Comments and Suggested Remedies on the Proposed Changes to Article III Food Safety Regulations

By January 31, 2022Article

After 22 years, with the changes, innovation and emerging trends within the food industry, it is timely that the ACHD Food Safety Program is making changes to these regulations.

The comments and remedies below are focused on the changes as it impacts our industry-leading work in the region. 

We have also included the transcripts of statements made during the Allegheny County Food Safety Program Public Hearing on January 20th, made by myself and 412 Food Rescue Senior Director Jennifer England; our nonprofit partners as represented by Dr. Beverly Moore, Deputy Director of the Allegheny County Housing Authority and Michelle Sandidge, Chief Communications Officer of the Housing Authority of the City of Pittsburgh; our volunteer drivers as represented by Lorien Benet Hart, Joann Aurand and John Boerger (who drives for both 412 Food Rescue and a for-profit, commercial food delivery company). We have also referenced statements made during the same hearing by Daniel Donovan, Giant Eagle’s Chief Communications Officer. 

These testimonies provide ample pre-amble and disambiguation of the 412 Food Rescue process, as underpinned by the Food Rescue Hero technology platform – created by our organization and has grown to be the leading volunteer food transport coordination technology for surplus and donated food. We would be more than happy to provide a demonstration as well as a side-by-side comparison of the process between our technology and commercial food delivery such as Amazon, Instacart, UberEats, etc. 

Allegheny County Executive Rich Fitzgerald’s food rescue from Giant Eagle delivered to an Allegheny County Public Housing site–as referenced in Dr. Beverly Moore’s testimony–can also be viewed on YouTube at this link: https://youtu.be/JdXUDXa7fT0

We can provide valuable insight on federal and state trends as it relates not only to food donation transport but the overarching technology-enabled, point-to-point food logistics industry, of which we are part. At the minimum, along with the Food Policy Council, we respectfully request to see the revisions before it is presented to the Board of Health for approval. 

We have been consulted in drafts of Federal legislation on food donation currently being considered in Congress and participate as advisors in various national organizations in the food recovery and logistics space, such as ReFed. Our technology use grows in California where the landmark SB1383 bill has been enacted. 

To truly be in lockstep with the emerging trends in food and responsible innovation, we would like to offer our expertise in technology and logistics to avoid–unintended–unequal standards between for- and non-profit food delivery service regulations. Our guiding philosophy is that safe food is everyone’s right and nonprofit technology companies such as 412 Food Rescue and Food Rescue Hero have the same operating design and standards as for-profit services. Nonprofit does not translate to “less” in any way, which these regulations, by virtue of focusing on only one sector and not the other, makes this implication. 

It is important to note that because our technology, Food Rescue Hero, is currently being used in 16 cities in North America and slated to grow to 100 cities by 2030, these regulations will not only affect local operations but is a precedent that is being watched closely by other cities and will reverberate internationally. 

Thank you,

Leah Lizarondo
CEO and Co-Founder, 412 Food Rescue
Founder, Food Rescue Hero

 

SECTION 300. PURPOSE AND SCOPE 

The purpose of this Article is to safeguard public health through the application of the principles of food safety, foodborne illness prevention and environmental health in food facilities.

The safeguard to public health must encompass all citizens and we feel that these regulations, as written, puts specific penalties on food donation and only nonprofit-focused food delivery, and risks lack of clarity on its equitable intent. 

REMEDY: The same standards and regulations currently being applied to commercial food delivery services-not covered in these articles-should be applied to nonprofit food delivery services that use the same process and control measures. 

SECTION 331 302. FOOD PROTECTION

302.1 General 

  1. A. At all times, including while being stored, prepared, displayed, served, dispensed, packaged, or transported, food shall be protected from cross-contamination between foods and from potential contamination by insects, insecticides, rodents, rodenticides, chemicals, unclean equipment and utensils, unnecessary handling, flooding, draining, and overhead leakage or condensation, sewage, or other agents of public health significance. The temperature of potentially hazardous food TCS food shall be maintained at 47 41°F or below, or 135°F or above, at all times, except as otherwise provided in this Article.

