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.