down FDA Food Code Items #43–#46
Item #43: In-Use Utensils: Properly Stored
When your chefs and servers are in the middle of a rush, where do their utensils go? Item #43 tracks how scoops, tongs, and knives are stored while actively being used.
The Rules: Utensils can be stored in the food product with handles extended upward out of the food, on a clean and sanitized surface, or immersed in running water. If stored in hot water, the water must be maintained at 135°F (57°C) or above.
Common Violation: Leaving an ice scoop handle buried inside the ice bin or letting a spatula rest on a greasy countertop.
Item #44: Utensils, Equipment & Linens: Properly Stored, Dried, & Handled
Cleanliness doesn’t stop once the dish machine finishes its cycle. Item #44 addresses how clean items are handled and stored before their next use.
The Rules: All equipment and utensils must be completely air-dried before being stacked or stored—using a towel to dry them is a strict violation because it introduces cross-contamination. Additionally, utensils must be stored covered or inverted (handles facing up) to protect food-contact surfaces from dust and splashes.
Common Violation: Stacking wet pans (“wet nesting”) or storing forks with the tines pointing upward where staff might touch them.
Item #45: Single-Use/Single-Service Articles: Properly Stored and Used
Single-service items—like plastic cutlery, paper cups, take-out containers, and paper straws—are designed to be used once and thrown away. Because they cannot be cleaned and sanitized, keeping them pristine is vital.
The Rules: These articles must be kept in their original closed packaging or stored in a clean, dry cabinet at least 6 inches off the floor until used. They must also be handled in a way that prevents contamination of the surfaces that touch a customer’s mouth.
Common Violation: Leaving boxes of plastic cups open on the floor under a prep table or touching the rims of cups when handing them to customers.
Item #46: Gloves Used Properly
Single-use gloves are a great tool for preventing bare-hand contact with ready-to-eat (RTE) foods, but only if they are used correctly.
The Rules: Gloves are not a substitute for handwashing. Staff must wash their hands thoroughly before putting on a new pair of gloves. Gloves must be discarded and replaced whenever they become torn, soiled, or when switching between tasks (such as moving from raw chicken to slicing tomatoes).
Common Violation: Blowing into gloves to open them, or wearing the same pair of gloves to prep food, answer the phone, and go back to prepping food.
📉 What is the Point Loss in Most States?
On traditional 100-point retail food inspection scoring systems utilized by many states, Items #43, #44, #45, and #46 are classified as Good Retail Practices (GRPs) rather than Critical Violations (or Priority Items).
The Penalty: In most states, an out-of-compliance mark for any individual item from #43 to #46 results in a 1-point deduction (with some jurisdictions assessing a 0.5-point deduction for minor or isolated occurrences).
While losing 1 point might not seem like a disaster, these minor deductions accumulate rapidly. A kitchen that is sloppy with its utensils, wet-nests its pans, and misuses gloves can easily rack up a 4-to-5-point deficit from this section alone—dropping an “A” grade down to a “B.”
đź’ˇ Pro-Tips for a Compliant Kitchen
Ditch the Towels: Enforce a strict “air-dry only” policy at your dishwashing station.
Handle First: Train front-of-house staff to always grab silverware by the handles and cups by the base.
Trigger Handwashing: Remind team members that a change of gloves always requires a wash of hands.
By mastering these simple utensil and glove habits, you protect your customers, optimize your workflow, and guarantee a stellar score on your next health inspection.
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