Aside from temperature, TIME is an accepted food safety control standard. It is what we, and most commercial food delivery systems use, and our technology allows us to monitor trip length and intervene when unsafe boundaries are reached. (More on this in the comments on Section 335. Also please see Leah Lizarondo testimony transcript on average delivery time – 27 minutes.) 

Further, FDA Food Code §3-501.19, TIME as a Public Health Control, affords a 6-hour time window (as revised with the 2017 code) for chilled food starting below 41° and a 4-hour time window for food held at or above 135°. Merely within that parameter, food rescued by volunteers is within that federal guideline, negating any need to enhance the guidance.

REMEDY: Time should be included as an acceptable food safety measure. 

332.5 Date Marking of Food Ready-to-eat 

TCS food prepared and held refrigerated for more than 24 hours in a retail food facility shall be clearly marked at the time of preparation to indicate the date by which the food shall be consumed on the premises, sold or discarded, which is, including the day of preparation, seven (7) days or less from the day the food is prepared, if the food is maintained at 41°F or less. The day of preparation shall be counted as “Day 1.

Please see our comment below on the move toward the rationalization (not added proliferation of) date labeling on food as it causes consumer confusion and increases food waste. 

SECTION 335. DONATION OF FOODS 

Once served or sold to a consumer, unused portions of or left-over food, shall not be offered as food for human consumption except as otherwise provided in this section.

335.2 Unpackaged and unserved foods.

Unpackaged and unserved foods may be donated if the following requirements are met.

It is unclear what this applies to. Whole fruits and vegetables? Bread and baked goods? Prepared food? The requirements suggest it is referring to TCS prepared food but is vague and could lead food establishments to worry that they will violate the article because it is ambiguous. eg. donating bread that hasn’t been held cold.

REMEDY: Clearly enumerate what types of food this does and doesn’t apply to. If it means TCS prepared food from a commercial kitchen, ie. catered food, it should be clearly identified. Otherwise, we recommend striking this from the articles.

  1. The temperature of the food is at or below 41° Fahrenheit, or an ambient temperature of 45° Fahrenheit for raw shell eggs, at the time of donation, and is protected from contamination;

 

  1. The food has been at or above 135° Fahrenheit during hot holding and service, and subsequently refrigerated to meet the time and temperature requirements in § 332.3, or maintained at proper holding temperatures required in § 332.4;

This ONLY makes sense when referring to certain food types but the wording in 335.2 is broad it would seem to apply well beyond TCS foods.

  1. The donor can substantiate that the food recipient has the facilities to meet the transportation, storage, and reheating requirements” of the article; and

In his testimony on January 20th, Daniel Donovan, Chief Communications Officer for Giant Eagle, attested to the quality control and food safety standards the company takes for both food that it sells and donates. All of our food donors share the same values. 

This regulation is problematic for a number of reasons:

  • Puts the onus and penalty on food establishments (the source of food) for certifying END-USE – which is unreasonably burdensome (if not impossible), hence, will ensure the decline of incentive to donate surplus and other food. 

Whether handling purchased or donated food – to put the burden on food establishments to substantiate the capacity of end-users and predict end-user behavior is unreasonable, an overreach and would put unnecessary risk of penalties on the food establishment.  (See above)

  • This is contrary to the spirit of the Bill Emerson Act and furthermore, runs counter to the bipartisan Federal bill currently being proposed by Senators Toomey and Blumenthal which would allow donors to give food directly to individuals.
  • This does not consider the new models of food delivery – purchased or donated – where there is a large logistics network between food establishment and recipient – whether an intermediary organization or direct to homes. The connection between food establishments and end-users is not a direct connection as it has been in the past. 

Even in a traditional food banking model, the donor depends on the vetting of the food bank for the ultimate destination of the food that is donated. 

The rise of new modes of delivery (purchased or donated food) has made this direct connection even more unnecessary but at the same time has allowed food to reach more people – even those who cannot get to a traditional food pantry because of lack of mobility, transportation, disability and other limiting factors. 

  • This regulation also prevents much of the food distribution that has been necessary during the pandemic such as POP-UP distributions at school bus stops, stadiums and other venues. In any crisis, these non-traditional (food) facilities are used as food distribution points. 

