Usually yes. Serving on disposable plates and cups removes the tableware from your dish load, but you still have tongs, scoops, knives, cutting boards and pans to wash, rinse and sanitize. The FDA Food Code calls for a sink with at least three compartments wherever equipment and utensils are washed by hand.
Shop the equipment in this article: two compartment sink, hand sink and three compartment sink. Freight is included on every order.
What the Food Code says
Section 4-301.12 of the FDA Food Code says a sink with at least three compartments shall be provided for manually washing, rinsing and sanitizing equipment and utensils. The compartments have to be large enough to immerse the largest item you wash. If something is too big for the sink, the code points you to a warewashing machine or to alternative equipment that the regulatory authority has approved.
The rule is about utensils and equipment, not only about plates. In the Food Code a utensil is any implement or container that touches food during storage, preparation or service. Paper plates take care of the customer’s side of the counter. They do not change what happens on yours.
Why disposables rarely mean nothing to wash
Walk through one shift and list everything that touches food:
- Tongs, spoons, ladles, spatulas and portion scoops
- Knives and cutting boards
- Steam table pans, sheet pans and food storage containers
- Blender jars, mixing bowls and measuring tools
- Removable parts of slicers, dispensers and other equipment
If any of those are in your operation and you do not have an approved dish machine, the inspector will look for somewhere to wash, rinse and sanitize them.
The exceptions an inspector can approve
The same section of the code allows alternative manual warewashing equipment where there are special cleaning needs or constraints, but only when the regulatory authority has approved it. A two compartment sink is one of the listed alternatives, and it comes with conditions. The operator has to get approval first, limit the number of items washed, and wash in batches, for example at the end of a shift. Wash and sanitizing solutions have to be made up right before use and drained right after. The code also says a two compartment sink may not be used where there is a continuous or intermittent flow of kitchenware or tableware through it.
In other words, a smaller sink is something you ask permission for. It is not something you can assume because the menu is simple.
Operations that sometimes get a different answer
Some health departments treat a few kinds of operation differently. Two examples are a stand that sells only prepackaged food with no open food handling, and a cart or truck that returns to a commissary where all utensils are washed. These are local decisions and they vary a great deal from one county to the next. Ask before you sign a lease or build out a truck.
The hand sink is a separate question
Using disposables does nothing to the handwashing requirement. Plan for a separate hand sink in addition to whatever warewashing sink you are required to have.
Your local health department has the final say, so confirm with them before you build or buy.
What to buy
Most operators in this position choose a compact three compartment sink sized to the largest pan they wash. If your health department approves the alternative, look at a two compartment sink. Add a hand sink for the handwashing station, and check that the sink you pick has the right faucet for its backsplash holes. Our Express KitchQuip stainless steel sinks are NSF certified, and freight to the 48 contiguous states is included in the price.