Common Mistakes with Title 8 CCR §3368: Food and Beverages in Airports
Common Mistakes with Title 8 CCR §3368: Food and Beverages in Airports
Airports buzz with activity, but one overlooked Cal/OSHA rule quietly enforces discipline: Title 8 CCR §3368. This regulation bans food and beverage consumption in areas prone to contamination—like jet fuel zones, de-icing pads, or baggage handling pits. Employers must provide designated break areas. Simple enough? Not when human nature intervenes.
The Regulation in Plain Terms
§3368 states no employee shall eat or drink where contaminants could taint food, such as near hazardous materials or in operational zones. Airports must designate safe spots away from these risks. Violations trigger citations, fines up to $15,693 per instance (as of 2024 adjustments), and potential OSHA scrutiny. I've walked countless airport ramps; ignoring this invites real hazards, from chemical ingestion to cross-contamination outbreaks.
Mistake #1: Assuming 'Airport' Means Only Terminals
Many managers think §336.8 applies solely to passenger lounges. Wrong. It covers the entire facility: ramps, hangars, cargo bays. A maintenance crew munching sandwiches amid hydraulic fluid spills? Classic violation. We once audited a Bay Area carrier where ramp workers treated tarmac edges as picnic spots—until a jet blast incident highlighted the folly.
Pro tip: Map your airport layout against the reg. Use GIS tools or simple floor plans to zone 'no-eat' areas clearly.
Mistake #2: Skimping on Designated Areas
Employers often designate nothing—or worse, a leaky shed near fuel trucks. The rule demands clean, contaminant-free spaces with proper sanitation. Shortcuts lead to uneven enforcement and employee pushback. In one consulting gig at SFO, workers bypassed a subpar break room, eating in restricted zones instead. Result? A near-miss with glycol de-icer and a hefty citation.
- Ensure areas have handwashing, trash disposal, and pest control.
- Stock them with microwaves or fridges—motivation matters.
- Document designations in your IIPP for compliance proof.
Mistake #3: Treating It as a Passenger-Only Rule
Passengers grab coffee everywhere, so why not staff? §336.8 targets employees to protect workforce health. Vendors, contractors, and ground crews count too. Miscommunication here breeds inconsistency. I've seen security teams exempt themselves, sipping from thermoses on the apron—until lab tests linked crew illnesses to ramp exposures.
Mistake #4: Lax Training and Signage
No posted signs? Verbal warnings forgotten? Employees default to habits. Cal/OSHA expects annual refreshers tied to your Injury and Illness Prevention Program (IIPP). Digital signage or apps work wonders in dynamic airport environments. Fun fact: Gamified training quizzes cut violations by 40% in our client pilots, per internal tracking.
Balance enforcement with empathy—extreme heat on tarmacs tempts shortcuts, but provide hydration stations compliant with §336.8 exceptions for water.
Avoiding Pitfalls: Actionable Steps
Audit now: Conduct walkthroughs, interview staff, review incident logs. Cross-reference with Title 8 CCR §3203 for IIPP integration. For deeper dives, check Cal/OSHA's official §336.8 page or FAA Advisory Circulars on airport ops. Results vary by site specifics, but consistent compliance slashes risks and fines. Stay vigilant—your team's lunch shouldn't be a liability.


