14.4 Off-Site Service, Catering, Delivery, and Vending

Key Takeaways

  • Move off-site TCS food in insulated containers that keep hot food hot and cold food cold; check temperatures on arrival.
  • Label off-site food with the name, discard time, and holding instructions, and avoid bare-hand contact with ready-to-eat food.
  • Delivery vehicles stay clean. Catering starts with a site evaluation for power and handwashing.
  • Do not take leftover TCS food back from a catering site for reservice.
  • TCS vending machines must shut off automatically if they leave safe temperatures; vended TCS food is packaged and labeled. Mobile units follow the same Food Code rules plus water and wastewater tanks.
Last updated: August 2026

Off-site service is the same Food Code with worse equipment, a moving vehicle, and someone else’s sink — or no sink. Delivery, catering, vending, and mobile units do not get a lighter 135°F or a friendlier 41°F. They get insulated containers, labels, arrival checks, and a leftover rule that is stricter than a restaurant steam table because you do not control the client’s kitchen after you leave.

The PIC who can hold chili legally in-house and then send it across town in a plastic tub with no ice pack has not finished the holding chapter.

Delivery: Containers, Labels, Vehicles, Arrival Checks

Pack TCS food in insulated containers that keep hot food hot and cold food cold. Hot boxes, Cambros, and refrigerated bags are equipment, not décor. A cardboard box and a hope that the drive is short are not 3-501.16. Do not pack hot pans against cold pans in one uninsulated stack and call the steam “a heat source.”

Label each container with the name of the food, the discard time, and holding instructions (hold at 135°F or above; hold at 41°F or below; discard at 2:00 p.m.). The receiving site may be a conference-room volunteer, not a certified manager. The label is the procedure they can follow. Unlabeled hotel pans of “the chicken thing” with no discard time are how leftover TCS gets served at 5 p.m. after a 10 a.m. drop.

Avoid bare-hand contact with ready-to-eat food during packing, delivery, and set-up. Gloves, tongs, deli paper, or a scoop — the same RTE rule as the make line. A boxed lunch is still RTE food. The lid does not make bare hands legal.

Delivery vehicles stay clean. Interiors are washable. Spill raw chicken juice in a trunk and then stack salad boxes on that carpet and you have built a mobile cross-contamination room. Keep chemicals and fuel away from food. Keep the vehicle free of pests and personal laundry. If the operation runs a refrigerated van, the van is a cooler: measure food, not only the dashboard display.

Check temperatures on arrival. The legal hold at the commissary does not prove the legal hold at the loading dock of the office park. Probe hot TCS (135°F or above) and cold TCS (41°F or below) before you hand the event over. Food that arrived at 118°F is not “fine because it was 140°F when we left.” If time as a public health control is the written plan for that drop, the time mark and discard time travel with the food — and arrival at an illegal start temperature still fails the 4-hour entry rule from 14.2.

Catering: Site Evaluation and Leftovers

Catering begins before the truck is loaded. Evaluate the site: working power for hot-holding and cold-holding equipment, a legal handwashing setup (not a restroom down two flights and a bottle of water), protection from pests and weather, and enough tables so raw and ready-to-eat work do not share one unprotected folding table. A client who says “we have a kitchen” still gets a walk-through. A break-room microwave and a bathroom sink are not a catering commissary.

On site, the same service rules apply: sneeze guards or equivalent protection if guests self-serve, utensils stored correctly, no bare-hand RTE contact, temperature checks on the 2-hour / 4-hour holding rhythm. If the site cannot hold 135°F or 41°F, you either bring equipment that can or you use a written time-as-control procedure with marks and discard times. You do not discover the missing outlet at 11:50 and invent four hours.

Leftover policy: generally do not take leftover TCS food back for reservice. Food that sat on a client buffet, in an unmonitored conference room, or under guest hands is not commissary inventory. Discard it or leave it with the client under a written agreement that it will not re-enter your food supply. The exam answer is do not bring leftover TCS back to serve again tomorrow. Unopened packaged non-TCS may follow the same re-service logic as 14.3. Chili, sliced turkey, cut fruit, and cooked rice do not.

