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.

More food safety rules

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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