HACCP Compliance Begins with Your Equipment

The 1999 FDA Food Code for equipment and ANSI/NSF 4 - 1996 are clear with statements and design criteria for products. In both specifications it is concisely stated that all seams and joints are to be sealed and smooth with appropriate radii for cleaning and that no fasteners are allowed in the food zone. Legion builds all equipment - including the SkittleŽ Cooker, Combi-Pan™ Tilting Skillet, all kettles, braising pans and chafers - with welded and polished seams and absolutely no screws or fasteners in the food zone and splash zone.

Materials, Joints and Seams:

  • NSF §4.5 - Joints and seams in the food zone shall be sealed and smooth(definitions § 2.17 & 2.20).
  • FDA §4-101.11 – Materials must be (A) safe, (B) durable, corrosion resistant, and nonabsorbent, (C) Sufficient in weight and thickness to withstand repeated WAREWASHING, (D) Finished to have a SMOOTH, EASILY CLEANABLE surface and (E) Resistant to pitting, chipping, crazing, scratching, scoring, distortion, and decomposition.
  • FDA §4-202.11 - (A) SMOOTH; (B) Free of breaks, open seams, cracks, chips, pits, and similar imperfections; (C) Free of sharp internal angles, corners, and crevices; (D) Finished to have SMOOTH welds and joints.

Fasteners and Threads:

  • NSF §4.6 - Exposed screw, bolt, and stud threads; screw, bolt and rivet heads; nuts and studs shall be eliminated from the food zone.
  • FDA §4-202.13 - "V" type threads may not be used on FOOD-CONTACT SURFACES.


  • NSF §4.1 - Food zones shall be readily accessible and easily cleanable (definitions § 2.01, 2.1.1, &2.1.2).
  • FDA §4-202.11 - (E) Accessible for cleaning and inspection by one of the following methods:
    (1) Without being disassembled
    (2) By disassembling without the use of tools, or
    (3) By easy disassembling with the use of only simple tools such as mallets, screw drivers, or wrenches that are kept near the EQUIPMENT and are accessible for use.

The 1999 FDA Food Code also includes requirements for:

  • Temperature & thermostat tolerances for minimum temperature (Principle #3, § (b) & (c))
  • Reliability (Principle #1)
  • Use of hazardous substances
  • Training

NSF also includes requirements for vermin:

  • §4.0 - Cooking, holding, rethermalization and hot food storage equipment shall be fabricated to exclude vermin . . .
  • §4.8 - Equipment shall be fabricated to minimize the retention of dirt, dust, and preclude the harborage and shelter of vermin.

Modular construction provides a haven for vermin of all kinds and is the reason Legion does not include enclosed products in any product lines.

It is Legion’s policy and practice to provide equipment that:

  • complies with the intent and statements of the most stringent design standards
  • allows operators to easily comply with all aspects of the 1999 FDA Food Code, HACCP guidelines and NSF.
Call 800-887-1988 for a complete analysis with appropriate excerpts from the codes included.

Also, the following FDA and USDA references may be contacted directly for information and clarification.

  • Larry Edwards, FDA, Equipment Group, 202-205-8280
  • Gail Smith, USDA, Division of Cooperative Programs, 202-205-8140