Vending

TCS vending machines must automatically shut off if they leave safe temperatures. A sandwich machine that warms above 41°F, or a hot-soup machine that drops below 135°F, stops vending. Staff cannot tape the door and keep selling. Vended TCS food is packaged and labeled (name, and the information a packaged food needs so the guest is not buying an anonymous leftover). Restocking is a receiving event: check dates, package integrity, and machine temperature before the machine goes back into service.

A vending machine that sells only shelf-stable packaged non-TCS snacks is a different animal. The shutoff rule the exam cares about is the TCS machine.

Mobile Units and Food Trucks

A food truck is a food establishment that happens to have wheels. Same Food Code principles: approved source, 135°F / 41°F holding, no bare-hand RTE contact, employee health, warewashing or an approved commissary plan, and protection from contamination. What changes is plumbing.

Water tanks supply potable water for handwashing and food prep. Wastewater tanks (greywater) collect what the sinks produce and are sized so the truck does not dump on a parking lot. Freshwater and wastewater connections do not cross. Tanks are cleaned, filled from a potable source, and emptied into an approved sewage receptor. A five-gallon jug and a bucket under the sink are not a mystery exception; they still have to meet the Code’s mobile water and waste rules as the jurisdiction applies them. Power, refrigeration recovery after the generator blips, and outside storage of backup product in a personal car are the usual truck failures. The PIC treats a generator outage like a cooler failure: measure food, use time only if a written program already exists, discard what left the legal band too long.

Off-Site Risk and Control

Off-site riskWhat goes wrongControl
Hot food cooling in transitUninsulated pans drop below 135°FInsulated hot-holding containers; arrival probe; discard or do not serve if time is gone
Cold food warming in a trunkSalad, dairy, or cut fruit enter the TDZInsulated cold containers, ice packs, refrigerated vehicle; arrival probe
Unlabeled drop-offClient holds leftover TCS all afternoonName, discard time, and holding instructions on every container
Bare hands on boxed lunchesRTE contamination after a legal cookGloves, tongs, or wraps; same no-bare-hand rule
Dirty delivery vehicleChemicals, raw drip, or pests reach packaged foodClean, food-only interior; raw and RTE separated
Catering site with no power or no hand sinkCannot hold temperatures or wash handsSite evaluation before the event; bring equipment or change the menu
Leftover TCS returned to the commissaryUnmonitored buffet food re-enters serviceDo not take leftover TCS back for reservice
TCS vending machine above 41°F or below 135°FMachine keeps selling abused foodAutomatic shutoff; packaged, labeled product
Food truck wastewater dumped on asphaltSewage and handwash failureSized wastewater tank; approved dump site; potable water tank

Scenario: Tuesday Corporate Lunch Drop

The commissary packs hot pasta at 145°F into a charged Cambro and cold boxed salads into a refrigerated bag with a 41°F probe check. Each Cambro is labeled “marinara pasta — hold hot 135°F+ — discard 1:30 p.m.” The van was cleaned after yesterday’s raw-chicken catering load. On arrival the pasta probes 139°F and the salads probe 40°F. Staff set up with gloves and tongs. At teardown, leftover pasta and opened salad pans are discarded. Unopened cracker packs return. That drop met 14.4. The same drop in grocery bags, no labels, no arrival check, and leftover pasta back in Wednesday’s soup, did not.

Exam Traps

  • “The drive is only 20 minutes” is not a temperature control. Insulate and probe.
  • Leftover catering TCS is tomorrow’s special is false. Do not take it back for reservice.
  • Boxed lunches allow bare hands is false. RTE is still RTE.
  • Vending machines are exempt is false. TCS machines shut off when they leave 41°F or 135°F.
  • Food trucks follow different temperatures is false. Same 3-501.16; extra water and waste duties.
  • Client kitchen equals approved site is false until you evaluate power and handwashing.

Off-site work is holding, labeling, and leftover discipline under worse conditions. If the container cannot keep the number, the label cannot state the discard time, or the site cannot wash hands, the event is not ready to leave the dock.

Test Your Knowledge

How should TCS food be packed and identified for off-site delivery?

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Test Your Knowledge

What does the Food Code require of a vending machine that sells TCS food?

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Test Your Knowledge

A caterer is booking an off-site lunch in a client conference room. Which pair of controls is correct?

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