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preparation procedures or to institute a procedure for monitoring holding temperatures of food.

If using time only or time-temperature combinations in lieu of temperature for controlling the growth and toxin-formation of pathogenic bacteria, strict controls must be in place and followed. Inspectors should verify that the written procedures are on-site and followed in accordance with the Food Code.

Date marking is the mechanism by which active managerial control of time-temperature combinations can prevent the growth of Listeria monocytogenes in potentially hazardous (TCS), ready-to-eat foods during cold storage. With exceptions, all ready-to- eat, potentially hazardous foods (TCS foods) prepared on-site and held for more than 24 hours should be date marked to indicate the day or date by which the foods need to be served or discarded. Inspectors should ask questions to ascertain whether the system in place to control for L. monocytogenes meets the intent of the Food Code. Food that should be date marked and is not should be discarded.


Assessing Reheating for Hot Holding

In order to assess a food establishment’s control of reheating for hot holding, the time of day that the inspection occurs is a key factor. Every effort should be made to schedule an inspection during pre-opening preparation. If inspections are conducted during pre- opening preparation or other preparation periods, inspectors should ask questions regarding the history of hot-held foods. Foods in compliance for minimum hot holding temperatures may have in fact been improperly reheated before being placed into hot holding units or steam tables.

If items are found “reheating” on the steam table, further inquiry is needed to assess whether the equipment in question is capable of reheating the food to the proper temperature within the maximum time limit. Corrective action for foods found out of compliance for reheating for hot holding would depend on how long the food had been out of temperature and other factors. In most cases, however, the food may be rapidly reheated and hot held.


Assessing Cooling

Improper cooling remains a major contributor to bacterial foodborne illness. Cooling temperatures and times need to be closely evaluated during every inspection. In order to assess whether a food establishment has control over cooling, the time of day that the inspection occurs is critical. Early morning inspections allow an opportunity to verify that leftovers from the night before were cooled properly or cooled using a proper cooling method. Alternatively, afternoon inspections may allow an inspector to verify cooling of products that may have been prepared that morning. Because many food establishments prepare bulk products only on certain days of the week, it is essential that inspectors become as familiar as possible with each operation and schedule their inspections accordingly.

Annex 5 – Conducting Risk-based Inspections 529

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