Contains Nonbinding Recommendations  
 
 
Returning Refrigerated Transport  
Vehicles and Refrigerated Storage Units to 
Food Uses After Using Them to  
Preserve Human Remains 
 Guidance for Industry  
  
 September 2023 
 
 
Additional copies are available from: 
Office of Food Additive Safety 
Center for Food Safety and Applied Nutrition 
Food and Drug Administration 
5001 Campus Drive 
College Park, MD 20740 240-402-1200 
https://www.fda.gov/FoodGuidances 
 
You may submit either electronic or written comments regarding this guidance at any time.  Submit 
electronic comments to https://www.regulations.gov.  Submit written comments to the Dockets 
Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, 
Rockville, MD 20852.  All comments should be identified with the docket number FDA2017-D-
0085.  
 
For questions regarding this document as it relates to human food, contact the Center for Food 
Safety and Applied Nutrition (CFSAN) at 240-402-1200.  For questions regarding this document as 
it relates to animal food, contact the Center for Veterinary Medicine (CVM) at 240-402-7002.  
U.S. Department of Health and Human Services 
Food and Drug Administration  
Center for Food Safety and Applied Nutrition  
Center for Veterinary Medicine  
    
Contains Nonbinding Recommendations  
  
  
 
 
Table of Contents
 
  
  
 
I.      Introduction ........................................................................................................... 3 
II.  Background ............................................................................................................ 4 
III.  Discussion .............................................................................................................. 5 
IV.  Additional Resources ............................................................................................. 6 
 
 
  
   
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Contains Nonbinding Recommendations  
 
Returning Refrigerated Transport  
Vehicles and Refrigerated Storage Units to 
Food Uses After Using Them to  
Preserve Human Remains 
 
Guidance for Industry 
 
This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic.  
It does not create or confer any rights for or on any person and does not operate to bind FDA or the 
public.  You can use an alternative approach if the approach satisfies the requirements of the 
applicable statutes and regulations.  If you want to discuss an alternative approach, contact the FDA 
staff responsible for implementing this guidance.  If you cannot identify the appropriate FDA staff, 
call the appropriate telephone number listed on the title page of this guidance.    
    
I.  Introduction  
  
FDA plays a critical role in protecting the United States from threats such as emerging infectious 
diseases.   
  
During the Coronavirus Disease 2019 (COVID-19) pandemic, FDA was asked whether refrigerated 
food transport vehicles and refrigerated food storage units used for the temporary preservation of 
human remains subsequently can be used to transport and store human and animal food.  In May 
2020, FDA issued a previous version of this guidance to provide information and resources related to 
the cleaning and disinfection of such vehicles and storage units to address food safety before they are 
used again to transport and store food.  The information in the guidance, however, also can be 
applied to situations where there is a temporary need for refrigerated food transport vehicles and 
refrigerated food storage units to temporarily hold human remains and where those vehicles and 
storage units are to be used subsequently to transport and hold human and animal food.  Thus, we 
have revised the guidance so that it is no longer limited to the COVID-19 pandemic. 
 
The recommendations in this guidance are intended to supplement existing food safety regulations 
and guidance.1  Other aspects of cleaning and disinfection, such as worker, environmental, and 
 
1  For example, FDAs Sanitary Transportation of Human and Animal Food (21 CFR part 1 subpart O), Current Good 
Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food (21 CFR part 117) and 
Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Food for Animals (21 
CFR part 507) regulations contain requirements regarding the safe storage and transportation of human and animal food 
that also may apply.   
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Contains Nonbinding Recommendations  
vehicle safety, are addressed by other federal agencies, such as the Occupational Safety and Health 
Administration (OSHA), Environmental Protection Agency (EPA), Centers for Disease Control and 
Prevention, and Department of Transportation (DOT), as well as State and local government 
agencies.  Several additional resources related to these topics are included in Section IV of this 
document.  
   
In general, FDAs guidance documents, including this guidance, do not establish legally enforceable 
responsibilities.  Instead, guidances describe our current thinking on a topic and should be viewed 
only as recommendations, unless specific regulatory or statutory requirements are cited.  The use of 
the word should in FDA guidance means that something is suggested or recommended, but not 
required.  
 
 
II.  Background  
  
On January 31, 2020, the Department of Health and Human Services (HHS) issued a declaration of a 
public health emergency (PHE) related to COVID-19 under section 319 of the Public Health Service 
(PHS) Act and mobilized the Operating Divisions of HHS.2  In addition, on March 13, 2020, the 
President declared a national emergency in response to COVID-19.3 The national emergency related 
to the COVID-19 pandemic ended on April 10, 20234, and the PHE related to COVID-19 declared 
under the PHS Act expired on May 11, 20235. 
  
