ADVANCEMENT OF THE PRACTICE
Open Access
DIRECT FROM AAS
The Home Food Processing Establishment License in Iowa
Eric Bradley, MPH, REHS, CP-FS, DLAAS
(The Iowa Legislature, 2022). The new law went into eect on July 1, 2022. When the Iowa Department of Inspections and Appeals (DIA), the state agency that oversees the food inspection program in Iowa, requested the law not go into eect until the administrative rules were approved, the request was denied. DIA and local jurisdictions had to assist these busi- nesses to begin operating without rules, which were eventually passed in September 2022. Previously, Iowa had a home bakery license that had been known until 2016 as a home food establishment license. A person could make bread, cakes, pastries, cookies, cakes, and pies that were not TCS (food requiring time and temperature control for food safety) in their home without a license if items were being sold directly to the consumer. If the per- son wanted to wholesale these baked goods or sell them at a temporary food event or farmers market, the home bakery license was required. If the person wanted to produce TCS baked goods like cheesecakes, soft pies, and custard or cream fillings, the home bakery license was also required (The Iowa Legislature, 2020). The home bakery license was changed to the home food processing establishment license and allowed a person to produce food from their residential kitchen for consumption o the premises if the business has gross annual sales of <$35,000. While the law specifically prohibits TCS food under the home food pro- cessing license, it does allow the sale of poul- try, poultry byproduct, poultry food product, meat, meat byproduct, or meat food product if the product is exempt under the Code of Federal Regulations (CFR) 381.10 or CFR 303.1 (The Iowa Legislature, 2022). The law defines “produce” as “to prepare a food item
Editor’s Note: In an eort to provide environmental health profes- sionals with relevant information and tools to further the profession, their careers, and themselves, the National Environmental Health Association (NEHA) has teamed up with the American Academy of Sanitarians (AAS) to publish two columns a year in the Journal . AAS is an organization that “elevates the standards, improves the practice, advances the professional proficiency, and promotes the highest levels of ethical conduct among professional sanitarians in every field of environmental health.” Membership with AAS is based on meeting certain high standards and criteria, and AAS members represent a prestigious list of environmental health professionals from across the country. Through the column, information from dierent AAS members who are subject-matter expects with knowledge and experience in a multitude of environmental health topics will be presented to the Journal’s readership. The conclusions and opinions of this column are those of the author(s) and do not necessarily represent the views of NEHA. Eric Bradley is a diplomate laureate and executive secretary and treasurer of AAS. He has been a registered environmental health specialist for 19 years and has >25 years of experience in the environmental health field.
S ince the COVID-19 pandemic, the U.S. food service industry has struggled to find and keep sta. Due to the revolv- ing door of food workers, many restaurants barely have enough time to train new employ- ees in basic job duties, much less food safety, before they move on to another facility. Many environmental health professionals involved in food inspections have seen this occurrence firsthand. An environmental health profes- sional conducts a food inspection and when they go back for a follow-up, the food sta are
all new, and in many cases, so is the manager. Since no one at the facility has an idea of what was out of compliance during their past in- spection, does the environmental health pro- fessional conduct a follow-up inspection or do they conduct another routine inspection? To add to this already tumultuous atmo- sphere, the 2022 Iowa legislature passed House File (HF) 2431. This law changed Iowa’s existing home bakery license into a home food processing establishment license and ocially established a cottage food law
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Volume 86 • Number 9
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