Marking Discard Times for TPHC Foods

Time as a public health control (TPHC) is when time and temperature control for safety (TCS) foods are held without temperature control for up to four or six hours (depending on the rule option used) if they meet certain time limits and other guidelines in the regulations.  When using TPHC, if the food is not used within four to six hours, the food must to be discarded.   The use of TPHC has benefited many food service operations; however, since its allowance, confusion has often been found during inspections about how TPHC foods should be marked to identify when they need to be discarded.  Some facilities were noting the time the food was removed from temperature control while others were noting the time the food was to be discarded. 

To comply with the way the specific rule is written, all food service operations using TPHC are now required to mark or otherwise identify the discard time for all items that are under time as a public health control.  [The time the TCS food is removed from temperature control may still be noted; however, the discard time must also be noted.]   In addition, when TCS foods are held under the 6-hour TPHC rule, that food needs to be marked with the time the food was removed from refrigeration and the time that is 6 hours past the point in time when the food was removed from temperature control (i.e. the discard time).

For more information on the requirements for time as a public health control (TPHC), please see the Food Service Rules and Regulations located on our website.

One-Day ServSafe Course Available in Cobb!

Cobb & Douglas Public Health will offer a special, one-day ServSafe  Food Safety Managers class on Wednesday, November 6th.  This will be a good opportunity for persons that need to recertify, first-timers who already have a strong food safety foundation, and those that need to retake the ServSafe exam.

The class will be held in the 2nd floor meeting room located on the Marietta Health Center Campus at Building B (1738 County Services Pkwy, Marietta, GA 30008).  The deadline for registration is October 9, 2019. Please share this information with those you believe may be interested. See the registration form or our website for more information.

Straight from the Field: Overflowing Dumpsters!

By Parish Divinity, EHS3

While performing a change of ownership inspection at one of my facilities, I saw what was captured in the image posted above. Garbage should not be left on the ground outside of the dumpster. Not only is it an eyesore but it can attract the attention of insects and rodents.  This violation was documented on the inspection report under 17-B, Garbage/refuse properly disposed; facilities maintained.  Per the Georgia Department of Public Health Rules and Regulations for Food Service, 511-6-1.06(5) (p) and (r):

Maintaining Refuse Areas and Enclosures. A storage area and enclosure for refuse, recyclables, or returnables shall be maintained free of unnecessary items and clean.

Frequency. Refuse, recyclables, and returnables shall be removed from the premises at a frequency that will minimize the development of objectionable odors and other conditions that attract or harbor insects and rodents. 

Be mindful to monitor the refuse storage area frequently to make sure that the garbage inside the dumpster is being removed.  This will prevent the buildup of food debris and trash that can attract unwanted insects and rodents. Other tips to help keep the area sanitary include posting a “CLOSE DOOR AFTER USE” sign on the dumpster as a reminder for user,  keeping the dumpster’s drain plug securely in place to prevent the entry of rodents, and arranging to have the dumpster rinsed, as needed, by its service company.

Don’t Forget To Date Mark Your Frozen Prepared TCS Foods!

For quite some time, we have emphasized the importance of date marking ready-to-eat TCS* foods that are being held more than 24-hours after preparation in order to minimize the possibility for the growth of Listeria–a pathogenic bacteria that is capable of growing at refrigerated temperatures.   [The maximum hold time for these date marked foods can be no longer than 7 days from the preparation date of the oldest prepared TCS food used as an ingredient.]  This same requirement also applies to the opening of commercially prepared TCS foods, which can’t be consumed beyond their expiration date or a 7 day hold time—whichever comes first.  One often overlooked scenario is the proper date marking of prepared foods that are frozen for later use.  Freezing food may stop the growth of Listeria, but that’s not enough to kill it!

Freezing prepared TCS foods will stop the 7 day clock: however, the initial preparation and holding of the food has to be taken into account.  The table shown above gives an example of how such date marking should be implemented.  In this case, chicken was cooked and cooled, the morning of Day One and is date marked with the Date Prepared/Opened (October 1).   After being refrigerated for 2 days, it was then placed in the freezer the morning of Day Three and marked with that date as the Date Frozen (October 3).  The day that the prepared TCS food was removed from the freezer to thaw  is noted as the Pull Date (October 10) and the clock starts ticking again.

The time the prepared TCS food was held before freezing at 41°F or less (in this case two days, October 1 and 2) is subtracted from the 7 day total, which allows us to determine the Discard Date.  In this example, the Day Seven discard date marked is October 14.  Thus, the chicken must be consumed or discarded by the end of the day on October 14.

Click here for a date marking label template that can be used for tracking TCS food that is frozen after preparation. 

*Time and temperature control for safety

Food Safety Videos Available!

Over the past few years, Cobb & Douglas Public Health has hosted several Food Safety Partnership Panels composed of four participants representing the food service industry, public health, and consumers.  Each video is about 30 minutes in length, highlights an area needing emphasis at the time of the recording, is good for training, and is available at

This time of year, we like to emphasize the importance of having a safe food source.  Partnership Panel #13– entitled Safe Food Source–reminds the viewer of questions operators should ask of their food suppliers– along with red flags to keep in mind–when deciding whether a food source is acceptable for a food service establishment to use or is safe to use as a consumer.  The panel also takes a look at the illegal slaughter of animals for meat–which is a more frequent occurrence as we get closer to the holidays, and much more.  Check out this video along with the various other topics available on our website.

Food Safety Education Month Is Here!

A message from Food Program Manager Karen Gulley

Greetings during Food Safety Education Month!

During the month of September, we will be sharing information regarding new regulatory requirements and expectations in Georgia, along with reminders of basic food safety principles. A new resource entitled Food Safety Ninja will help with compliance in these areas. We give shout-outs to the Lake County General Health District (Ohio) for helping to make current food safety principles understandable in a fun and informative way.

Available in English, Spanish and Chinese, this project– which was funded by an FDA grant–uses short videos, narratives and quizzes, to explore proper date-marking (even when you’re freezing ready-to-eat foods), hand washing, chemicals, employee illness, cold and hot holding, reheating, and cooling. The site houses a wealth of information for anyone interested in food safety, especially food safety operators seeking tools for staff training.

Remember to always think food safety–and Happy Food Safety Education Month!