Time As a Public Health Control
- Jul 16
- 3 min read

Time without temperature control may be used for a working supply of TIME/TEMPERATURE CONTROL FOR SAFETY FOOD (TCS food) under carefully controlled conditions.
Some examples include:
A working supply of sliced tomatoes could be held without refrigeration at a sandwich make table for up to four (4) hours if the proper public health controls are in place.
Pizza for sale by the slice could be held in a display case at less than 135°F for up to four (4) hours if the proper public health controls are in place.
A working supply of raw shell eggs could be held without refrigeration for up to four (4) hours next to a grill where eggs are cooked to order if the proper public health
controls are in place.
Slices of chilled melon could be put out for service on a buffet line for up to six (6) hours if the melon slices have a temperature of 41°F or less when they are put on display, their temperature never exceeds 70°F, and the proper public health controls are in place.
A charcuterie board of meats and cheeses could be put out at a catered tailgate party for up to six (6) hours if the meats and cheeses have a temperature of 41°F or less when they are put on display, their temperature never exceeds 70°F, and the proper public health controls are in place.
A Written Procedure Is Required To use time as a public health control instead of
temperature control, the FOOD ESTABLISHMENT must do the following:
Prepare written procedures in advance regarding how food products will be safely
handled using time as a public health control.
Maintain these written procedures in the FOOD ESTABLISHMENT where they are available for the Health Department to see, upon request.
A Procedure for a 4-Hour Holding Time Must Include: Food with an internal temperature of:
41°F or less when removed from cold holding temperature control, or
135°F or greater when removed from hot holding temperature control.
The food must be marked or otherwise identified to indicate the time that is 4 hours after the time when the food was removed from temperature control.
Within 4 hours after the time when the food was removed from temperature control, the
food must be:
Served at any temperature if it is a READY-TO-EAT food,
Cooked and served, or
Discarded.
Food not under temperature control in containers or packages not marked with the
time they must be discarded shall be immediately discarded.
A Procedure for a 6-Hour Holding Time Must Include:
The food must have an internal temperature of 41°F or less when removed from
cold holding temperature control.
The internal temperature of the food must be monitored and it may not exceed
70°F during the 6-hour holding period (unless an ambient air temperature is
maintained that ensures the food does not exceed 70°F during the 6-hour holding
period).
The food must be marked or otherwise identified to indicate the time that is 6 hours after the time when the food was removed from temperature control.
Temperature monitoring is required. The food must be discarded if its temperature exceeds 70°F. Keep records!
Within 6 hours after the time when the food was removed from temperature control, the food must be:
Served at any temperature if it is a READY-TO-EAT food,
Cooked and served, or
Discarded.
Food not under temperature control in containers or packages not marked with the
time they must be discarded shall be immediately discarded.
NOTE: FOOD ESTABLISHMENTS such as hospitals, nursing homes, assisted living facilities, senior centers, or child or adult day care centers that serve a HIGHLY SUSCEPTIBLE POPULATION (persons who are more likely than other people in the general population to experience foodborne disease because they are immunocompromised,
preschool age children, or older adults) may not use time as a public health control for raw eggs.
Using Time as a Public Health Control at Temporary Events
At temporary events of brief (less than 4 hours) duration such as some fairs or festivals, using time as a public health control may be an especially useful procedure. In these settings where ambient air temperatures may be quite hot and mechanical refrigeration is not available, the use of ice chests or coolers alone may be inadequate to consistently hold foods below 41°F.
Similarly, at these temporary events there is often inadequate equipment for hot holding food
above 135°F once it has been cooked. Using time as a public health control reduces the need for hot holding cabinets, steam tables, or other equipment commonly found in a fully equipped commercial kitchen.



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