412 Food Rescue’s 1,500 food distribution network encompasses both traditional and non-traditional food sites. 

Further, the trend of food distribution and access (again, whether purchased or donated) has been to ensure that food goes to where it is most convenient to the end-user. The days of food being available only at traditional sites such as restaurants, cafeterias, soup kitchens or traditional food pantries etc. are long gone. 

Innovative food distribution and food recovery networks are now able to distribute food in non-traditional locations (such as public housing, community health centers, etc.), bringing food accessibility and reach to more people, more than ever. Limiting distribution will reverse positive and responsible progress made toward alleviating hunger – in the pandemic and beyond. 

REMEDY – this provision should be stricken. The responsibility of the food establishment – whether handling purchased or donated food – is to follow safe handling practices at their location, which they have full control of. Any assumption of control beyond their establishment is unreasonable and placing this responsibility on food establishments will result in restriction of donated food. 

  1. The food is to be transported by the food recipient directly to a consumer, the recipient only needs to meet the transportation requirements in this section, including holding temperatures.

The wording is extremely ambiguous, confusing on identifying recipient/consumer, and unclear on what it is requiring. What is a food recipient? What is a consumer? What assumptions are being made about use at destination?

Assumptions are being made at destination/consumer. In preceding meetings and conversations, assumptions were made that purchased food is “meant” to be consumed right away. The time groceries are left at a porch cannot be tracked by a store. 

Current trends in logistical process for purchased and donated food is as follows:

Food establishment >> food transport >> recipient (possibly an intermediary such as a soup kitchen, food pantry, housing site) or consumer. 

Again, the onus should not be on the originating food establishment to be responsible at the destination of the food. The donor’s responsibility is for safe handling of food at their site. 

The logistics process above applies to both purchased and donated food. These restrictions are only placed on donated food, which means erroneous assumptions are being made that food transport for either one is different. 

Commercial and nonprofit food delivery services largely and effectively control for food safety using TIME not temperature. There are no such regulations for food establishments that use commercial food delivery services to transport purchased food. 

Our process design and food safety controls are similar to these companies.

REMEDY – this provision should be stricken. 

335.3 Labeling 

Donated foods transported offsite shall be labeled with the name of the food, the source of the food, the date of preparation, and the discard date.

We believe that requiring “date of preparation” is redundant if the “discard date” is indicated and previous requirements state this clearly. 

This also runs counter to the Food Date Labeling Law that is aimed to be reintroduced in Congress. The addition of MORE dates in food packaging will be disallowed based on the provisions of that law. The proliferation of dates in any food packaging is one of the leading causes of food waste. The rationalization of these dates will reduce wasted food. 

There is tremendous support for simplifying and rationalizing date labeling. Beyond this law, industry standards are moving toward a quality date using “Best by” and a food safety date using “USE BY.” 

REMEDY: We encourage ACHD to adhere to this emerging standard by redacting “date of preparation” as a requirement. 

335.4 Shelf Life 

Donated TCS foods may not exceed the shelf life for leftover foods outlined in Section 332.5 which states that “TCS food prepared and held refrigerated for more than 24 hours in a retail food facility shall be clearly marked at the time of preparation to indicate the date by which the food shall be consumed on the premises, sold or discarded, which is, including the day of preparation, seven (7) days or less from the day the food is prepared, if the food is maintained at 41°F or less. The day of preparation shall be counted as ‘Day 1.'” 

This indicates a different date labeling standard for sold food v. donated food (outlined in  335.3) which is potentially confusing and discouraging for the donor. 

REMEDY: Sold food and donated food standards should be aligned. This should be stricken or consistency with standards for sold food should be referenced. 

335.5 Damaged Foods  

Heavily rim or seam-dented canned foods, prepackaged foods with compromised packaging, or packaged foods without the manufacturer’s complete labeling shall not be donated.

This is vague and is potentially overly restrictive compared to the guidelines of Food Rescue Hero (and Feeding America) that are specific to the type of “packaging damage” that is acceptable. 

That is, a substantial amount of food is donated because the outer packaging is damaged and cannot be sold. In some cases, where the food-contact packaging is intact, food may be able to be donated. 

