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Board adopts 2017 FDA model food code but removes proposed on-site CFPM requirement

Mohave County Board of Health · October 28, 2025
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Summary

Tara Stanek, environmental health division manager, asked the board to adopt the 2017 FDA Model Food Code to replace the county's 2009-based rules; the board approved the adoption but voted to remove the proposed requirement that a certified food protection manager be physically on-site during food operations for certain permit types.

Tara Stanek, manager of Mohave County's Environmental Health Division, presented a proposal to update county food-service regulations by adopting the 2017 FDA Model Food Code (the version Arizona adopted at the state level in 2019) to replace the county's current 2009-based local rules.

Stanek reviewed the public-health rationale (foodborne illness remains common and costly), outreach and engagement the division conducted (presentations and workshops across county communities), and the main operational changes the 2017 code introduces. She explained key items likely to affect local operators: updated cooking and time-temperature requirements for some animal products; additional labeling requirements for subingredients in manufactured foods; updated thawing rules for vacuum-packaged frozen fish; requirements for written procedures to respond to vomiting and diarrheal contamination events; and a strengthened requirement that permitted Type-1 through Type-3 establishments have a certified food protection manager (CFPM) available.

Stanek said Mohave County issues about 1,600 annual food permits and 300 temporary permits. Under current practice roughly 1,100 permit-holders already carry a CFPM on staff (not necessarily on-site during every shift). If the county adopted the 2017 code as written, Stanek explained, approximately 750 establishments would be required to have a CFPM physically on-site during food operations. She also detailed department assistance: no-cost local CFPM training and testing during an initial compliance period, templates for contamination-response procedures, and an FDA employee-health policy tool for ill-worker exclusion.

During discussion, board members and the county attorney raised implementation concerns, delegation-agreement implications, and cost burdens on small or nonprofit operators. Supervisor Gould moved an amendment to strike the proposed CFPM on-site requirement from the county's adoption; Terry Coyle seconded. County legal staff and the division manager noted that adopting portions of the state-adopted code may require revisiting the county's delegation agreement with Arizona Department of Health Services, but that the board can choose local modifications.

The board voted on Supervisor Gould's motion to adopt the 2017 food code while removing the on-site CFPM requirement; the motion passed on a voice vote. Manager Stanek said the division will provide CFPM training opportunities, issue written guidance and templates, and work with state officials as necessary to align the county's delegation agreement.

The board did not adopt the CFPM on-site requirement; staff will implement the remainder of the 2017 code changes per the board's direction and will report back on delegation-agreement implications and compliance timelines.