Regulatory & Compliance Resources

2022 FDA Food Code Updates 

2022 FDA Food Code

Summary of Food Code Changes

Understanding Updates to the 2022 FDA Food Code

See below for the most relevant Food Code information for CDM, CFPPs.

Where do ANFP Members work?

Pie Chart


Percentages represent where ANFP members (both CDM, CFPPs and non-CDM, CFPPs) work.

Where do you work?

Select your work environment below to explore relevant resources and regulatory information.

Nursing Home/LTC


Assisted Living/CCR/Retirement

School Foodservice



Food Code Information for CDM, CFPPs

Important Definitions

The following definitions help to clarify the role that CDM, CFPPs play in Food Code Compliance:

  • Highly susceptible population means PERSONS who are more likely than other people in the general population to experience foodborne disease because they are: (1) Immunocompromised; preschool age children, or older adults; and (2) Obtaining FOOD at a facility that provides service such as custodial care, health care, or assisted living, such as a child or adult day care center, kidney dialysis center, hospital or nursing home, or nutritional or socialization services such as a senior center.
  • Person in charge means the individual present at a FOOD ESTABLISHMENT who is responsible for the operation at the time of inspection.
  • Permit holder means the entity that: (1) Is legally responsible for the operation of the FOOD ESTABLISHMENT such as the owner, the owner’s agent, or other PERSON; and (2) Possesses a valid PERMIT to operate a FOOD ESTABLISHMENT

Person in Charge (PIC) Additional Food Safety Training Requirement Clarified

The following definitions help to clarify the role that CDM, CFPPs play in Food Code Compliance:

  • The Food Code Person in Charge (PIC) requirements apply to establishments or Care Communities that have a retail food license to sell food outside their buildings. This retail food license is regulated by the State/Local/County Health Inspector.
  • Centers for Medicare & Medicaid Services (CMS) and its survey process does not include the PIC in 483.60 Food & Nutrition Services (FNS) Regulations but does require specific educational requirements for the FNS Director which lists the CDM, CFPP first on that list. DO BE AWARE some states may have specific Long Term Care regulations that include added Food Safety training for which you would need to be in compliance.
  • If your facility operates with a retail food license, the FDA requires a person to be the designated PIC, so it may benefit your department to have multiple staff members trained.

Food Protection Manager Certification vs. Demonstration of Knowledge

  • You may refer to the definition for Accredited Program in ¶1-201.10(B)(3). Food protection manager certification occurs when individuals demonstrate through a certification program that they have met specified food safety knowledge standards. Page 324
  • However, it is important to note that certification as a Food Protection Manager by passing an examination that is part of an accredited program (Page 339) is not the only method of demonstrating that you meet specified food safety knowledge standards. The food code states:
    • Based on the RISKS inherent to the FOOD operation, during inspections and upon request the PERSON IN CHARGE shall demonstrate to the REGULATORY AUTHORITY knowledge of foodborne disease prevention, application of the HAZARD Analysis and CRITICAL CONTROL POINT principles, and the requirements of this Code. The PERSON IN CHARGE shall demonstrate this knowledge by:
      • (A) Complying with this Code by having no violations of PRIORITY ITEMS during the current inspection;
      • (B) Being a certified FOOD protection manager who has shown proficiency of required information through passing a test that is part of an ACCREDITED PROGRAM or
      • (C) Responding correctly to the inspector’s questions as they relate to the specific FOOD operation
        • Referenced to Section 2-102.11 Page 55
      • FDA encourages food regulatory authorities and others evaluating credentials for Food Protection Managers to recognize the Conference for Food Protection/American National Standards Institute (ANSI) means of accrediting certification programs. This procedure provides a means for universal acceptance of individuals who successfully demonstrate knowledge of food safety. The procedure provides officials assurance that food safety certification is based on valid, reliable, and legally defensible criteria. In addition, universal acceptance eliminates the inconvenience and unnecessary expense of repeating training and testing when managers work across jurisdictional boundaries


For more information, or answers to specific regulatory questions, please e-mail