In some cases where one packaged item in a case is severely damaged (and removed) the rest of the case is perfectly safe and donateable. For example, a case of cereal where the outer packaging is damaged and one box inside is damaged but the rest remain intact. Or a case of energy bars where one bar has a missing label.

Donors donate those items because they cannot be sold but most of the food in the case is donatable. 

The statement “without the manufacturer’s complete labeling” is also vague and prohibitive. What specifically on the label needs to be included? And is it acceptable for it to be missing from an outer case if the inner units are intact?

The lack of clarity in these guidelines will cause an enormous amount of perfectly good food to be wasted. 

REMEDY: Existing standards used by 412 Food Rescue, Feeding America and others should be used. They should clearly define what type of damage renders packaged food unacceptable. Both organizations can provide these upon request. 

335.6 Distressed Foods 

Foods which are considered distressed, such as foods which have been subjected to fire, flooding, excessive heat, smoke, radiation, other environmental contamination, or prolonged storage shall not be directly donated to the consumer. Such foods may be sold or donated to a permitted food salvage facility.

Foods that have been environmentally contaminated are different from foods that have been subject to prolonged storage. Long storage is not a food safety issue and should not be included. In cases where it might present a food safety concern, it should be specified.

REMEDY: Prolonged storage should be removed from this section.

SECTION 336 FOOD TRANSPORTATION 

336 306.1 General 

The requirements for storage, display, and general protection against contamination, as contained in this Article shall apply in the transporting of all food from a food facility to another location for service, catering, or donation operations. All potentially hazardous food TCS food shall be kept at 41°F or below, or 135°F or above, during transportation. Adequate approved equipment must be used for maintaining food product temperatures. 

It is unclear whether “this Article shall apply in the transporting of all food from a food facility to another location for service, catering, or donation” covers ALL third-party food transportation services. 

Our inquiries with the Food Safety Program have met this response: 

We quote – “Food delivery services should be delivering food from permitted food facilities to the end consumer.” 

Our delivery services deliver to both end consumers and short-term intermediaries such as food pantries, soup kitchens, public housing sites, etc. 

FURTHER, we (and the food bank) have worked with commercial food delivery services to deliver food from food establishments to households and the same intermediaries. 

Assumptions cannot be made on end-use intent. Sometimes, restaurants do not even know that orders are for third-party delivery services like DoorDash or Grubhub until those customers call to complain about their orders.  (Andrew Kenney, Restaurants Are Fed Up With GrubHub and DoorDash, And Now Legislators Are On Their Side, CPR News (May 19, 2021).) In these cases, drivers will sometimes place orders when they arrive at the restaurant, which may make it appear to the restaurant like they are handing food directly to the consumer rather than to an intermediary where additional time and temperature regulations come into play.  

Our general view is that the largest emerging trend in the food space is largely ignored (or extremely unclear as to how they are regulated) in the changes to these regulations EXCEPT as it relates to donation. Food delivery – whether restaurant food or groceries and other food – has grown over the last three years. 

1 in 4 online grocery orders are deliveries (this is a mix of ambient, cold and frozen food). Sources have shown that 1 in 3 households have had food delivered during the pandemic and the sector will only continue to grow. 

PRIMARY REMEDY: Strike Section 336 as the REMEDY for Section 331 already recommends TIME as an acceptable public health control in food transport. 

SECONDARY REMEDY: Include TIME as an acceptable public health control for ALL food transported via third-party delivery services, whether purchased or donated. 

Discount unverifiable end-use intent and end-use assumptions and bring equity to the code by using uniform and standard regulations to any third-party delivered food and food delivery services. If regulations are not required for commercial third-party delivery services, then regulations are not required for donated food delivery services. The lines between the two can be ambiguous. Both uphold the same food safety standards. 

SECTION 350. FOOD SAFETY ADVISORY COMMITTEE There is hereby established a Food Safety Advisory Committee which may recommend to the Board of Health additions and changes to this Article and advise the Department and the Board of Health on matters relative to food safety which are brought to its attention by any person.

