Conference for Food Protection

2018 Biennial Meeting

Issue View | Council III | 2018 Scribe Packet

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Issue Number: Council III 020

Issue History

This is a brand new Issue.


Amend Food Code - Reheating RTE Food to be Held Using TPHC

Issue you would like the Conference to consider

Clarify the requirements for the use of time as a public health control (TPHC) under Food Code Section 3-501.19 when ready-to-eat foods are reheated and then immediately held using time alone as the public health control. This section currently addresses foods cooked and then held using TPHC and implies that foods must be hot held before being held using time alone as the public health control, but it is not clearly specified in the codified language or Annexes. The time requirement of two hours should apply to foods that are reheated and then held using TPHC.

Public Health Significance

If ready-to-eat foods are allowed to remain in the temperature danger zone for prolonged periods of time during reheating before being held using time as a public health control, pathogens such as Clostridium perfringens and Bacillus cereus could grow and produce enterotoxins.

Recommended Solution: The Conference recommends...

that a letter be sent to FDA requesting clarification of Section 3-501.19 to indicate foods reheated prior to being held using time as a public health control must be reheated as specified in Section 3-403.11.

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