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Issue Number: Council I 004


Change definition of PHF/TCS to TCS

Issue you would like the Conference to consider

Following issuance of the final report "Evaluation and Definition of Potentially Hazardous Foods" (Technologists, 2010) by the Institute of Food Technologists (IFT) on December 31, 2001 the recommendation was made to change the name of "potentially hazardous foods" or "PHF" to "temperature control for safety food" or "TCS". The report advised that use of both terms (e.g. PHF/TCS) during a transition phase would facilitate migration from one term to the next. Now over a decade since the IFT report, the transition term has been in common use in the FDA Food Code since 2005.

The definition of "Potentially Hazardous Food (Time/Temperature Control for Safety Food)", abbreviated PHF/TCS in the FDA Food Code, has now been in common use for over six years. While it has served its purpose for introducing the new term, the time has come to complete the migration to the new definition. The definition and abbreviation for "Potentially Hazardous Food (Time/Temperature Control for Safety Food)" or "PHF/TCS" should be modified to drop the reference to "potentially hazardous food" and "PHF". Instead, the definition should read "Time/Temperature Control for Safety Food" abbreviated as "TCS".

Public Health Significance

By eliminating use of both terms, the final intent of the IFT report will be realized by simply using the term "Time/Temperature Control for Safety Food" or "TCS". Stakeholders that use the FDA Food Code will be able to communicate clearly with others and the public more effectively using this simple term. Emphasis on time and temperature in the name of this definition will focus attention on critical elements of food safety that can be effectively controlled.

Recommended Solution: The Conference recommends...

that a letter be sent to the FDA requesting the following change to the 2009 Food Code (as modified by the Supplement issued in 2011):

Replace the current definition "Potentially Hazardous Food (Time/Temperature Control for Safety Food)" abbreviated as "PHF/TCS" with the new term "Time/Temperature Control for Safety Food" abbreviated "TCS" throughout the entire FDA Food Code.


Submitter Information

Name Chris Gordon
Organization Virginia Department of Health
Address 109 Governor Street
Richmond, VA 23219
Telephone 804-864-7417
Fax 804-864-7455
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