During the COVID-19 pandemic, additional refrigerated storage was needed for human remains.  
Refrigerated food transport vehicles and refrigerated food storage units ordinarily used for food 
preservation were used to preserve human remains temporarily.  In response to questions about 
returning refrigerated food transport vehicles and refrigerated food storage units for use in food 
transport and storage, we issued guidance on how such refrigeration vehicles and refrigeration units 
could be safely used under certain circumstances.   
 
The guidance, while issued during the COVID-19 pandemic, contained recommendations that would 
be applicable in most scenarios where refrigerated food transport vehicles and refrigerated food 
storage units ordinarily used for food preservation might be used to preserve human remains 
temporarily.  Consequently, we have revised the guidance so that the recommendations can apply in 
most situations where refrigeration vehicles and refrigeration units that temporarily held human 
remains can be returned to use for food transport and storage. 
  
 
2 Secretary of Health and Human Services Alex M. Azar, Determination that a Public Health Emergency Exists. 
(originally issued on Jan. 31, 2020, and subsequently renewed), available at 
https://www.phe.gov/emergency/news/healthactions/phe/Pages/default.aspx.   
3 Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak 
(Mar. 13, 2020), available at  https://trumpwhitehouse.archives.gov/presidential-actions/proclamation-declaring-national-
emergency-concerning-novel-coronavirus-disease-covid-19-outbreak/.   
4 Joint Resolution terminating a National Emergency, available at https://www.congress.gov/118/plaws/publ3/PLAW-
118publ3.pdf.   
5 Fact sheet ending the PHE related to COVID-19, available at https://www.whitehouse.gov/briefing-room/statements-
releases/2023/05/09/fact-sheet-actions-taken-by-the-biden-harris-administration-to-ensure-continued-covid-19-
protections-and-surge-preparedness-after-public-health-emergency-transition/.  
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Contains Nonbinding Recommendations  
III.  Discussion  
  
Refrigerated food transport vehicles and refrigerated food storage units used for the temporary 
preservation of human remains subsequently can be safely used for food transport and food storage 
under certain circumstances.  It is important that food is protected during transport and storage to 
ensure food is safe for humans and animals and that conditions do not exist that may adulterate the 
food.  Before returning to service to transport or store human or animal food, refrigerated food 
transport vehicles and refrigerated food storage units used to hold human remains should be 
thoroughly cleaned and disinfected.6    
  
The floors, walls, ceilings and other hard, non-porous surfaces on the interiors of refrigerated food 
transport vehicles and refrigerated food storage units are generally designed to be easily cleaned.  
After being cleaned, these surfaces should be disinfected to reduce the risks associated with 
pathogens.  Appropriate Environmental Protection Agency (EPA) registered disinfectants (the EPA 
registration number is on the products label) should be used to accomplish both goals.  EPA 
registered disinfectants should be suitable for the intended material being disinfected.7  
  
Disinfectants should be used in accordance with EPA-registered label use instructions to ensure safe 
and effective use of the product (for example, maintaining the required wetted contact time).  Some 
surfaces may require repeat applications to ensure treatment for the required contact time.  Also, 
because some disinfectants may not be effective at refrigeration temperatures (check the label), 
interiors may need to be brought to the appropriate temperature before disinfection.  Further, note 
that certain chemicals, at concentrations known to be effective for proper disinfection, may damage 
the interior surfaces of the refrigerated food transport vehicles and refrigerated food storage units.   
When there is evidence that interior surfaces were in direct contact with blood or bodily fluids, FDA 
recommends that refrigerated food transport vehicles and refrigerated food storage units not be 
returned to service for transporting or storing food for humans or animals if any one of the following 
conditions exist:   
  
  There are interior surfaces made of porous unfinished wood or other materials that are not 
suitable for cleaning and disinfection and that cannot be removed and replaced;   
  
  There are interior surfaces that are damaged or compromised (e.g., cracked fiberglass, exposed 
seams) such that they are not able to be properly cleaned and disinfected;     
  
  There are mechanical refrigeration components located within the storage areas that cannot be 
cleaned in place or removed for cleaning and/or replacement;     
  
  The unit is permeated by offensive odors that cannot be eliminated through cleaning and 
disinfecting.  
 
6 Disinfection describes a process that eliminates many or all pathogenic microorganisms, except bacterial spores, on 
inanimate objects.  CDC Guideline for Disinfection and Sterilization in Healthcare Facilities (2008). (Available at: 
https://www.cdc.gov/infectioncontrol/guidelines/disinfection/index.html)  
7 EPA, Selected Registered Disinfectants, available at https://www.epa.gov/pesticide-registration/selected-epa-
registered-disinfectants. 
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Contains Nonbinding Recommendations  
  
Under OSHA requirements, workers who conduct cleaning tasks must be protected from exposure to 
hazardous chemicals used in these tasks.  In these cases, OSHAs Personal Protective Equipment 
(PPE) (29 CFR 1910 Subpart I) and Hazard Communication (29 CFR 1910.1200) standards may 
apply, and workers may need appropriate PPE to prevent exposure to the chemicals.  If workers need 
respirators, they must be used in the context of a comprehensive respiratory protection program that 
meets the requirements of OSHA's Respiratory Protection standard (29 CFR 1910.134) and includes 
medical exams, fit testing, and training.  
  