REMEDY: The Food Safety Advisory Committee should include representatives from 412 Food Rescue as well as a member of a commercial delivery service as these are the largest emerging trends in the food space and should be represented in the committee overseeing these changes.

Support from Partner Nonprofit Distributors

We have asked select members of our nonprofit distribution partners, specifically nontraditional food sites-which run the highest risk of being prevented from being able to distribute food under these new regulations–to submit signatures of support to 412 Food Rescue, our process and safety standards. If the Food Safety Team deem it necessary, further requests can be made.

Organization Name Organizational Support Individual Support
Allegheny County Housing Authority Beverly Moore
Housing Authority of the City Of Pittsburgh Michelle Standidge
National Church Residences Nanci Lederman
Good Food Project Greg Austin
McKeesport Agape Center Kelly Doyle
Washington Christian Outreach Debbie Broadly
Food Helpers George Omiros
Victory Family Church Pastor Chris Palmer
Parkside Manor Jen Hadly + 26 Resident [recipient] signatures
Hugh Lane Foundation Sarah Rosso
Wilkinsburg Community Ministry Ruth Kittiner
I.W. Abel Place Philip Hamlin
Ciss House of Hope Ministries Linda Fulmer
Children’s Hospital Pittsburgh Family Support Center Jodi Krall
Children’s Hospital Pittsburgh Family Support Center Danielle Thum
Children’s Hospital Pittsburgh Family Support Center Abigail Carpenter
Children’s Hospital Pittsburgh Family Support Center Stephanie Spreling
Children’s Hospital Pittsburgh Family Support Center Kristin Hannibal
Children’s Hospital Pittsburgh Family Support Center Molly Carney
Children’s Hospital Pittsburgh Family Support Center Anne-Marie Rick
Children’s Hospital Pittsburgh Family Support Center Carly Bouch
Children’s Hospital Pittsburgh Family Support Center Ryan Malave
Children’s Hospital Pittsburgh Family Support Center Noel Zuckerbraun
Children’s Hospital Pittsburgh Family Support Center Robert Hickey
Children’s Hospital Pittsburgh Family Support Center James Bonhoff
Children’s Hospital Pittsburgh Family Support Center Amanda Lovallo
Children’s Hospital Pittsburgh Family Support Center Dakota Peterson
Children’s Hospital Pittsburgh Family Support Center Jasmine Sondhi
Children’s Hospital Pittsburgh Family Support Center Ann Condon-Meyers
Children’s Hospital Pittsburgh Family Support Center Mavis Britwum
Children’s Hospital Pittsburgh Family Support Center Theresa Barrett
Children’s Hospital Pittsburgh Family Support Center Katheryn Schloss

Statements Presented During Hearing on January 20, 2022

Jennifer England – 412 Food Rescue

Good evening, my name is Jennifer England and I am the Head of City Partnerships for 412 Food Rescue. I’m speaking today about the proposed regulation changes to Article III.   

Food Rescue Hero is the largest volunteer food rescue organization in the world and it was founded right here in Allegheny County as 412 Food Rescue. 

Our core belief that informs our mission is that EVERYONE deserves access to safe, healthy, AND convenient food.

Thanks to thousands of volunteer food rescue heroes, our model of food recovery and redistribution prevents perfectly good food from entering the waste stream and brings healthy food directly to people who need it.  

We have successfully delivered 20 million pounds of food in the Pittsburgh community and more than 80 million pounds in 16 cities in North America.  We are able to do this through Food Rescue Hero, which is a technology platform and mobile app that mobilizes volunteers to transport surplus food to those who can use it.  

The Food Rescue Hero app addresses the logistical challenges of food rescue through community-powered networks. Volunteer drivers are alerted when surplus food is available to be picked up near them. 

Since its launch in 2016, the app has redirected more than 80 million pounds of perfectly good food from food donors to the people who need it instead of sending it to the landfill.  

As I mentioned, Food Rescue Hero was developed and launched in Pittsburgh and is now being used by hunger relief and food rescue organizations in Cleveland, Philadelphia, San Francisco, Northern Virginia, Los Angeles, Vancouver, and more.  As our technology continues to grow both nationally and internationally, our goal is to impact hunger in 100 cities by 2030.

