Serving in a Pandemic: A HACCP for Patrons

In the absence of guidelines, restaurants are left to write their own

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Illustration by Jessie Cacciola

person without a mask is an egg without a shell. This will mean something to cooks who spend their days saving us from bad eggs. We, the people, are an unpasteurized yolk. One crack of a mask, a drop to the chin, and microbes are free. Vapors float out like fireflies, invisible only most of the time, as they flicker on to their next host.

I, like many critics stated this week, have not dined out at a restaurant since mid-March, and I don’t plan to until we are reopening them because it is safe to — not because, for those in the industry, we believe we have no other choice; or for patrons, who miss the way things were. Preventative actions don’t need to feel awkward. What they should feel is reassuring to anyone who’s been forced off the streets for as long as we have.

Since March, we’ve been waiting for someone to tell us something new. As each week passed by like three, I had (and still have) spiral conversations with my hospitality family about the place where we used to work, where people used to gather, as if the news is new. So let’s talk about what we know, what isn’t new: There is no cure for COVID-19 yet. We must wear a mask in public until there is one, and we can’t eat with a mask on.

We can blame leadership for not giving us better options, please do, but these conditions have not changed. They haven’t changed for the cooks who’ve been feeding us since March through their take-out windows or distanced deliveries at our door. They, the servers, the feeders, the healers, unsurprisingly are the ones we now expect to suffer so we can dine outside. Know that restaurants are doing everything in their power to continue to serve. The least we can do is whatever we must do to allow this to happen safely. An inability to imagine what this means is not due to a lack of information but our ability to ignore information we do not like.

What this looks like is not the end of service, but how we used to serve; not the end of restaurants, but for now, how they used to function. Outdoor dining doesn’t need to mean there is any interaction between a masked server and an unmasked patron. It could mean there’s a place to sit outside when we pick up an order. But what we really miss is being served.

On Sunday, April 26th, New York Governor Andrew Cuomo first addressed what reopening would look like. Despite the freedom, most were likely disappointed when he stated, very plainly, that individual businesses would need to come up with their own plan for how they would reopen safely. They’ll first need to determine if they’re able to reopen, he said, “given everything we now know” — meaning, while maintaining social distance, all the actions that got us over the curve. Businesses might have to get creative. They might need a whole new economic model.

What we knew then was that most restaurants in the U.S. would need to attempt to reopen before there was a vaccine if they had any chance of reopening at all. Today, four months since the shutdown began, there is still no unified plan for how this should be done, especially for the front of house, when the public is concerned about their freedom. I wonder if anyone would believe that cooks have the freedom to serve them a rotten sunny side up. They don’t. Thankfully indoor dining, which was slated to begin Monday, has been postponed until further notice.

Those in charge of kitchen operations have had their eyes peeled for months, waiting for word from the CDC and talking amongst themselves, then waiting for guidelines to be adopted by the state and local health department — for NYC, that’s the DOHMH. Kitchens could, and did, build their plans from cues from the CDC, but this is not the department that would come to inspect them locally. By the end of April, best practices began circulating out of Hong Kong, like this one from Black Sheep Restaurants. In mid-May, California released its dine-in guidelines. Corby Kummer — in connection with the Aspen Institute Food & Society Program, World Central Kitchen, Off Their Plate, and the James Beard Foundation—wrote a back-of-house guide, Safety First: Serving Food and Protecting People During COVID-19. Again and again, the same precautions were reinforced: Wear a mask. Distance. Wash your hands. Limit contact.

While difficult, this can be controlled in kitchens. But would patrons follow their lead? We couldn’t have one without the other.

Above all, Cuomo warned, businesses would need to “monitor the public health impact.” Reopening is a risk they’d be taking, willingly. No business needs to reopen. Regardless of how little this feels like a choice, it is. So restaurants would need to document the effects of their actions, to prove that what they’re doing is okay. If an outbreak were to happen, the restaurant would need to be able to show that it did everything it could to prevent the outbreak, and have proper contacts in place to notify anyone who might be affected.

What is essentially being asked for without calling it by its name, is something restaurants have been very familiar with for over a decade. It’s something a restaurant needs whenever it must prove itself, when applicable guidelines are unavailable: a HACCP plan. Well known to any cook making anything from scratch, a Hazard Analysis and Critical Control Points (HACCP) plan is a system for identifying risks and the methods for controlling those risks. HACCP was originally developed for war and space travel, where there is little margin for error. Now it’s mostly recognized by local health departments to approve sous vide.

In the good old days, HACCP compliance meant monitoring every ingredient that entered your establishment, along with anything that might grow on those ingredients, be they good bacteria or bad: natural yeast in sourdough starter; cultures in a house-made yogurt or charcuterie; potential salmonella in your unpasteurized eggs. But cooks can’t simply provide recipes to the DOHMH. For any process that isn’t outlined in the health code, cooks must provide a HACCP plan. This includes time sheets and temperature check lists, as if cooks are scientists in a lab. In many ways, they are. Mostly they’re just trying to make you a ham sandwich or par-cook a steak.

There are multiple processes within one recipe, many of which are not, as it turns out, outlined in our health code, no matter how safe they may be. The HACCP plan proves the method is safe in terms the DOHMH can understand, even though the department does not provide templates for creating one. Some cities do, but the NYC DOMHM does not. For that, restaurants will often hire a food safety consultant. Having such a plan has proven crucial in overturning a punitive violation by a health inspector, or lowering fines that can average anywhere from $300 to $1,200 per visit.