Cleaning chemicals' safety data sheets and other manufacturer instructions can provide additional 
guidance about what controls, including PPE, workers need to use the chemicals safely.  
 
IV.  Additional Resources   
  
Additional information that may be helpful is provided below.    
 
 
The Occupational Safety and Health Administration  
 
29 CFR 1910.132  Personal Protective Equipment (PPE)  
Available at:  https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.132    
 
29 CFR 1910.134  Respiratory Protection  
Available at:  https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134    
 
29 CFR 1910.1030  Bloodborne Pathogens  
Available at:  https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030    
 
29 CFR 1910.1200  Hazard Communication  
Available at: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200    
 
OSHA COVID-19 webpage  
Available at: https://www.osha.gov/coronavirus    
  
The Environmental Protection Agency  
   
EPA Registered Disinfectants 
Available at: https://www.epa.gov/pesticide-registration/selected-epa-registered-disinfectants 
  
Office of Land and Emergency Management  Medical Waste web page   
Available at:  https://www.epa.gov/rcra/medical-waste   
  
 
 
 
     
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Contains Nonbinding Recommendations  
U.S. Department of Transportation  
 
Handling and Disposing of COVID-19  
Available at: https://www.phmsa.dot.gov/transporting-infectious-substances/covid-19-information   
  
U.S. Department of Transportation  
 
Title 49 CFR Parts 100-185 - Hazardous Materials Regulations  
Available at: https://www.phmsa.dot.gov/standards-rulemaking/hazmat/hazardous-materials-
regulations 
   
How to Comply with Federal Hazardous Materials Regulation  
Available at:   
https://www.fmcsa.dot.gov/regulations/hazardous-materials/how-comply-federal-hazardous-
materials-regulations 
 
The Centers for Disease Control and Prevention (CDC)  
 
When and How to Clean and Disinfect a Facility 
Available at: 
https://www.cdc.gov/hygiene/cleaning/facility.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.
gov%2Fcoronavirus%2F2019-ncov%2Fcommunity%2Fdisinfecting-building-facility.html  
 
Guidelines for Disinfection & Sterilization in Healthcare Facilities  
Available at:  https://www.cdc.gov/infectioncontrol/guidelines/disinfection/index.html   
 
Cleaning and Waste Disposal Recommendations  
Available at:  
https://www.cdc.gov/hygiene/cleaning/facility.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.
gov%2Fcoronavirus%2F2019-ncov%2Fcommunity%2Fdisinfecting-building-facility.html 
 
CDC National Institute for Occupational Safety and Health  
Safety and Health Topic:  Emergency Preparedness and Response Resources  
Available at:  https://www.cdc.gov/niosh/emres/   
 
CDC National Center for Environmental Health  
Available at:  https://www.cdc.gov/nceh/   
  
U.S. Army Public Health Center  
 
Technical Guide 195A, November 2015 Safety and Health Guidance for Mortuary 
Affairs Operations  Infectious Materials  Available at:   
https://phc.amedd.army.mil/PHC%20Resource%20Library/TG195A_SafetyandHealthGuidanceforM 
ortuaryAffairsOperations.pdf   
 
 
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Contains Nonbinding Recommendations  
U.S. Department of Agriculture  
 
Foreign Animal Disease Preparedness and Response Plan: Standard Operating Procedures: 
Cleaning and Disinfection Available at:  
https://www.aphis.usda.gov/animal_health/emergency_management/downloads/sop/sop_cd.p
df  
  
World Shipping Council  
 
Joint Industry Guidelines for Cleaning of Containers  
Available at: 
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8&ved=2ah
UKEwivqMy50aqBAxXLF1kFHTDbD5IQFnoECBMQAQ&url=https%3A%2F%2Fwww.worldshi
pping.org%2Fnews%2Fnew-updated-version-released-of-pjoint-industry-guidelines-for-the-
cleaning-of-containers&usg=AOvVaw2C124yNt7Jjyje7_CsIpZG&opi=89978449 
 
Prevention of Pest Contamination of Containers:  Joint Industry Guidelines for Cleaning of  
Containers (pest contamination includes contamination by organic material of animal origin) 
Available at: https://www.worldshipping.org/s/Cleaning-of-Containers_Joint-Industry-Guidelines_-
EN.pdf  
  
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