Years ago there was a legendary commercial starring a corpulent Orson Wells who solemnly gazed into the camera with a wine glass in hand and told all of American, “Paul Masson will sell no wine before its time.”
While wine may age gracefully and improve over time, most food, especially prepared foods, do not. In fact, everyone in the industry would be wise to announce, “We shall serve no food after its time.”
The proper control and management of time and temperature are not only two of the most important components of an effective food safety management program, but improper time and temperature control are the two most common critical violations of the FDA Food Code and a leading cause of foodborne illness. In fact, time and temperature control is so important, what was previously referred to as a “Potentially Hazardous Food” (PHF) has officially been renamed “Time and Temperature Control for Safety” (TCS) Food.
Despite this emphasis on the proper control and management of time and temperature, the FDA Food Code establishes a procedure referred to as Time as a Public Health Control (TPHC). Simply put, this means if food establishments meet certain time limits and other guidelines, they can hold foods for four to six hours without temperature control. If properly understood and executed this can be a tremendous help to a foodservice operation.
Before this change in the Food Code, all prepared, ready-to-eat foods had to be maintained out of the temperature danger zone (41°F-135°F). Based on the current definition of the temperature danger zone, that means holding hot foods at a minimum temperature of 135°F and holding cold foods at a maximum temperature of 41°F.
The Food Code recognizes that even if a food has been prepared properly, it will take several hours for any pathogens to multiple to a dangerous level. That is also why there are specific rules and guidelines that must be followed to use time as a public health control.
What are those rules and guidelines? The following include the main requirements for preparing foods using Time and Temperature Control for Safety System:
✓ Written procedures explaining your specific operation must be maintained and available for review at all times. If you have a comprehensive food safety management plan already in place, this is just another piece of the puzzle.
If foods are prepared in advance of being held, written procedures must be available for each process. In other words, if you are cooking, cooling and cold-holding before you use time as a control, you must demonstrate you have a system for monitoring temperatures and documenting the cooking, cooling and holding procedures.
✓ All foods must be properly labeled to indicate when time control begins and when the time period expires.
Include in the written procedures that if any foods have not been properly labeled, they will be immediately discarded.
✓ All foods must be discarded once they reach their established time limit, whether it is four or six hours.