Here's an example of excessive regulation hampering business

Paulie

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I'm trying to start a mobile retail food business in NJ. The requirements for the mobile business are more stringent than the stationary business, most notably that in addition to the 3 compartment sink and separate hand washing sink on the mobile unit, I must also have an established and approved "servicing area" that also has a 3 compartment sink and a separate utility sink or "mop sink" as the health dept. calls it, for disposal of mop water and other liquid waste and for cleaning and sanitizing all cleaning equipment.

All the requirements on my mobile unit are simple and pretty cost effective for me, I have already priced out what I need and everything so far is within my budget.

The problem is the "servicing area". The service area can not be a private residence, it has to be what they refer to as a "detached or attached garage" or something similar, used for such things as vehicle and
equipment cleaning, discharging liquid or solid wastes, refilling water tanks and ice bins and boarding food.

This makes no sense to me. I could just get a second 3 compartment sink unit and also install a single sink unit for the mop/utility usage. I could maybe see where the food storing part comes into play, but I don't see why there needs to be some separate location for this when I can just as easily store it all on the unit itself in the fridge and other locations where food would be while I'm open and selling food.

This separate location can be an already established restaurant if not my own "detached or attached garage". It wouldn't be within my budget to rent some kind of location to be the servicing area, so my only option is to find a restaurant owner who would be willing to allow his kitchen to be my designated servicing area. I'm sure I could find someone willing, probably for a fee of who knows how much, considering they know I need it.

My hope is to find someone willing to do it for around $1000 or maybe barter for any painting they might need done as I also own a painting business. And I would also advertise their restaurant on my mobile unit.

I just think this is excessive and unnecessary. I can easily provide adequate sinks and cleaning abilities on the mobile unit. This servicing area part is really holding this back at the moment.
 

Ravi

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Not sure if I'm reading you right, but it sounds as if they want any cleaning operation kept separate from the food prep area?
 

midcan5

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Interesting and I admit complicated. I was watching 'No Reservations' a while back and a women served food out of the back of a truck, looked good. In Philly, the food police would be after her. Well maybe as we have lots of street vendors. Licensing and inspections has always been a pain, people often avoid them just so they don't have to put up with ridiculous rules. We did my son's basement, what a pain the inspectors were in Princeton when they moved and needed permits for sale. Downright silly stuff.

Cajun Country - Travel Channel
 
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Paulie

Paulie

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Not sure if I'm reading you right, but it sounds as if they want any cleaning operation kept separate from the food prep area?
Not exactly. The mobile unit is required to have a 3 compartment sink, and another sink for hand washing. That's pretty much it as far as sanitation, besides the surfaces of the unit needing to be smooth and non-porous for easy cleaning.

So if they're already saying I can clean utensils on the unit, why do I need a separate location where I would also be cleaning utensils? The separate location also has to have a 3 compartment sink, plus the mop sink.

I can just have another 3 compartment sink on the mobile unit and a mop sink, and keep them separate from where I would prep food.
 

Ravi

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Not sure if I'm reading you right, but it sounds as if they want any cleaning operation kept separate from the food prep area?
Not exactly. The mobile unit is required to have a 3 compartment sink, and another sink for hand washing. That's pretty much it as far as sanitation, besides the surfaces of the unit needing to be smooth and non-porous for easy cleaning.

So if they're already saying I can clean utensils on the unit, why do I need a separate location where I would also be cleaning utensils? The separate location also has to have a 3 compartment sink, plus the mop sink.

I can just have another 3 compartment sink on the mobile unit and a mop sink, and keep them separate from where I would prep food.
Where are you getting this information? Maybe you are reading it wrong. It sounds to me from your initial post that you need an area elsewhere to clean your equipment, not your utensils.

I mean, you wouldn't want your mop sink to be a sink you used for food prep, would you?
 
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Paulie

Paulie

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Not sure if I'm reading you right, but it sounds as if they want any cleaning operation kept separate from the food prep area?
Here's the section in the regulation guide:

Servicing Area

Each mobile retail food establishment or transportation vehicle must operate from a base location
that is referred to as a Servicing Area. The Servicing Area is used for such things as vehicle and
equipment cleaning, discharging liquid or solid wastes, refilling water tanks and ice bins and
boarding food. The Servicing Area shall consist of:

1) A retail food establishment within Cape May County that is inspected yearly by the Cape May
County Department of Health:

a. The Cape May County Department of Health must approve the retail food
establishment for use as a Servicing Area
b. A “Servicing Area Certification for Mobile Retail Food Establishment” form must be
completed by both the owner of the retail food establishment and the owner of the
mobile retail food establishment.
c. Preparation of food IS allowed in a retail food establishment that is the approved
Servicing Area for the Mobile Retail Food Establishment

