Whose Job Is It to Keep the Mobile Food Truck Industry Safe?

By John Thomas (photo by author)

What is one of the fastest growing businesses in America? If you guessed mobile food vendors, that is correct! The United States has seen a dramatic increase in this industry, and the American public is feeding into its growth, using this trendy concept for events. In fact, some food festivals are exclusively mobile food vendor rallies.

What is a mobile food vendor? A mobile food vendor may consist of a food truck, trailer, van, or cart that prepares and serves food. Why did I give you a definition of a mobile food vendor? The general public only considers food trucks to be mobile food vendors, but in reality they appear in many different shapes and sizes.

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Now that we have identified the good things about mobile food vendors, let’s look at the darker side of this industry. Most mobile food vendors have propane on board. I have been told that most fire inspectors complete a fire inspection by using a soapy water mix on the top of the cylinder. But what about the pipes inside of the vehicle? How does anyone know if the connects or pipes are leaking? Most of the mobile food vendors I have inspected with propane leaks didn’t explode because the vent fans were kept on, keeping the propane below the explosive range.

Many mobile food vendors are using large vans, trucks, trailers, or converted campers. They are, in effect, just buildings on wheels, yet most are not built like permanent structures. If mobile food vendor vehicles are just buildings on wheels, why don’t they have the same regulations as buildings? This is where most of the problems come into play. No one conducts inspections during the building of these vehicles. There are no regulations on these vehicles—no regulations for building codes, plumbing inspections, and no electrical inspections.

The fire service has stepped in to help this industry avoid incidents like the one that occurred July 1, 2014 in Philadelphia, in which the operator and her daughter died while operating a mobile food truck. Although the video hit the national news, still no laws have been passed to help owners from preventing this tragedy from happening again. Until now.

I have spent the last five years working on developing an ordinance, state codes and advocating that National Fire Protection Association (NFPA) to develop a standard on how to build, operate, and inspect mobile food vendor vehicles.   

Here just are a few of the dangers I have found with mobile food vendors:

• Leaking flexible gas lines
• Propane leaks from stoves when the pilot light went out
• Even after the propane was disconnected from a trailer, the system leaked enough that it sent my gas meter into alarm
• Loose propane cylinders
• Flexible ¼-inch pipe for propane gas lines
• Generators leaking carbon monoxide into the vehicle to the point my gas meter went into alarm
• Generator pans filled with oil and gas
• Generators too close to propane cylinders
• Grease in the venting system
• No hood suppression system
• Uninspected hoods and fire extinguisher

So what do we do? How can the fire service help mobile food vendors stay safe? How can the fire service protect the patrons and passersby from injuries and possible death?

Until the NFPA creates a standard or guide for mobile food vendors, the fire service can help save lives and property by following these simple steps:

• Require all mobile food vendors to be inspected by the fire marshal’s Office.
• Enforce inspections by creating an ordinance with safety requirements.
• Within the ordinance, the following safety requirements can be adopted:
• Under the International Fire Codes any cooking that produces grease, latent vapors must have a hood suppression system.
• Fryers must have a “K” extinguisher. 
• Vehicle must be required to have smoke detectors, carbon monoxide detectors, and propane leak detectors.
• NFPA 96 states mobile food vendors need signage to indicate where the propane is stored.
• Require generator inspection checks to ensure generators are not over-loaded or leaking fluids.
• Require signage to indicate where the generator and fuel are located.
• Include a penalty section of the ordinance for mobile food vendors who are not in compliance with the ordinance. 
• Once the ordinance has been passed by the local agency’s lawmakers, the fire department can then enforce the inspections of mobile food vendors
• If the township/city has regular mobile food vendors, it makes  it easier to conduct the inspections 
• Mobile food vendor rallies should have a procedure adopted on how the mobile food vendor vehicles should be set up. Remember, 10 feet between vehicles is required.

Perhaps you have noticed that most of what you see in the proposed ordinance is covered in different sections of NFPA 96, 1192, and 58. Although some people have argued to just have the mobile food owners look through the three standards, even I didn’t want to read through all of these standards. Do you think a mobile food vendor or operator is going to sift through them all? I would assume they would rather take the time to develop new menus or business ideas. If your area is currently using the International Codes, these codes would also come into play, for example, securing pressurized cylinders.

When conducting any inspection of a restaurant, be sure to ask the staff if they know how the hood suppression system works. If you get 10 percent of the staff that knows, then you’re lucky. In most cases, more than 90 percent of restaurant staff have no clue on what to do if the system activates or how they should clean the hood and attached equipment. While conducting one restaurant inspection, the owner of the business asked me: “What are those metal things that are hanging by the pull station?” (They were the old fusible links). When a new restaurant opens in my area, I make it a point to visit the owners and staff to discuss fire safety and how the systems work in their restaurant. If restaurant staff has no clue on the operations of a simple hood system, how can we expect mobile food vendors to know about properly building and maintaining a whole truck or trailer? They need guidance from the local enforcing agency. We now have a training course available to become experts on keeping mobile food vendors and the public safer.

The motto is: “Educate Before We Violate.” This means we must educate the business owner, the operators, the chefs and staff on the dangers inherent to the mobile food industry…and what to in case of an emergency.

When an emergency strikes a mobile food vehicle, things go bad quickly. There is not much time to think. Remember, a mobile food truck is like a rolling bomb because the propane is mounted on the vehicle. Unlike a building, the walls on most mobile food vehicles are aluminum with little or no insulation. There are typically no suppression sprinklers and no fire alarms tied into an alarm company. If it is zero dark 30 and a mobile food vendor’s vehicle is parked in a parking lot with other trucks, no one will know of an emergency until the propane cylinder explodes—and by then the vehicle is gone.

In summary, here are some tips to help mobile food vendor owners and operators:

1. Develop an ordinance that requires mobile food vendors to be inspected before operating within your district.
2. Set a permit fee process if you do not have one in place.
3. Train all of inspectors on how to conduct a full and proper inspection of mobile food vendor vehicles.
4. Follow information from the International Fire Codes, NFPA 58, NFPA 96, and NFPA 1192 on hood suppression systems.
5. Notify all mobile food vendors that your district will be conducting a new fire inspection of mobile food vendor vehicles.
6. Work closely with the local court system, health department, and local clerk’s office.  

John Thomas is a 27-year veteran of the fire service and has been investigating fires for 26 years. A New Jersey Level-2 fire service instructor, he teaches hazmat, incident command, and fire investigation. Thomas has conducted and developed fire investigation courses for law enforcement and attorneys. He is the owner of Fire Inspector Services LLC, which conducts fire service training and consulting relative to mobile food vendors, fire investigation, private industry security and fire safety, and terrorism and counterterrorism.