Storage and Inventory Management of USDA Foods

This management bulletin (MB) provides guidance regarding the storage and inventory management of U.S. Department of Agriculture (USDA) Foods and clarifies USDA Policy Memorandum FD-107: Donated Food Storage, Distribution, and Product Dating (Revised), dated November 21, 2017, which is on the USDA Food Distribution Policy Web page at https://www.fns.usda.gov/usda-foods/storage-and-inventory-management-usda-donated-foods. This MB supersedes MB USDA-FDP-02-2010: Storage and Inventory Management of USDA Donated Foods dated August 2010.

Product dates found on retail and USDA Foods are not federally regulated and can have a variety of definitions. Food manufacturers may voluntarily provide dates to help consumers and retailers decide when food is of best quality, but these dates are not an indicator of wholesomeness or food safety. Factors including the length of time and temperature food is held during storage, the characteristics of the food, and the type of packaging will affect how long a product will remain at optimum quality. It is important for recipient agencies (RA) to forecast anticipated demand of each item ordered to ensure inventories do not exceed a six month period.

As a general rule, RAs should use a first-in-first-out system of inventory management by marking food cases or other containers with the date of receipt. However products marked with the earliest best-if-used-by date, best-if-used-before date, etc. should be used first, even if those items were received after a similar item in inventory. RAs should maintain records of when products are received and exercise effective inventory management and proper storage practices to ensure freshness. For further guidance and regulatory requirements, refer to 7 CFR, Section 250.14(b). Additionally, USDA Foods processors, distributors, and RAs that receive shipments directly from USDA vendors should also refer to Food and Nutrition Service Instruction 709-5, Revision 2: Shipment and Receipt of USDA Foods on the USDA Food Distribution Program Instructions and Handbooks Web page at https://www.fns.usda.gov/usda-foods/shipment-and-receipt-goods-fns-instruction-709-5 for supplemental guidance on the receipt and storage of USDA Foods.

The following sections clarify the meaning of date codes that may be found on USDA Foods in accordance with guidance provided by the USDA Food Safety and Inspection Service.

Product End Dates Definitions

Any of the following date codes could appear on retail or USDA Foods; however, they are not directly related to food safety. If handled improperly, the foods could lose quality prior to the date marked on the package. Most importantly, RAs should consume all USDA Foods before product end dates have passed.

• A best-if-used-by or best-if-used-before date indicates when a product will be of best flavor or quality.
  
  
• A use-by date is the last date the manufacturer recommends using the product while at peak quality.
  
  
• A sell-by date is also a product quality indicator and is the date by which the manufacturer recommends the food product is sold for inventory management purposes.

Pack Codes, Date of Pack, and Manufacturing Dates

A pack code, date of pack, or manufacturing date is a series of letters and/or numbers that indicates when the product was packaged, processed, or manufactured. For example, some USDA Foods, such as canned items, may contain manufacturing dates, which indicate when the products were produced. Certain USDA Foods fruits and vegetables, such as canned or frozen peaches, pears, green beans, and corn, may contain pack codes or a date of pack. Foods with pack codes or a date of pack are canned shortly after harvest and may be delivered throughout the following year or until the next harvest season. Thus, RAs may receive product packed or manufactured in the previous year (e.g., product packed in September 2017 may be delivered in July 2018).

Packing or manufacturing dates should not be interpreted the same as best-if-used-by or best-if-used before dates. While they may help determine the age of a product, these codes do not necessarily provide useful information on product wholesomeness or nutritional value. For products that only have packing or manufacturing dates rather than best-if-used-by dates, RAs should maintain records of when products are received and exercise effective inventory management and proper storage practices to ensure USDA Foods are consumed in a timely manner and in optimal condition.

Foods with Special Handling Requirements

Certain types of USDA Foods such as dried fruits, grain products, yogurt, and string cheese are more sensitive to storage conditions. These types of items should be stored in a cool, dry place, or at refrigerator or freezer temperatures as applicable, and should be consumed as soon as possible after receipt. If handled improperly, these items may spoil prior to the dates voluntarily marked on cases or containers. Please refer to the USDA Foods fact sheets for specific storage requirements for these types of USDA Foods, which are on the USDA Food Distribution Web page at https://www.fns.usda.gov/fdd/nslp-usda-foods-fact-sheets.

Out-of-Condition Foods

Out-of-condition foods are foods that are no longer fit for human consumption as a result of spoilage, contamination, infestation, adulteration, or damage. If there are no visible defects but there is a question as to the wholesomeness of the foods, RAs must have the foods inspected by local health authorities, as necessary, to ensure the foods are still safe. If it is determined the out-of-condition foods are USDA Foods, RAs must follow food recall and complaints procedures, as applicable, and ensure that out-of-condition USDA Foods are removed, destroyed, or otherwise disposed of, in accordance with 7 CFR, Section 250.15, USDA instruction and local requirements pertaining to food safety and health.

General Resources

Information on food product dating are found on the USDA Food Safety and Inspection Service Food Product Dating Web page at https://www.fsis.usda.gov/wps/portal/fsis/topics/food-safety-education/get-answers/food-safety-fact-sheets/food-labeling/food-product-dating/food-product-dating

Information on how to file a USDA Foods complaint is on the USDA Food Distribution Program Web page at https://www.fns.usda.gov/fdd/how-file-complaint and on the California Department of Education Food Distribution Program MB 04-405: USDA Commodity Complaints Web page at https://www.cde.ca.gov/ls/nu/fd/mb04405.asp.

Contact Information

For questions regarding this subject, please contact Amy Bell, Child Nutrition Consultant, Food Administration Unit, by phone at 916-322-5051 or by email at abell@cde.ca.gov.