2) A detached or attached garage or other building (if allowed by your Local Zoning Board) that
contains the following:

a. A 3 compartment sink with hot/cold running water to each compartment. Drains must
be indirectly connected to the sewage system through the use of air gaps or air breaks.
b. A service sink (mop sink) for the disposal of mop water and other liquid waste and for
the cleaning of mops and other cleaning tools
c. Sufficient space for storage of all refrigerated/frozen foods, dry foods, paper products
and utensils/wares within the approved area. Dry storage of food, paper products and
utensils/wares must be 6 inches off the floor.
d. Indoor floor, wall and ceiling surfaces must be constructed of a non-absorbent material
e. Preparation of food is NOT allowed in a building that is not a retail food establishment,
but that is the approved Servicing Area for the Mobile Retail Food Establishment
My responses to this are: Vehicle cleaning can be done ANYWHERE. Equipment cleaning is already being done on the mobile unit at the 3 compartment sink Im required to have there. I'm only going to be using tongs, forks, spatulas, etc. Nothing bigger than that. Discharging wastes could be done at a separate sink unit, and refilling water could be done simply by bringing a bunch of water cooler type bottles with me. The sink units are already equipped with everything needed as far as water supply, drainage, waste collection, heater, etc.

There's just no reason for having to have a separate location. It's almost a deal-breaker.
 
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Paulie

Paulie

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Not sure if I'm reading you right, but it sounds as if they want any cleaning operation kept separate from the food prep area?
Not exactly. The mobile unit is required to have a 3 compartment sink, and another sink for hand washing. That's pretty much it as far as sanitation, besides the surfaces of the unit needing to be smooth and non-porous for easy cleaning.

So if they're already saying I can clean utensils on the unit, why do I need a separate location where I would also be cleaning utensils? The separate location also has to have a 3 compartment sink, plus the mop sink.

I can just have another 3 compartment sink on the mobile unit and a mop sink, and keep them separate from where I would prep food.
Where are you getting this information? Maybe you are reading it wrong. It sounds to me from your initial post that you need an area elsewhere to clean your equipment, not your utensils.

I mean, you wouldn't want your mop sink to be a sink you used for food prep, would you?
Rav, you're not reading me right. I would have a 4 compartment sink unit that would satisfy the requirement of 3 compartments for utensil cleaning and 1 for hand washing. Then I would have an additional 3 compartment sink unit located away from that area, along with a single sink unit for mop usage.
 
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Paulie

Paulie

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I may have found my solution to this, I forgot I know a restaurant owner who would probably let me use his kitchen as my designated servicing area. But I still think this is just overboard on regulation. I understand needing to have equipment cleaning and food area cleaning separate from each other, but needing an entirely different stationary location for the servicing area is unreasonable.
 

Ravi

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To me it sounds like you need a place to store your vehicle and maintain it. I'm not really seeing a problem with that. I would certainly be more apt to buy food from a roach coach that doesn't hook up a hose to it's kitchen sink to wash said roach coach. Plus, you need a sanitary place to store extra food, paper goods, etc.

Maybe you'd be better off starting a business to house and service roach coaches.
 
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Ravi

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Not exactly. The mobile unit is required to have a 3 compartment sink, and another sink for hand washing. That's pretty much it as far as sanitation, besides the surfaces of the unit needing to be smooth and non-porous for easy cleaning.

So if they're already saying I can clean utensils on the unit, why do I need a separate location where I would also be cleaning utensils? The separate location also has to have a 3 compartment sink, plus the mop sink.

I can just have another 3 compartment sink on the mobile unit and a mop sink, and keep them separate from where I would prep food.
Where are you getting this information? Maybe you are reading it wrong. It sounds to me from your initial post that you need an area elsewhere to clean your equipment, not your utensils.

I mean, you wouldn't want your mop sink to be a sink you used for food prep, would you?
Rav, you're not reading me right. I would have a 4 compartment sink unit that would satisfy the requirement of 3 compartments for utensil cleaning and 1 for hand washing. Then I would have an additional 3 compartment sink unit located away from that area, along with a single sink unit for mop usage.
:confused: Are you doing all your food prep and storage on the truck?
 
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Paulie

Paulie

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To me it sounds like you need a place to store your vehicle and maintain it. I'm not really seeing a problem with that. I would certainly be more apt to buy food from a roach coach that doesn't hook up a hose to it's kitchen sink to wash said roach coach. Plus, you need a sanitary place to store extra food, paper goods, etc.

Maybe you'd be better off starting a business to house and service roach coaches.
No it's not about the vehicle. The vehicle can be stored anywhere. It's about the cleaning equipment and the food storage. In my case it's going to be a pontoon boat. The health dept. said it's fine to keep it in a boat slip. The servicing area is for cleaning equipment, disposing waste, and storing food. I get the storing food part, but why can't the food just be stored on the boat? Whats the difference? A refrigerator is a refrigerator. If the boat is already sanitized as per the regulations, whats the problem with storing the food there?
 
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Paulie

Paulie

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Where are you getting this information? Maybe you are reading it wrong. It sounds to me from your initial post that you need an area elsewhere to clean your equipment, not your utensils.