I’m proud to say that 412 Food Rescue is viewed as subject matter experts on food recovery and have been consulted by several members of Congress. Senator Toomey’s office contacted us when the Senator began working on bipartisan legislation- along with Senator Blumenthal- that would expand federal protections for food donations as well as Representatives Pingree & Newhouse when they introduced legislation in the House of Representatives that also aims to increase food donations by strengthening liability protections and rationalizing date labeling standards. These bills are before congress currently.

We are thankful to have had the opportunity to share our experiences and knowledge in this kind of complex policymaking — we hope to have the opportunity to continue sharing this knowledge locally with our partners in Allegheny County.

After reviewing the proposed regulations, we feel that they do not make donated food safer, but rather make it harder to donate food.  Our local donor base continues to grow year over year and as of today we have more than 1500 food donors right here in Allegheny County – these donors trust our standards and processes to deliver their donated food safely. Giant Eagle, Whole Foods, Trader Joes, Shop n Save, University of Pittsburgh, UMPC, CMU and 400 restaurants–just to name a few all have vetted our services and believe we provide a guarantee of safe, convenient access to donated foods.  We look forward to working with ACHD to ensure that everyone has access to safe, healthy, AND convenient food.

Leah Lizarondo – 412 Food Rescue

My name is Leah Lizarondo and I am the co-founder and CEO of 412 Food Rescue and the founder of the Food Rescue Hero app. 

We strongly believe that the people we serve deserve good, healthy, SAFE food. 

As you heard from our volunteers, our process is very simple and similar to the for-profit food delivery services. We work with ServSafe, ACHD certified food establishments to donate surplus food, we match the food with nonprofits who serve food insecure populations and during COVID, launched a home delivery service that we expect to grow. Our volunteer drivers download our app and are notified of food that is available to rescue. The app guides them through the process of pick up and delivery. 

Our dispatchers are ServSafe certified and ensure that TCS food is matched with a nearby, food safe trained nonprofit (or directly to a home) that has opted in to the donation, understands what it is and can use it accordingly–whether immediately or for later use.

We are very proud to say that with more than 25,000 registered Food Rescue Heroes in the US and Canada, and over 300,000 deliveries locally, we have ZERO food safety incidents. Including the 100,000 meals we delivered from local restaurants–funded by Allegheny County in 2020. In fact, there has been zero case law nationally from donated food. 

Our entire process AND our technology are designed to bring people in need the same access, convenience, quality and safety as everyone else. 

There are two industry standards to control for food safety-time and temperature. We and commercial food delivery services largely control for TIME. The ACHD has made some positive changes on the requirement of temperature control for safety during transport which would have crippled our operations. They have now added TIME as an acceptable food safety control at transport–which we support. 

Of note is that our average trip is 27 minutes, 90% under an hour. Well under the 4 hour industry standard. Our technology monitors delivery time closely and can flag deliveries at risk so they can be addressed. 

We deliver food as safely as any commercial, for-profit delivery service – whether it is prepared food or food from groceries. I do want to note that these regulations on food transport only apply to nonprofit services like ours. 

There are other changes that give us concern, such provisions that may limit our ability to bring food to nontraditional food access sites such as public housing; date labeling standards that will add difficulty for donors; unclear language on what constitutes food that cannot be donated and others. We do not want to see an increase in food insecurity and a return to the food emergencies in public housing that has been eliminated. 

We look forward to continuing to work with the ACHD to ensure we deliver millions of fresh meals a year to reach over a quarter of a million people in need in our region. And continue to be the global leader in technology-enabled, people-powered food recovery. 

Michelle Sandidge – Chief Community Affairs Officer – Housing Authority of the City of Pittsburgh

I’m Michelle Sandidge, Chief Community Affairs Officer at Housing Authority of the City of Pittsburgh. 412 Food Rescue is a vital partner, providing healthful food to our food insecure residents that in many cases have zero other options. 

My organization develops and makes available affordable, safe housing and helps families in the Pittsburgh region achieve independence. We currently house more than 18,000 Pittsburghers, manage more than 2,200 public housing units, and provide oversight of an additional 600+ mixed-finance units.

