Preparation Date vs. Use-By-Date on Food Labels
One area of agreement in foodservice establishments is the importance of datemarking and labeling foods in storage. Operators are instructed to practice First-In, First-Out (FIFO) food rotation for improved food quality, food safety and cost controls, and they use dates on their prepared food containers as their guide for food rotation. However, there is some confusion about which date is best to record on food labels before storage…"Preparation Date," "Use-By Date" or both? In this context, "Use-By Date" is synonymous with "Discard Date" and "Expiration Date."
Correct, effective labeling is a common challenge for many food establishments because they may not be aware of proper practices or are just plain confused. To avoid confusion, it is helpful to understand common labeling practices or shortcomings as well as the downside of using only Preparation Date information on labels.
FOOD ROTATION REGULATIONS
Time and Temperature Control for Safety (TCS), ready-to-eat foods prepared on-site (or foods in opened containers) can be stored in the refrigerator for up to 7 days, according to the FDA 2017 Food Code. This regulation is for safety reasons, in order to avoid bacteria growing to dangerous levels. For this reason, the FDA requires these foods to be labeled with a "Use-By-Date." This date is what most health inspectors would look for. The goal is that foods will be used or discarded by their "Use-By-Date" for safety reasons, as well as for quality. Stricter time limits can be set by the restaurant for quality reasons. For example, setting a 3-day limit for tuna salad or 4 days for sliced ham.
FOOD ROTATION PREPARATION DATE
Management or the corporate office often mandates employees to use the Preparation Date for rotating foods in order to control food quality, and of course, food costs. Therefore, kitchen staff is driven to record the date that the food is prepared on, which is often the only date marked on the food label. Sometimes colored day labels are used to represent the Preparation Date instead of the Use-By Date. There is often resistance to also write the Use-By Date on labels (either alone or in addition to the Preparation Date). Some operators may make statements such as:
"We use the Preparation Date (only) on our labels" or "We use the colored day-of-the-week label as the Preparation Date." A few pitfalls can happen here:
- It is up to employees going in and out of the refrigerator to mentally calculate the "shelf-life" or "Use-By Date" from the Preparation Date for the products they use, day in and day out.
- Unless there is 100% training in calculating these "Use-By-Dates," it leaves a lot of room for error.
- Whether the Use-By Date represents the FDA's recommended 7-day maximum shelf-life or stricter shelf-life limits set by the company, there is no clear visual of that Use-By Date on the label, and expired (unsafe) foods may inadvertently remain on shelves. People are simply looking for the "lowest date" on the shelf, though expired.
- When the health inspector visits and sees a past date on a food label, depending on the jurisdiction, he/she may assume that foods are expired, requiring the operator to discard the food. This would also be a food code violation.
USE-BY DATE (DISCARD DATE)
Recording the "Use-By-Date" on the label eliminates the calculation step for all employees. The Use-By Date is calculated once by the person preparing the food (or even better, the Prep-n-Print System). The Preparation Date is the key to calculating the "Use-By Date" (i.e., "Discard Date") by adding the shelf-life (number of days) to the Preparation Date in order to determine when to discard the food for safety purposes. The Use-By Date can be handwritten or indicated by the colored day-of-the-week symbol/label, in addition to the Preparation Date, if that is required by company policy.
If an operator insists on using a Preparation Date on their food labels, they are advised to also include a Use-By-Date.
By Cindy Rice, RS, MSPH, CPFS