Time as a public health control: a written procedure and a 4-hour log for a café or restaurant

A pizza shop's topping rail, a sandwich line's sliced tomatoes, a pastry case with cream-filled items, a sushi bar's rice: some food is easier to serve at room temperature than at 41°F or 135°F. The Food Code allows that, for a limited time, as long as you plan it, mark it and throw it out on time. The rule is called time as a public health control, often shortened to TPHC.

This post gives you the rules in one table, a written procedure to fill in and keep on site, a time-mark log, and the mistakes that turn TPHC into a violation.

General information. Your state or local health department enforces its own edition of the Food Code, and some ask to review or approve a TPHC procedure before you use it, so ask yours first. Section numbers below are from the FDA Food Code 2026.

What TPHC is, and what it isn't

Time/temperature control for safety food (TCS food: cooked rice, cut tomatoes, cut melons, cut leafy greens, dairy, cooked meats and so on) normally has to stay at 41°F or below or at 135°F or above. Under §3-501.19, you may instead use time alone as the control, for a "working supply" of TCS food before cooking, or for ready-to-eat TCS food that's displayed or held for service.

It's a deliberate choice made in advance. It is not a way to rescue food that was left out by accident: food with no time mark, or past its mark, is thrown out.

The rules, in one table

Most cafés use the 4-hour option: it has no temperature check during the hold, only a clear starting point and a hard stop. The 6-hour option needs a thermometer reading during the hold, which is more work but gives a longer window for cold food in a cool room.

Before you start: is TPHC right for this item?

Go through these questions for each item, and only put an item on your procedure if you can answer yes to all of them.

• Can you sell or use the batch in 4 hours (or 6)? If half a pan goes in the bin every time, use a smaller pan or put the item back in the cold well.
• Does the starting temperature work? Food that comes out of a cooler that's running at 44°F doesn't qualify for the 4-hour option. Check the cooler first, and our thermometer calibration post covers the thermometer.
• Was it cooled properly before? Cooked rice or beans that were cooled slowly overnight aren't made safe by TPHC. The procedure has to say how the food was cooled, under §3-501.14; our hot-holding and cooling guide covers the two-stage cooling rule.
• Can everyone on shift mark it? Every pan, every refill, every time. If you can't trust the marking on a busy Saturday, don't use TPHC on a busy Saturday.

The written procedure

Fill in the bracketed parts, print it, and keep a copy where the inspector can see it, and another in your food safety binder.

[Café / restaurant name] — Time as a public health control (TPHC) procedure

Location: [address] · Person in charge of this procedure: [name / role] · Effective from: [date] · Reviewed: [date]

1. Items held using time

2. Starting the clock

• Take the food out of temperature control and check the temperature with a calibrated probe thermometer. Write it on the log.
• If it isn't at 41°F or below (cold) or 135°F or above (hot), don't start TPHC: put it back and fix the cooler or warmer.
• Mark the container straight away with the discard time, 4 hours from now. Use [a color label / tape and marker / the time stamp gun]. Write the time, not "4 hours."

3. During the hold

• Use the oldest container first. Don't add new food to a container that's already on the clock: start a new container with its own mark.
• Keep the food covered and protected as usual.

4. The discard time

• At the marked time, [the line lead / the shift lead] throws out anything left, whatever it looks like, and writes it on the log.
• Food with no mark, a smudged mark, or a mark that's past the time is thrown out.
• Food on TPHC never goes back into the cooler or the hot well to "reset" the clock.

5. Food cooked and cooled before TPHC

• [Cooked items] are cooled from 135°F to 70°F within 2 hours and to 41°F within a total of 6 hours, and recorded on the cooling log, before they're used under TPHC.

6. Who's trained

• Everyone who works the [stations] is trained on this procedure before their first shift there. Training is signed off on [the station training sheet].

Approved by: ………………………… Date: ……………

The cooling line in step 5 restates the Food Code's two-stage cooling rule (§3-501.14(A)); keep it in your own words if your cooling process is different, but keep the numbers.

The TPHC log

One sheet a day per station, on a clipboard next to it. The log is your proof that the marks match what happened.

[Café / restaurant name] — TPHC log · [station]

Date: [date] · Option: 4 hours · Thermometer: [ID]

Manager review at close: ………………………… Time: ……………

For the 6-hour option, add two columns: Check time and Warmest part °F, with a check at least every [hour], and a rule written in your procedure that anything reading above 70°F is discarded at once.

Marking that works on a busy line

• Write the discard time, not the start time, for the 4-hour option. "2:30" on a pan is impossible to misread. "Out at 10:30" makes the cook do the math at the worst moment.
• One color per hour block (day-dot style labels, colored tape) helps the line see at a glance what's next to expire. The color is a helper; the written time is the record.
• A timer, too. A kitchen timer or a phone alarm set for each discard time is the simplest backup.
• Mark the pan, not the lid. Lids get swapped.

What goes wrong in inspections

Our mock health inspection scoring sheet has a line for TPHC, and the temperature log sheet covers everything you keep in temperature control.

Your TPHC checklist

• [ ] Health department asked whether they review or approve TPHC procedures
• [ ] Written procedure listing every item, its station and its option, on site
• [ ] Starting temperatures checked with a calibrated thermometer and logged
• [ ] Every container marked with its discard time when it leaves temperature control
• [ ] No topping up a container that's on the clock
• [ ] Leftovers discarded at the marked time, and logged
• [ ] Cooled foods cooled per the two-stage rule before TPHC
• [ ] Staff on those stations trained and signed off

Where Mays fits

• The log as a form. Build a TPHC log form under Tasks → Types: a Single choice field for the item, a Temperature field for the starting temperature with a pass range (for cold food, set both ends, such as 0 to 41°F; a hot-held item needs its own form or field, with 135°F as the low end), so a warm start shows Out of range, a Date / time field (Time only) for when it left temperature control, a Text field for the discard time you marked, and a Yes / No for Discarded at the marked time. Put it on the station's opening checklist, or on each station's task list. See Building custom forms.
• An alert on a warm start. Under Insights → Alerts & Reports, a Task Form Field Threshold alert on the starting temperature, At or above 42, notifies the people you pick every time someone logs a start that's too warm. See Alerts and scheduled reports.
• The record for the inspector. Tasks → Data lists every submission with a column per field, and Export CSV downloads them. See Task Data.
• The procedure where staff can read it. Put the written procedure in a Knowledge Base folder shared with the kitchen, so it's in the app's Knowledge tab on every phone. Keep the printed copy on site too. See Your knowledge base.

What Mays doesn't do: it doesn't work out the discard time for you (a form's formulas work with numbers, not clock times), there's no countdown or reminder at the 4-hour mark, and Mays doesn't print time labels. Keep the timer and the marker on the line.

Time is a control, not a loophole

Write the procedure before you need it, check the starting temperature, mark every container with its discard time, and throw out what's left when the time comes. Done that way, TPHC is as safe as a cold well, and a lot easier on a busy line.

Start your free trial: 30 days, every module, no card needed. Or book a walkthrough and we'll build your TPHC log and alert with you.