A church food pantry checklist, from IRS rules to dignity at the door

Somewhere in America tonight there is a church pantry run out of a supply closet by two retirees and a very determined woman with a clipboard. It has a refrigerator that makes a noise like a diesel truck, a shelf of green beans from three different decades, and a waiting list of people who need it. Nothing tests a congregation's unity quite like the question of where to put the second freezer.

I love these places. They are the answer to a question that gets asked in Washington with a straight face: who is going to feed people if the government does not? The answer is that people have been doing it for centuries, one casserole and one canned good at a time, and the good ones do it well. The bad ones do it with the best of intentions and a food-safety problem waiting to happen.

This checklist is for the first kind, and for anyone who wants to become it. It is grouped by area, and every item comes with a reason, because a rule you understand is a rule you will follow. It is not legal advice or a substitute for your local health department. Treat it as a map. The details of what applies to you depend on your state and county, and the people who can answer them are named in each section.

Group one: your legal footing

1. Know your tax status. A church is treated as a tax-exempt 501(c)(3) organization automatically, without filing an application. If the pantry is simply a ministry of the church, it operates under the church's status. Why: you do not need to spend months and filing fees on an application you do not need. If you want the longer tour of how the tax rules treat churches, see Do churches pay taxes? Eleven questions about churches and the tax man.

1. Get an Employer Identification Number if the church does not have one. An EIN is free from the IRS. Why: food banks, banks, grant makers and insurance carriers will ask for it, and having it ready saves weeks.

1. Decide whether the pantry is a church ministry or a separate nonprofit. A separate entity would incorporate under state law and apply for its own recognition. Why: a separate entity can protect the church's other assets if something goes wrong, but it adds paperwork and a board. Many small pantries stay under the church's umbrella. Ask your denomination or an attorney to weigh in.

1. Check your state's charitable-solicitation rules. Many states exempt churches from registration but not always every ministry. Your state attorney general or secretary of state usually has the answer. Why: the penalty for asking for money without the right paperwork is an embarrassing letter, and it is entirely avoidable.

1. Check local zoning and parking. Why: a pantry that generates a line of cars at 8 a.m. can irritate neighbors and land the church in a dispute with the city. A quick call to the zoning office, and a heads-up to the neighbors, is cheaper than an argument.

Group two: insurance and volunteers

1. Call your insurance agent and say exactly what you are doing. Ask whether your general liability policy covers food distribution, volunteers, and any delivery vehicles. Why: many congregations assume they are covered and find out otherwise after a claim.

1. Ask about accident coverage for volunteers. Why: a volunteer who slips on a wet floor while stacking boxes should not be your church's financial crisis, or his own.

1. Understand what the Volunteer Protection Act does and does not do. The federal Volunteer Protection Act of 1997 shields individual volunteers from personal liability for harm caused by ordinary negligence while acting within the scope of their duties for a nonprofit, with exceptions. It protects the volunteer, not the organization. Why: it helps you recruit people who worry about being sued, but it is no substitute for insurance.

1. Screen volunteers wherever children are present. If the pantry serves families, runs a children's backpack program, or uses youth volunteers, run background checks on adults who work with minors, use a two-adult rule, and put the policy in writing. Why: it protects children, and it protects the congregation from the worst day it could ever have.

1. Hold a short orientation for every new volunteer. Cover food safety, privacy, how to treat guests, and what to do if someone is upset. Why: most problems at a pantry are not caused by bad people. They are caused by good people who were never told the rules.

Group three: food safety

1. Call the county or city health department before you open. Ask what permits, inspections or training apply to a pantry that stores and gives out food. Why: rules differ by place, and some jurisdictions treat donated, shelf-stable food lightly and perishable food more strictly. You want to learn that from a phone call and not from an inspector at the door.

1. Keep cold food cold. The standard in the FDA Food Code is 41 degrees Fahrenheit or below for refrigerated food. Freezers should hold at 0 degrees. Put a thermometer in every unit and keep a written log. Why: temperature is the single most common way a good pantry makes someone sick, and a log is your proof that you were paying attention.

1. Set a written policy on what you will not hand out. Typical entries: bulging, leaking or badly dented cans, broken seals, open packages, food that has been left out too long, and anything that smells or looks wrong. Why: a bright line lets a tired volunteer say no without an argument.

1. Understand date labels. On most foods, "best by" and similar dates describe quality, not safety. Infant formula is the notable exception and should not be handed out past its date. Why: knowing the difference keeps you from throwing away good food, and keeps you from handing out the one product where the date really matters.

1. Train volunteers in basic hygiene. Hand washing, clean gloves for open food, hair restraints where needed, and a firm rule that anyone who is sick stays home. Why: because this is the most basic rule in food service, and the one most often forgotten by well-meaning volunteers.

1. Store food off the floor and watch for pests. Why: a mouse in the supply closet can end a pantry's good name.

1. Sign up for recall notices. The FDA and USDA publish them. Your regional food bank usually passes them along as well. Why: if a product is recalled, you need to be able to pull it from the shelf and, if possible, tell the people who took it.

1. Know the Bill Emerson Good Samaritan Food Donation Act. Enacted in 1996, it protects donors, and the nonprofits that receive their food, from civil and criminal liability for donated food given in good faith, except in cases of gross negligence or intentional misconduct. Why: grocers and restaurants will ask about it before they donate. Read the current text so you can answer them honestly, and note that it protects good-faith handling, not carelessness.

