Acceptable Corrective Actions for Deviation in Hot Holding?
I am a school-trained culinarian, have food manager manager certification, have had food handler training/cards in three states and various counties within those states, have a company-provided HACCP program manual and I just paid $200 for a food safety HACCP course that can't answer this question:
Can food that is in the danger zone be served?
There is often talk about time and temperature and there are clear numbers that define the danger zone (though it varies slightly state to state and county to county); it is clear that the time in the danger zone should be minimized; my own company's food audit form docks points for food that is in the danger zone; but, nowhere can I find clear and direct information that answers this basic question.
Thanks for any input.
hi Iconoclast ,
This process should be studied well for food safety , TCS is very specific and required standardized cooking and holding process , also good practices of forecasting and projection to minimize the product reaching the end of holding time , it is a long issue ,any way ,
You can refer to Food code v 2013 , U.S. Public Health Service , FDA (https://www.fda.gov/...e/UCM374510.pdf )
in the annex you will find tables for what you are asking
a)Chart 4-A Summary Chart for Minimum Cooking Food Temperatures and Holding Times Required by Chapter 3
I am a school-trained culinarian, have food manager manager certification, have had food handler training/cards in three states and various counties within those states, have a company-provided HACCP program manual and I just paid $200 for a food safety HACCP course that can't answer this question:
Can food that is in the danger zone be served?
There is often talk about time and temperature and there are clear numbers that define the danger zone (though it varies slightly state to state and county to county); it is clear that the time in the danger zone should be minimized; my own company's food audit form docks points for food that is in the danger zone; but, nowhere can I find clear and direct information that answers this basic question.
Thanks for any input.
Hi Iconoclast,
The difficulty with yr query is that the answer is not necessarily black or white unless you automatically discard as your corrective action.
I extracted these comments/pic from the attachments below -
How often you monitor the temperature of foods during hot holding determines what type of corrective action you are able to take when 135 ºF is not met. If the critical limit is not met, your options for corrective action may include evaluating the time the food is out of temperature to determine the likelihood of hazards, and based on that evaluation, reheating or discarding the food. Your frequency of monitoring during this operational step may mean the difference between reheating the food to 165 ºF or discarding it.
(RH1 - Pg 39)
Determining the most appropriate on-site correction of out-of-control procedures such as inadequate hot and cold holding can be very complicated. Since determining on-site correction depends on a number of factors, you may need to conduct a hazard analysis of the food in order to determine the appropriate course of action to take. Annex 6 of this Manual lists the out-of-control procedures that may require a hazard analysis in order to determine the appropriate on-site correction. More information on conducting a hazard analysis is found in Annex 3.
(RH2 - Pg 24)
Limitations of Reheating as an On-site Correction
One on-site correction used in the field is reheating. A common misconception is that reheating is a “magic step” for eliminating hazards resulting from improper holding or cooling. If a ready-to-eat, potentially hazardous food is improperly held or cooled, the potential for spore or toxin-forming bacteria growth increases. Whether to recommend that the food be reheated or discarded depends on a number of factors
including, but not limited to –
• the hazards of significance
• the nature of the food
• its intended use
• other important considerations discussed later in this section including the degree of time and temperature abuse
Although reheating can eliminate vegetative bacterial cells resulting from post-cook contamination (i.e. Salmonella) or from improper holding or cooling (i.e. Clostridium perfringens), it has limitations that must be considered.
Some bacteria form spores that survive cooking. These spores can germinate and grow if food is improperly held after cooking. Bacterial spores are likely to be present in most foods. When a food is expected to contain spores of toxigenic bacteria such as Clostridium botulinum or Bacillus cereus, reheating may be ineffective. The emetic toxin of B. cereus, which has been largely associated with outbreaks in starchy foods, is very stable to heat. While the toxin of C. botulinum may be destroyed with extended reheating, the critical limit for reheating in the Food Code (165 ºF for 15 seconds) will not be effective in ensuring the food’s safety
.(RH2-Pg 24)
You should also look to see that the monitoring intervals are adequate enough to ensure hazards are being controlled. For instance, if hot holding is designated as a CCP and the plan states that the manager will check the product temperature only once per day, the lack of frequent temperature checks may allow time for spore-forming or toxin-forming bacteria to grow to dangerous levels without any ability to take corrective action. It is clear to see how important adequate monitoring is to achieving active managerial control.
(RH2-Pg 34)
Hot holding, intervention strategy.png 24.75KB 3 downloads
(RH2 – Pg75)
RH1 - Retail HACCP,FDA - Operators.pdf 555.5KB 36 downloads
RH2 - Retail HACCP,FDA - Regulators.pdf 701.1KB 25 downloads
I am a school-trained culinarian, have food manager manager certification, have had food handler training/cards in three states and various counties within those states, have a company-provided HACCP program manual and I just paid $200 for a food safety HACCP course that can't answer this question:
Can food that is in the danger zone be served?
There is often talk about time and temperature and there are clear numbers that define the danger zone (though it varies slightly state to state and county to county); it is clear that the time in the danger zone should be minimized; my own company's food audit form docks points for food that is in the danger zone; but, nowhere can I find clear and direct information that answers this basic question.
Thanks for any input.
Hi Iconoclast,
:welcome:
The answer to your question would depend on local legislation but put simply the answer is yes, for example from the FSA Guidance on Temperature Control Legislation in the United Kingdom
Downward Variation from the 63°C Minimum Hot Holding Temperature
56. A food business operator may offer a defence against failure to observe this requirement by proving that
- a well founded scientific assessment of the safety of the food at temperatures below 63°C has concluded that the food can be kept safely at that temperature for a specified period and
- the food was held in a manner that was justified in the light of the scientific assessment
Hot Holding Tolerance Period
57. A food business operator may offer a defence against failure to observe the requirement to keep foods at or above 63°C by proving that the food:
- had been kept for service or on display for sale for a single period of less than 2 hours.
58. This tolerance would also apply to a recommended temperature for hot holding lower than 63°C. At the end of the period of up to 2 hours, the food should be as quickly as possible cooled to a temperature of 8°C or below or discarded.
59. As with other defence provisions, the burden of proof rests with the food business operator to show that these defences can be used.
Kind regards,
Tony
Hi Iconoclast,
I am assuming that "in the danger zone" is referring to an event occurring during the (nominal) "hot holding" step.
The US Food Code, for the hot holding step, contains approaches to achieve FS via limits for both (a) Time (3-501.19 [B]) and (b) Temperature respectively, eg –
US Retail FS Control.png 71.78KB 4 downloads
(Validatory material for the time limit is presented in the Code)
So my answer to "able to be served" is Maybe depending on the elapsed time in (a) or on the FS corrective action/evaluation in (b)
PS @ Ehab Nassar, Thks yr Post - I found the FDA website a bit difficult to connect so might add that the Food Code 2013 is also available here -