Conference for Food Protection

The next revision of the FDA Food Code should require the Person-in-Charge of a food establishment that has a warewashing machine using a hot water sanitizing final rinse to have a temperature measuring device that measures the utensil surface temperature.

The Food Code currently requires under 4-302.14 Sanitizing Solutions, Testing Devices that "A test kit or other device that accurately measures the concentration in MG/L of SANITIZING solutions shall be provided" and furthermore under 4-501.116 Warewashing Equipment, Determining Chemical Sanitizer Concentration that the "Concentration of the SANITIZING solution shall be accurately determined by using a test kit or other device."

As far as hot water mechanical operations, the Food Code currently requires, in part, under 4-703.11(B) that "...Hot water mechanical operations...and achieving a UTENSIL surface temperature of 71 degrees C (160 degrees F) as measured by an irreversible registering temperature indicator."

In the case of hot water mechanical operations, the Food Code does not explicitly require both the availability and the use of an irreversible registering temperature indicator or similar device.

It should also be noted that the January 2000 FDA Plan Review Guide, Part 8 - Warewashing Facilities, under mechanical warewashing utilizing hot water for sanitization on page 81, states: "An approved maximum registering thermometer or high temperature test papers shall be available and used."

Reliance on the machine's fixed TEMPERATURE MEASURING DEVICE to determine if SANITIZATION has been achieved can be problematic as these devices are not routinely calibrated and may be in disrepair even if the machine itself is working properly. The use of a field temperature indicator (or similar) in conjunction with the fixed pressure gauge and fixed TEMPERATURE MEASURING DEVICE is appropriate to determine if SANITIZATION has been achieved.

Effective SANITIZATION destroys organisms of public health significance that may be present on food equipment and utensils after cleaning or which may have been introduced into the rinse solution.

that a letter be sent to the FDA requesting the 2009 Food Code (as modified by the Supplement issued in 2011), Section 4-302.13, be amended as follows (new language shown with underline):

Temperature Measuring Devices, Manual and Mechanical Warewashing

(A) In manual warewashing operations, a temperature measuring device shall be provided and readily accessible for frequently measuring the washing and sanitizing temperatures.

(B) In mechanical WAREWASHING operations, an approved irreversible registering indicator or waterproof maximum registering thermometer shall be provided and used regularly for measuring the final rinse temperature at the utensil surface.