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temperature of a potentially hazardous food (TCS food) itself, rather than the temperature between packages, is necessary for regulatory citations. In large holding units and on steam tables, it is necessary to take the temperatures of foods in various locations to ensure that the equipment is working properly. If deviations are noted in the product temperatures, it is important to take extra steps to find out whether the problem is the result of equipment failure or whether a breakdown in a process such as cooling or reheating is the reason for the problem.

Corrective actions for foods found in violation should be required based on the jurisdiction’s regulatory food code. If foods are to be discarded, forms such as those used for stop sale or embargo may need to be completed and signed by the person in charge in accordance with the jurisdiction’s regulatory food code. In order to properly evaluate the degree of time and temperature abuse and the proper disposition of the affected food, several issues must be considered. Answers to these questions, in combination with observations made during the inspection, should provide inspectors with enough information to make the appropriate recommendation for on-site correction:

  • Are there any written procedures in place for using time alone as a public health control and, if so, are they being followed properly?

  • What are the ingredients of the food and how was it made?

  • Is it likely that the food contains Clostridium perfringens, Clostridium botulinum, or Bacillus cereus as hazards?

  • Has there been an opportunity for post-cook contamination with raw animal foods or contaminated equipment?

  • If there has been an opportunity for post-cook contamination, can the hazards of concern be eliminated by reheating?

  • Are the food employees practicing good personal hygiene including frequent and effective handwashing?

  • Was the food reheated or cooked to the proper temperature before being allowed out of temperature control?

  • What is the current temperature of the food when taken with a probe thermometer?

  • How long has the food been out of temperature control (ask both the manager and food employees)? Are the answers of the food employees and the manager consistent with one another?

  • Is it likely that food has cooled to its current temperature after being out of temperature control for the alleged time?

  • Will the food be saved as leftovers?

  • How long before the food will be served?

  • Given what is known about the food, the food’s temperature, the handling of the food, and the alleged time out of temperature, is it reasonably likely that the food already contains hazards that cannot be destroyed by reheating?

Even if food can be reconditioned by reheating, steps should be taken by the person in charge to ensure compliance in the future. Examples include repairing malfunctioning or inoperative equipment or implementing a risk control plan (RCP) to modify

Annex 5 – Conducting Risk-based Inspections 528

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