I mean, you wouldn't want your mop sink to be a sink you used for food prep, would you?
Rav, you're not reading me right. I would have a 4 compartment sink unit that would satisfy the requirement of 3 compartments for utensil cleaning and 1 for hand washing. Then I would have an additional 3 compartment sink unit located away from that area, along with a single sink unit for mop usage.
:confused: Are you doing all your food prep and storage on the truck?
Yes. Food prep is allowed on the mobile unit, and food would be stored in the already required refrigerator.

I'm only going to be selling hot dogs and burgers. They will be stored in the fridge/freezer, and cooked on the grills.

This is all allowed on the mobile unit, which is why I don't understand needing the separate servicing area.
 

Ravi

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To me it sounds like you need a place to store your vehicle and maintain it. I'm not really seeing a problem with that. I would certainly be more apt to buy food from a roach coach that doesn't hook up a hose to it's kitchen sink to wash said roach coach. Plus, you need a sanitary place to store extra food, paper goods, etc.

Maybe you'd be better off starting a business to house and service roach coaches.
No it's not about the vehicle. The vehicle can be stored anywhere. It's about the cleaning equipment and the food storage. In my case it's going to be a pontoon boat. The health dept. said it's fine to keep it in a boat slip. The servicing area is for cleaning equipment, disposing waste, and storing food. I get the storing food part, but why can't the food just be stored on the boat? Whats the difference? A refrigerator is a refrigerator. If the boat is already sanitized as per the regulations, whats the problem with storing the food there?
Not sure, but one problem I see is that if you have bought in bulk and are keeping items refrigerated long term then keeping them in a fridge you go in and out of constantly could compromise shelf life and food safety.

Have you actually asked these questions of your health department?
 
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Paulie

Paulie

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To me it sounds like you need a place to store your vehicle and maintain it. I'm not really seeing a problem with that. I would certainly be more apt to buy food from a roach coach that doesn't hook up a hose to it's kitchen sink to wash said roach coach. Plus, you need a sanitary place to store extra food, paper goods, etc.

Maybe you'd be better off starting a business to house and service roach coaches.
No it's not about the vehicle. The vehicle can be stored anywhere. It's about the cleaning equipment and the food storage. In my case it's going to be a pontoon boat. The health dept. said it's fine to keep it in a boat slip. The servicing area is for cleaning equipment, disposing waste, and storing food. I get the storing food part, but why can't the food just be stored on the boat? Whats the difference? A refrigerator is a refrigerator. If the boat is already sanitized as per the regulations, whats the problem with storing the food there?
Not sure, but one problem I see is that if you have bought in bulk and are keeping items refrigerated long term then keeping them in a fridge you go in and out of constantly could compromise shelf life and food safety.

Have you actually asked these questions of your health department?
I can see that, but then why can't I just have another fridge on board that I only use for the longer term storage?

And no, there's no point in question regulations because you already know they're not going to change them. I dealt with this same kind of crap when starting that preschool last year. Same shit...a bunch of regulations that really didn't make sense.
 

Ravi

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No it's not about the vehicle. The vehicle can be stored anywhere. It's about the cleaning equipment and the food storage. In my case it's going to be a pontoon boat. The health dept. said it's fine to keep it in a boat slip. The servicing area is for cleaning equipment, disposing waste, and storing food. I get the storing food part, but why can't the food just be stored on the boat? Whats the difference? A refrigerator is a refrigerator. If the boat is already sanitized as per the regulations, whats the problem with storing the food there?
Not sure, but one problem I see is that if you have bought in bulk and are keeping items refrigerated long term then keeping them in a fridge you go in and out of constantly could compromise shelf life and food safety.

Have you actually asked these questions of your health department?
I can see that, but then why can't I just have another fridge on board that I only use for the longer term storage?

And no, there's no point in question regulations because you already know they're not going to change them. I dealt with this same kind of crap when starting that preschool last year. Same shit...a bunch of regulations that really didn't make sense.
I meant more did you ask them WHY these regulations exist? What is their explanation?

Another state defines a service area as also the place where fresh water is obtained every day.
 

Ravi

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It's also possible that somewhere in the law there is an exemption. In Wisconsin, if you can demonstrate that proper care and sanitation is possible without a service base they will waive it for you.

I'd call and ask before you plunk down the cash to rent.
 
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Paulie

Paulie

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It's also possible that somewhere in the law there is an exemption. In Wisconsin, if you can demonstrate that proper care and sanitation is possible without a service base they will waive it for you.

I'd call and ask before you plunk down the cash to rent.
Thanks for finding that, I'll see what I can get out of them then.

As far as the fresh water thing, an easy solution is to bring a couple water cooler type bottles on with me before I go out for the day. The sink unit holds 5 gallons of fresh water, which I'm pretty sure I wouldn't be using only cleaning a couple cooking utensils and my hands throughout the day. That's a lot of water.
 

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