Since we started working with 412 Food Rescue in 2015, our partnership has connected thousands of low-income families with regular access to approximately 1.5 million pounds of fresh, healthy food while creating a national model for food rescue and delivery services.

We have received nearly 10,000 food deliveries from 412 Food Rescue volunteers, totaling 1.5 million pounds of food – the equivalent of more than 1.1 million meals. The total amount of delivered food has an approximate retail value of more than $3.4 million.

Approximately 73% of our residents live below the poverty line and many of them do not have regular, reliable access to food without 412 Food Rescue. Historically, our housing communities have averaged 5 to 7 emergency referrals for families without food each month, but since just six months after we began our partnership with 412 Food Rescue, we have received ZERO such calls. Put another way, our collaboration with 412 Food Rescue has effectively ENDED HUNGER in our public housing communities.

We attribute this dramatic success specifically to the ongoing efforts and new delivery-first model of 412 Food Rescue. 

Our team has experienced 412 Food Rescue to be meticulous when it comes to the handling of food they provide. Our site coordinators (the people on site at our buildings that receive the deliveries from 412 Food Rescue volunteer drivers) receive ServSafe training, and distribute or safely store the donated food right away. They also learn how to portion, store, handle and distribute food safely. 

I believe that if the proposed ACHD changes move forward as written, severely limiting 412 Food Rescue’s ability to transport food directly from food donors to our site, emergency calls for food will return and our residents’ health will be at risk. We rely on 412 Food Rescue to provide fresh fruits, vegetables and other perishable items that we simply cannot get anywhere else – and limiting our residents’ ability to access those foods will be devastating to them and to the larger Pittsburgh community.

Dr. Beverly Moore – Deputy Executive Director – Allegheny County Housing Authority

I’m Dr. Beverly Moore, Deputy Executive Director of Allegheny County Housing Authority. Our mission is to provide safe and decent affordable housing for low-income residents of Allegheny County. 

I approached 412 Food Rescue directly in 2015 because I saw the potential of the organization’s ability to provide fresh food to the people we serve, approximately 75% of which live below the poverty line, and many of which are food insecure, meaning that they do not have reliable access to a sufficient quantity of affordable, nutritious food.

Since 2015, we have received roughly 2 million pounds of food via 412 Food Rescue, through approximately 7,000 rescues. The impact has been far deeper than addressing hunger. It has built community, camaraderie and hope among our residents. 

412 Food Rescue maintains a gold standard in food handling, going above and beyond to be sure that the food we receive is high quality and properly handled throughout the process, including by our on-site volunteers who receive specific training.

Here’s an example of a program that we benefited from that would have been impossible under the proposed new regulations: the Community Takeout program, created in response to the difficulties local restaurants have faced as a result of the COVID-19 pandemic. Since the spring of 2020, the program has delivered 230,000+ meals to neighbors in need by providing funding to 53 restaurants and catering businesses throughout Allegheny County to create portioned meals, similar to what someone might order from a restaurant through DoorDash. 412 Food Rescue volunteer drivers transported the meals directly to the food insecure, including many who live in our buildings. The program’s estimated economic impact on the region is more than $1.7 million.

Of the program, County Executive Rich Fitzgerald said: “The Community Takeout program was a win-win for our community and we are grateful to 412 Food Rescue for its leadership with this initiative. The program supported our neighbors in need and helped support restaurants and catering businesses facing great uncertainty during the pandemic. It is only by working together that we can continue to address the challenges that we see in our community, and we’re grateful to everyone that played a part in this successful program.”

In 2019, Rich Fitzgerald also completed a food rescue from Giant Eagle in Kennedy Township to the Pleasant Ridge Housing Authority site in McKees Rocks, one of our sites. 

Our folks have really come to depend on this food. That $10 or more that they’re saving on groceries is currently going to other life-sustaining needs such as prescriptions or self care items, and the hardship that would result from taking that away, after the inflation and other challenges the pandemic has caused, would be devastating.