Though I’m sure this will offend many of you, what we need now is a HACCP plan for people. That includes you, the guest, and the restaurant’s staff. Health inspectors don’t typically hang out in the dining room, so this is a whole new world for them. The closest they’ll get to a customer is the prep area behind the bar. But health risks are now at every table. Rather than fear the chance, let’s call us what we are.

No sooner than three days before restaurants were allowed to open for outdoor dining, the city released a template for such a thing, a reopening safety plan, called New York Forward. But this HACCP-like document is not like the others. Since the viral incubation for COVID-19 can be delayed —as far as we know, by fourteen days—“proof of origin” remains a moving target. This process for risk analysis would be different.

Back in April, I had reached out to a friend in food safety, Austin Publicover. He’s a compliance consultant based in New York, most recently under the name Bulletproof Food Safety, and perhaps most notably, for Danny Meyer’s Union Square Hospitality Group. “I don’t foresee the DOH actually approving any policies or plans for COVID,” he wrote then. “It’s all subjective. It’s all one-size-fits-one, and their approval may or may not confer liability if someone provably contracts COVID from that establishment — assuming we ever get to test/trace/treat instead of shooting in the dark.”

Currently, this still holds up. A restaurant reopening plan does not need to be approved by the DOHMH, but it must be present on site in case of inspection. This phase is about reducing risk and enabling contact tracing. There are no guarantees. That doesn’t mean we take this phase lightly. When the safest protocols are not law, they tend to become law after the first mistakes are made. As restaurants have always done, they’ll need to develop a system of best practices that feels right for their team, for their employees, and for the customers who enter their house, despite what may be legally possible. In the case of a virus like COVID-19, we’ve already defined the risks.

Restaurants can ramp up cleaning schedules, create staff units, provide PPE, distance tables, and limit interactions, but most importantly, these efforts must be tracked. Restaurants must be able to alert customers of any possible outbreak, no matter how small. This measure is not unlike the way food-borne illnesses are prevented. Shellfish tags, which label each bag of live shellfish with vendor information and harvest dates, are kept long after the oysters or scallops are consumed. Legally, for 90 days. All sourcing information is traceable in case someone gets ill. It’s the only way to provide transparency, and track the origin of the outbreak.

Based on what we know, it may be safest for everyone if restaurants require reservations. From a customer perspective, contact information would only need to be provided once. Apps like Resy and OpenTable have already done the work for us. Maybe a form can be attached right there on the app for diners to sign, or a box for them to check.

Pre-set menus would cut down on interactions. Maybe the meal could even be pre-purchased before the diner arrives, whether they decide to dine there or take it to go. Maybe there’s a take-out window, and diners can seat themselves if they’d like to stay and sit outside.

Will some parts of service return when it’s safe? Possibly. Will we miss them? Maybe.


The word restaurant comes from the French, restaurer, meaning “to restore”. We also learned to save room for dessert — desservir, meaning to “clear the table”. Service à la française called for serving everything at once, while the Russians taught us how to course things out à la russe. Food was portioned on plates by servers, usually from a sideboard in the dining room, known as a buffet — which referred to the furniture, rather than the style of dining that would later become synonymous.

The firsts to go during the pandemic were those buffets, along with family-style plating, shared plates, and passed hors d’oeuvres. Invariably, “touching” the table, industry term for checking in on guests during their meal, should be kept to a minimum.

The precise origin of the Lazy Susan is unclear, but I believe most rumors are equally telling. Formerly known as the original dumb waiter, or “silent” server, most historians believe it came about in 18th century England to replace household servants. Without them there to refill glasses and replace accoutrements, diners were forced to reach across one other. It was most popular in the 1950s and ’60s, when the U.S. discovered its love for dim sum and a turntable of snacks.

Perhaps the weakest rumor of all surmises that Thomas Jefferson (or was it Edison?) invented the dumb waiter with his rotating bookcase and makeshift revolving door at Monticello — one side had a rack of shelves, which seems closer in semblance to the mechanical shaft infrequently used by restaurants to pass food between floors. I guess you could make a case that a rotating bookcase makes for a fine serving trolley. Maybe the Lazy Susan, later revived as a “self-serving table”, can reinvent itself once more, with a better name.

In Japan, solo dining comes with privacy dividers at Ichiran Ramen, which we experienced when franchises popped up in New York within the last few years. Partitions separate stools at a counter, similar to a row of phone booths, facing a wall. The kitchen crew is opposite that wall, ready to lift up the bamboo curtain in front of you like a bank teller, to deliver your food. Then there’s the style of tatami, referring to the mat used in low table settings, with the option for private group dining; walls divide up two-person spaces, or larger group spaces. These and larger, family-style Japanese restaurants often have service buttons on tables. Press only when you need assistance. In finer settings, it’s customary for servers to start your meal with oshibori, or warm hand towels, to cleanse your hands before eating.

In Seoul, abiding by distancing rule, some restaurants have installed glass dividers down the length of standard tables and between each seat, so you can see your dining companions but you cannot sneeze on them.

We may find that any one of these methods, or the next great idea, is less awkward in hindsight. We may even take it into a post-pandemic world, post-vaccine. Maybe only until we get one, whenever that may be.

What I know is this: Restaurants will do everything they can to merely exist. If we can support them in a way that actually supports them, they can begin the work to restore what was lost, as they always have, in whatever way they can. Sometimes it’s an amaro when we’re not ready to leave. Or a free meal for our healthcare workers, or the out-of-workers, when we need it most.

Written by

Jessie Cacciola is a food operator & writer in New York. She runs a research site for restaurants & those who inspect them at Grade Pending Press.

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