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Once food has been held using time as a public health control, if it’s not consumed, it must be discarded. The food cannot go back into cold or hot holding and it cannot be reheated. The only acceptable action is for the food to be discarded.

What foods can be held by time alone?

All TCS Foods except raw eggs awaiting preparation for a high risk population, such as the very elderly, very young, immune system compromised, etc.

✓ Smoked and vacuum-packed foods

What temperatures should the hot and cold foods achieve when the TPHC period begins?

This may vary according to your local food code. However, based on the FDA Food Code:

✓ Cold food must be at 41°F or colder.

✓ Hot food must be at 135°F or hotter.

What foods can be held for up to six hours instead of four hours?

✓ Cold food can be held for up to six hours if the starting temperature was 41°F or colder or you can verify, through temperature monitoring and recordkeeping, that the temperature of the food never reached 70°F.

If you know and understand the rules, you can see how you can use time without temperature as a control. You can also see how it helps you save time and money in certain situations without placing your customers at risk. You can also see the value of having a solid food safety management program in place and how it will allow you to employ TPHC.

It may even give you some extra time to enjoy a glass of wine that was not served before its time.


Steven Sklare is a sales executive for food safety services at SGS. He has been working in the food Industry for more than 20 years performing supply chain risk management, food safety audits and training, food safety management plan design and pest control services. He can be reached at cts.media@sgs.com.