Cooking, cooling, holding and date marking temperatures

These are the numbers a kitchen touches every day, and the ones an inspector asks the person in charge to recite from memory.⁵ They all come from two rules — 3717-1-03.3 for killing organisms and 3717-1-03.4 for stopping them growing.⁶

Laid out here in the order a kitchen actually meets them.

Cooking

Raw animal foods must be cooked so all parts reach one of these:¹

155°F has alternatives most kitchens never use but which are legal: 145°F for 3 minutes, 150°F for 1 minute, or 158°F instantaneously.¹ Useful if you are cooking sous vide or holding a low temperature deliberately.

“Intact” is doing real work in that table. A whole muscle is 145°F. Grind it, tenderize it, needle it or inject it and it becomes non-intact at 155°F — because whatever was on the surface is now through the middle. The same beef sits in two different rows depending on what your supplier did to it.

Stuffing is the trap. Stuffed pasta is 165°F. Not because pasta is risky, but because the stuffing insulates and the whole item has to get there.

Microwaves are their own rule

Raw animal foods cooked in a microwave must be rotated or stirred during cooking, covered to retain surface moisture, heated to 165°F in all parts — regardless of what the food is — and then left covered to stand for two minutes to equalize.¹ That standing time is part of the cook, not a courtesy.

Whole roasts get a chart of their own

Whole beef, corned beef, lamb, pork and cured pork roasts may be cooked low and slow on a published time-and-temperature curve, from 130°F held for 112 minutes up to 158°F instantaneously.¹ Oven temperature is also specified, by roast weight and oven type — for a roast under 10 lb in a still dry oven, 350°F or more.¹ If you are cooking prime rib or a deli roast this way, work from the rule rather than from habit.

Rare steak, legally

A whole-muscle, intact beef steak may be served rare if the operation does not serve a highly susceptible population, the steak stays intact, and both top and bottom surfaces reach 145°F with a cooked color change on all external surfaces.¹⁴

Anything else served raw or undercooked on request — tartare, soft eggs, lightly cooked fish, raw shellfish — is allowed only if you are not serving a highly susceptible population and you run the consumer advisory below, or you hold a variance backed by a HACCP plan.¹

The consumer advisory

If you serve any animal food raw or undercooked, you owe consumers two separate things, and most menus carry only one.³

1. Disclosure — say which items they are. Either describe them (“oysters on the half shell (raw oysters)”, “raw-egg Caesar salad”, “hamburgers (can be cooked to order)”) or asterisk them to a footnote saying the items are served raw or undercooked, or contain raw or undercooked ingredients.³

2. Reminder — asterisk those items to a footnote using one of these three wordings:³

“Regarding the safety of these items, written information is available upon request”

“Consuming raw or undercooked meats, poultry, seafood, shellfish, or eggs may increase your risk of foodborne illness”

“Consuming raw or undercooked meats, poultry, seafood, shellfish, or eggs may increase your risk of foodborne illness, especially if you have certain medical conditions”

An asterisk with no reminder footnote does not satisfy the rule, and neither does a reminder with nothing asterisked. It can live on brochures, deli case or menu advisories, label statements, table tents, placards, or any other effective written means — it does not have to be the menu.³ It does have to be written.

Worth checking your menu against this today. It costs a reprint to fix and it is one of the easiest findings an inspector will ever write.

Holding

Cooling — the one that fails

Cooked food must be cooled:²

• 135°F → 70°F within 2 hours, and
• 135°F → 41°F within 6 hours total

The first stage is where kitchens fail, and the arithmetic explains why: the food is hottest, the temperature gap is largest, and a full cambro of chili simply cannot shed that heat in two hours. If you miss the two-hour mark you have not lost four hours of slack — you have lost the batch.

Food prepared from ambient-temperature ingredients — reconstituted foods, canned tuna — gets 4 hours to 41°F.² So does TCS food legally received above 41°F.²

Approved methods, and you may combine them:²

• Shallow pans
• Smaller or thinner portions
• Rapid cooling equipment (a blast chiller)
• Stirring in a container set in an ice water bath
• Containers that transfer heat well
• Ice as an ingredient

Two details from the rule that a plastic lid quietly defeats: containers must be arranged for maximum heat transfer through the container walls, and left loosely covered or uncovered during cooling.² Sealing a hot container is the single most common cooling mistake, and it is the intuitive thing to do.