Group four: sourcing

1. Join your regional food bank as a partner agency. Why: food banks supply food in bulk at low or no cost, offer training, and know the rules. A cash gift to a food bank generally buys more food than the same dollars spent at a retail store, so ask yours how to make the most of donations.

1. Learn the paperwork that comes with federal commodities. Some food banks distribute food from the federal Emergency Food Assistance Program, known as TEFAP, which moves through state agencies to food banks and then to pantries. Why: if you take it, you agree to rules on record-keeping, nondiscrimination and eligibility. It is a good deal, but read the agreement.

1. Set up regular pickups from local grocers. Why: steady supply beats seasonal drives, and many stores have surplus they would rather give than throw away.

1. Do not rely on food drives alone. Why: drives bring in a flood around the holidays and a trickle in the summer, when children are out of school and need more help, not less.

1. Ask before accepting homegrown produce. Why: a gardener's tomatoes are a blessing, but your health department may have rules about how fresh produce is handled and labeled. Ask first.

Group five: intake that protects dignity

1. Ask for the least information you need. Name, household size and perhaps a ZIP code is often enough unless a commodity program requires more. Why: every question you ask is one more humiliation for someone who is already embarrassed to be there.

1. Consider a client-choice model. Arrange the shelves like a small market so families choose their own food. Why: it cuts waste, because no one takes home a bag of food the family cannot eat, and it treats the guest as an adult.

1. Plan for dietary needs and cultural preferences. Keep some items that suit allergies and common dietary requirements, and food your community actually eats. Why: a pantry that stocks only what was donated is a pantry that serves the donors.

1. Open when working people can come. Evenings and Saturday mornings. Why: the family with two jobs cannot arrive at 10 a.m. on a Tuesday, and these are exactly the people who need you.

1. Make the line bearable. Seats, shade, water, a number system or appointments. Why: standing in the heat for two hours is a penalty for being poor.

1. Put a trained, friendly person at the door. Greet people by name when you can. Why: tone is half of what you provide.

1. Protect privacy. Keep sign-in sheets out of sight. Never post photos of guests without their clear permission. Why: nobody should be identified in a church bulletin as the family who needed groceries.

1. Keep a short list of other help. Include the local helpline (many communities have a 211 service), SNAP and WIC offices, utility assistance and job services. Offer it without pushing. Why: a bag of groceries is a bridge, and a guest may need to know where it leads.

Group six: serve everyone without religious strings

1. Serve everyone, regardless of faith. Do not require church membership, attendance or a profession of belief. Why: this is the right thing to do and the plain reading of the Gospel's call to feed the hungry. It is also the rule if you take federal commodities. (Matthew 25 is the passage most congregations have in mind.)

1. Keep any prayer or worship voluntary and separate. Offer a prayer or a chaplain to those who want one. Put worship in a different room or at a different time from the food line. Why: federal rules for programs using USDA food, found in Part 16 of Title 7 of the Code of Federal Regulations, say that religious organizations may not require participation in religious activities as a condition of receiving help and that such activities must be separate in time or place. The same logic applies to good manners. If you want the background on how that rule evolved, see From Charitable Choice to the faith-based office, when churches got a seat.

1. Do not turn the line into a membership drive. An open invitation to Sunday service is fine. Pressure is not. Why: a person who comes for groceries and leaves feeling hunted will not come back, and will not trust the church.

1. Let volunteers be who they are. A volunteer can say "God bless you" and mean it. Why: the whole point of a church pantry is that it is run by people whose faith moves them to serve. Taking that out would defeat the purpose.

Group seven: records and review

1. Count households, visits and pounds of food. Do not record personal details in reports. Why: your food bank and any funders will ask, and the numbers help you make the case for more support.

1. Review the pantry once a year. Check temperature logs, insurance, volunteer training and complaints. Invite the health inspector for a friendly walk-through. Why: problems get small when you find them early.

1. Ask the guests. An anonymous comment card or a brief conversation works. Why: guests will tell you things volunteers never hear, such as that the Thursday line is too long or that the canned fish is going uneaten.

1. Write a one-page manual. Hours, who is in charge, what you serve, who to call. Why: when the woman with the clipboard goes on vacation, the pantry should not.

1. Plan for a surge. A plant closes, a storm hits, and the line doubles. Why: know in advance who you will call and where extra food will come from.

Where this fits

If your church is thinking about going further, perhaps opening its doors to foster families, ten steps from a church pew to a licensed foster or adoptive home is the next checklist. And if you want to understand why this kind of local work matters beyond the groceries, What Tocqueville saw in American clubs and why conservatives still quote him makes the case. Families who give to these ministries can see how the tax rules treat their gifts in Does your giving change your tax bill? A worksheet for church families.

The bottom line

• A church pantry is one of the best things a congregation can do, and doing it well means getting the dull things right: tax status, insurance, food safety and records.
• Call three people before you open: your insurance agent, your county health department and your regional food bank. Each will save you a mistake.
• Keep cold food at 41 degrees Fahrenheit or below and write the temperature down.
• Treat every guest as a neighbor. Ask little, protect privacy, offer choice, and open at hours working people can use.
• Serve everyone with no religious strings. Let your faith show in how you serve, not in what you demand.