53 9.3: Time as a Public Health Control (TPHC)
9.3 – Time as a Public Health Control (TPHC)
The FDA Food Code section 3-501.19 considers Time as a Public Health Control (TPHC), a critical food safety measure for managing potentially hazardous foods. This provision allows food establishments to use time alone, rather than time in conjunction with temperature, to control pathogen growth.
Written Procedures for TPHC Practices. Food establishments must develop and maintain written procedures on the premises detailing their TPHC practices. These procedures serve as a crucial documentation tool, ensuring consistency in food safety practices and facilitating regulatory oversight. The written procedures must outline:
Methods for complying with specific time and temperature requirements
Processes for preparing, cooking, and refrigerating food before implementing TPHC
Time Limits and Temperature Controls
When using TPHC, food establishments have two options:
4-Hour Rule: Foods can be held without temperature control for up to 4 hours.
6-Hour Rule: Cold foods can be held for up to 6 hours, provided they remain below 70°F (21°C) (Florida Department of Health).
Products shall be 41° F or below, or 135° F or above when removed from temperature control.
Products must be marked/identified; indicating what time the product was removed from temperature control.
Products may be cooked or served within the 4-hour window. At the 4-hour mark, products must be discarded.
Discard time of products must be recorded.
Any product unmarked or unidentified with the time it was removed from temperature control or has expired must be discarded.
_____________________________________________________________________________
TPHC Marking and Monitoring
Foods under TPHC must be clearly marked or identified to indicate:
The time when the food was removed from temperature control
The discard time (4 or 6 hours later, depending on the chosen method)
Compliance with TPHC Cooling Requirements
Food establishments must also ensure compliance with cooling requirements (section 3-501.14) for foods prepared and refrigerated before TPHC is applied. This additional step helps maintain food safety throughout the entire preparation and service process. By implementing these TPHC procedures, food establishments can effectively manage food safety risks while maintaining operational flexibility. However, it’s crucial that staff are well-trained in these procedures and that the establishment maintains strict adherence to the time limits and marking requirements to ensure public health protection (FDA Food Code).
Time – Maximum Up to 4 Hours
Strict guidelines are established by the Food Code for time as a public health control measure to ensure food safety. When using time without temperature control for up to 4 hours, food must adhere to specific initial temperature requirements and marking procedures.
For most foods, the initial temperature must be 41°F (5°C) or below when removed from cold holding, or 135°F (57°C) or above when removed from hot holding. However, certain ready-to-eat fruits, vegetables, and hermetically sealed foods may have an initial temperature of 70°F (21°C) or less, provided they do not exceed this temperature within the 4-hour period.
All foods subject to time control must be clearly marked to indicate when the 4-hour limit will expire. This marking is crucial for proper tracking and ensures that food is either served, cooked, or discarded within the safe time frame. Any food in unmarked containers or exceeding the 4-hour limit must be discarded to prevent potential foodborne illness risks (Food Code, 2022).
Time – maximum up to 6 hours
The FDA Food Code allows for time as a public health control measure for certain foods, permitting them to be held without temperature control for up to 6 hours under specific conditions. This provision is designed to balance food safety with operational flexibility in foodservice establishments. According to the FDA (2022), foods initially at 41°F (5°C) or below can be held without temperature control for up to 6 hours, provided their temperature does not exceed 70°F (21°C) during this period. This approach is based on scientific evidence showing that pathogen growth remains limited within these time and temperature parameters.
The 6-hour time frame is critical, as it represents the maximum duration during which the food can be safely held without exceeding the upper temperature limit. The Centers for Disease Control and Prevention (CDC) emphasizes that this time-temperature relationship is crucial in preventing the rapid multiplication of foodborne pathogens in the “danger zone” between 41°F and 135°F (5°C and 57°C). The United States Department of Agriculture (USDA) concurs, noting that adhering to these time and temperature controls is essential for maintaining food safety and reducing the risk of foodborne illness outbreaks in food service operations (USDA).
______________________________________________________________________________
Examples of TPHC foods would include: cut lettuce, carrots, and tomatoes on a salad buffet or salad bar; milk at a barista station; shell-eggs at a breakfast station.
TPHC restrictions: TPHC foods are not allowed in some jurisdictions; food cannot be returned to temperature control; raw eggs may not be made available for self-service; written procedures to enact the Food Code should be considered in advance.
______________________________________________________________________________
It’s important to note that this 6-hour rule is part of a comprehensive food safety management system. The FDA requires that foods held under this provision be monitored and marked to ensure compliance with the time and temperature limits. Additionally, any food that exceeds either the time limit or the maximum temperature must be discarded immediately to protect public health (FDA).