Lorien Hart – Musicians of the Pittsburgh Symphony Orchestra

My name is Lorien Benet Hart, and I am a violinist with the Pittsburgh Symphony Orchestra. The PSO is a full-time job, but with a schedule that changes weekly. We work evenings and weekends, which means that many volunteer opportunities that take place outside of traditional 9-5 work schedules aren’t accessible for us. 412 Food Rescue was made for people like me. There’s nothing else like it, where I can volunteer within an hour’s notice, on my own schedule, and make a direct, immediate contribution to my community.

In 2016, the Musicians of the PSO were looking for community outreach opportunities. I had heard about a new organization called 412 Food Rescue and got in touch to see if we could help. I rallied a small group of musicians, and we made our first delivery: a truckload of rescued food in McKeesport. 

That first food delivery made me realize that people experiencing food insecurity were craving dignity and nourishment – two things that are hard to come by going to traditional food pantries. The cost on a human soul of navigating shift job schedules and public transit to get to a food bank, to stand in line in the elements, and to receive canned food devoid of nutrients and flavor, is immense. 412 Food Rescue’s deliveries of fresh produce, bread, and meat are life-changing for folks experiencing one of the hardest times in their lives. 

After our first delivery, I was hooked. I told my colleagues about the experience, and we put together a program called Body & Soul – since 2016, 6-8 musicians at a time would deliver truckloads and carloads of food and play a concert for the recipients upon delivery. Since COVID, we have helped to deliver food but without performances. More and more musicians got involved, and now all of the Musicians of the PSO, plus many members of our staff and board have been on one of the hundreds of rescue trips.

Even as I worked with my colleagues on regular food deliveries, I needed to do more. On average, I’ve personally completed 508 food rescues per year since that first one in 2016. That’s 55,750 pounds of food delivered to people in need. A model that allows just one person to have that kind of direct impact on their community must be valued. 

If these proposed changes pass as written, it would mean putting all of that food back into the garbage, and that is devastating personally to my heart but even more devastating to the communities that 412 Food Rescue has elevated out of food insecurity. The numbers speak for themselves. It would be an enormous loss on progress we’ve made to increase human well-being and decrease our city’s carbon footprint.

412 has made international news through their work, and it would be detrimental  to the progress they have made in terms of food insecurity worldwide to have these regulations come in and put up roadblocks to getting food to people who need it.

John Boerger – Doordash Driver 

Good evening. My name is John Boerger, a resident of the Northside. 

I’m here to share my first hand experience as having driven for both Doordash and 412 Food Rescue – focusing on the process and shed light on how the two food transportation models are the same. 

First, to sign on to be a Doordash driver, you download the app, complete some basic information and identification as well as a background check. Once that is cleared, I am basically cleared to drive for the Company, getting information on pick-ups I can take on the app. There is no other step in between. 

I first heard about 412 Food Rescue on social media and the media and have always wanted to volunteer. In 2020, I finally signed up on the app. 

To sign on as a 412 Food Rescue driver is no different. You download the app, put in your information and complete a background check. The results come in about 5 minutes and you are cleared to do rescues. Your app will show you food rescues that are available and you can claim what you want, just like Doordash. 

Both sign up processes were quick and painless. 

When you do a pick up at a Doordash restaurant, the bags of food are typically left in a designated area – a table or shelf – regular tables and shelves, no special coolers and such. Sometimes I have to show my Doordash app to the restaurant, sometimes I don’t. I pick up the food and then drop it off with no contact – on the porch or front door. 

In my last pick up for 412 Food Rescue, I picked up the food in the Northside, close to where I live, and was given a route of 3 homes to drop off to. I arrived at 12:25 pm and my last drop off was completed by 12:55 – a half hour. The routes were created so that they were close together. 

The process of the pick up and packaging of the food was no different than what I had for Doordash, except there were also presents for the single mothers with the food I delivered. And of course for 412 Food Rescue, I was happily volunteering my time. 

And this pick up was especially close to me because I was raised by a single mom and this was for a nonprofit project called Single Moms Defined– a program that serves single mothers. 

So the whole process for both Doordash and 412 Food Rescue is the same-from how the technology works to how the pick up and delivery process was– really no different. Except of course for 412 Food Rescue, I was doing it to serve someone who needs support and it felt special to do that.