Thawing

Four legal routes:²

1. Under refrigeration holding the food at 41°F or less.
2. Completely submerged under running water at 70°F or below, with enough velocity to float loose particles off in an overflow — and for no longer than lets ready-to-eat portions rise above 41°F, or raw animal food sit above 41°F for more than four hours including prep time.
3. As part of the cooking process, or microwave-thawed and moved immediately to conventional cooking with no interruption.
4. Any method at all for a portion of ready-to-eat food thawed and prepared for immediate service on a customer’s order.

Note what is missing: a sink of standing water is not on the list, and neither is a prep table.

Date marking

Refrigerated, ready-to-eat TCS food held more than 24 hours must be clearly marked with the date or day by which it is to be consumed, sold or discarded — a maximum of seven days at 41°F or below, with the day of preparation counted as day one.²

For commercially packaged ready-to-eat TCS food, the clock starts the day you open the container, and your date may not exceed the manufacturer’s use-by date where that date was set for safety.²

Combine two dated items and the mix keeps the earliest date.² Yesterday’s chicken folded into today’s salad makes a salad that is a day old.

Any system works — calendar dates, days of the week, color-coded dots — as long as you can explain it to your licensor on request.²

What gets discarded

Food covered by the rule must be thrown out if it exceeds the time or temperature, if the container bears no date at all, or if it is marked with a date beyond the allowed combination.² An unmarked container is a discard on its own, regardless of how fresh it actually is.

What is exempt

Individual meal portions served or repackaged from a bulk container on request, and shellstock.² Also exempt, when prepared and packaged by an inspected food processing plant: deli salads, hard cheeses at 39% moisture or less, semi-soft cheeses between 39% and 50%, cultured dairy such as yogurt and sour cream, preserved fish such as pickled herring and salt cod, shelf-stable dry fermented sausage such as pepperoni, and shelf-stable salt-cured products such as prosciutto.²

Reheating

The condition people miss: reheating must be rapid, and the time the food spends between 41°F and the target may not exceed two hours.¹ A steam table is a holding device, not a reheating device — it cannot get there fast enough, and using it that way is a violation even if the food eventually reads 165°F.

That last row is real and useful: a roast beef sandwich au jus built to order from cooked, refrigerated beef may be served at any temperature.¹

Time instead of temperature

You may run food on a clock rather than a thermometer, but only with written procedures prepared in advance, kept on site and available to your licensor.²

Four-hour route: the food starts at 41°F or less, or 135°F or more. Mark it with the time four hours out. Cook and serve, serve if ready-to-eat, or discard within four hours. Unmarked containers, or ones marked beyond four hours, are discarded.²

Six-hour route: the food starts at 41°F or less and must not exceed 70°F at any point in the six hours.²

This is a genuinely useful tool for a busy line or a buffet, and it is also the one most often run informally — which is to say, without the written procedure that makes it legal.

Freezing fish for raw service

Before serving raw, raw-marinated, partially cooked or marinated-partially cooked fish, it must be:¹

• Frozen and stored at −4°F or below for 168 hours (7 days); or
• Frozen at −31°F or below until solid, then stored at −31°F or below for 15 hours; or
• Frozen at −31°F or below until solid, then stored at −4°F or below for 24 hours

Exempt: molluscan shellfish; scallop product consisting only of the shucked adductor muscle; several named tuna species including yellowfin, bigeye and both bluefins; certain aquacultured fish such as net-pen or land-raised salmon fed formulated feed containing no live parasites; and fish eggs removed from the skein and rinsed.¹

Keep the records. The person in charge must record the freezing temperature and time and retain it for 90 calendar days beyond service or sale — or hold a written statement from the supplier saying the fish was frozen to spec.¹ The supplier letter is the practical route, and it is worth getting one on file before you put crudo on a menu rather than after an inspector asks.

What this means for equipment

Nothing here works without measurement. A calibrated probe thermometer, a thin-mass probe for patties and fillets, and a thermometer in every refrigerated unit are all separately required — see what has to be in the kitchen.

And the two-hour cooling stage is an equipment question before it is a procedure question. If you regularly cool large volumes, shallow pans and an ice bath will get you only so far; that is the argument for a blast chiller, and it is a better argument than most equipment pitches because it is a number you can test against your own product with a thermometer and a timer this week.