Staying on Top of Key Drop Deliveries!

By Addie Zuniga, EHS2

An important duty of the person-in-charge (PIC) is to ensure the integrity and proper sourcing of food products received. This includes reviewing invoices, examining packaging, and verifying proper internal temperatures of Time-Temperature Control for Safety (TCS) foods as it comes into the facility. It’s the duty of the PIC to make sure packages are examined at the time of receipt, in order to reject any items that may appear damaged or tampered with, or TCS foods that are outside the safe temperature range.  But what about key drop deliveries?

Many food distributers run overnight routes, and this allows facilities the option of overnight deliveries. This is known as a “key drop delivery” – when food deliveries are dropped off in a kitchen, often inside a walk-in cooler, while the business is closed. This can be a convenient set-up, but how would the PIC maintain active managerial control over these deliveries when employees may not arrive at the facility for several hours after the truck has left?  The PIC must designate someone to look for damaged packaging or recalled products upon arrival, allowing those to be set aside for return and not served. However, temperature abuse can be hard to identify, especially if the TCS foods have already been in a walk-in cooler for a long period of time since delivery.  For example, there would be no way for the PIC to know if the refrigeration in the delivery truck had failed and that the TCS foods were transported for several hours in the temperature danger zone overnight, thereby posing a significant food safety risk. Therefore, it is not enough that a PIC simply verify internal temperatures of TCS foods when they arrive at the facility after a key drop delivery.

If a facility is considering key drop delivery, they must establish procedures with the distribution company, that the delivery drivers would be required to follow. There should be a written agreement in which the drivers are tasked with verifying and documenting the internal temperatures of a sample of TCS foods at the time of delivery, for the PIC to review. This is most often achieved by the driver noting the temperatures of various items on the invoice which is then left behind with the delivery.  These procedures may vary, but they should be detailed in the agreement. The PIC should maintain the right to reject these products, even after the driver has left, if they are not satisfied with documented temperatures or other conditions. This policy provides the PIC with the information they need to maintain managerial control over these products, and to know that they are safe for service.

This contract and procedure between the facility and the distributor must be approved by the health authority prior to key drop deliveries being implemented. The PIC should also keep a copy of the signed contract, as well as a recent sample of documented delivery temperatures, onsite for review during each health inspection. This documentation indicates to the health inspector that the PIC is maintaining active managerial control, and that foods are arriving safely and from approved sources.  If you are interested in key drop deliveries, please review the Key Drop Deliveries guidance document produced by Georgia Department of Public Health and our website for additional information. 

NEW: Debiting of Cold Holding Temperatures Above 41ºF

The safe cold holding temperature for time and temperature control for safety (TCS) foods is 41ºF.  Please note that a grace will no longer be allowed for temperatures observed above this (for example at 43ºF) when the item is considered to be in cold holding.    A temperature above 41ºF or more when cold-held would constitute a 9-point violation.  Facility operators are asked to ensure that all TCS food temperatures are monitored to help ensure the compliance temperature of 41ºF or below is maintained in order to help inhibit the growth of harmful foodborne illness causing bacteria.  [Note: We will allow for the calibration of thermometers within 1 to 2 ºF.]

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.

Think Food Safety As You Celebrate!

The desire to go out to dinner increases during times of celebration, such as Mother’s Day.  This increase in dining contributes to an increase in the potential for foodborne illness.  As food workers try to serve the increased volume of customers, there is a temptation to cut corners in order to keep things moving faster.  Please take some time to review Tips for Time and Temperature Control (TCS) Foods provided online by Gordon Foods as a quick reminder of key food safety principles to keep in mind, whether preparing in a restaurant or at home.

Hope you have a happy–and safe–Mother’s Day.