From: Fermon, Colleen
To: DPH-Testimony, Reg (DPH)
Subject: Retail Food Establishments
Date: Thursday, December 22, 2016 2:16:11 PM
I offer the following comments regarding the Proposed Revisions to 105 CMR 590.000-
590.010(C)(2) (b) The application must conform to the 2013 Food Code and the Temporary Food Establishments Document. Within the 2011 Final document, it notes the applicable 2009 Model Food Code Sections have been italicized. What are the differences between the 2009 and 2013 versions of the Federal Food Code as it pertains to temporary food? This may cause confusion among PICs.
590.010(C)(2) (c) reads a temporary food permit may be issued for a period of time that shall not exceed 14 days. The word consecutive is not provided.
590.010(H) (1) Are shared kitchen or incubator operation defined? Fledgling food retailer or preparer is included although fledging is not defined. Why is this language provided? If it is not a fledgling food operation, can’t the operator still use a shared kitchen or incubator operation?
590.010(H) (2) and (3) Entrepreneurs is included although it is not defined.
The rational for use of these facilities is provided in 590.010(H) (2) (a) or (b). If the operator no longer complies with 590.010(H) (2) (a) or (b), can they still operate out of these facilities?
590.010(H) (3) (a) the word or is missing between shared kitchen and incubator. 590.010(H) (4) (a) the word not appears to be missing between shall rent
590.010(H) (4) (b) wouldn’t it be clearer to change the wording from street fairs to a temporary food event?
590.010(I)(2) Reads in order to meet the minimum requirements of 590.010(I) a raw bar should: Why is this should which means a recommended? It appears shall which means required would be the appropriate word if that is what is needed to meet minimum requirements?
Colleen E. Fermon Director of Public Health Public Health Office Town Hall
25 Green Street
Ipswich, MA 01938
978-356-6606