Risk Factor: Improper Holding Time/Temperature Data Item #8: Refrigerated, Ready-to-Eat (RTE) Foods Are Properly Date Marked and Discarded Within 7 Days of Preparation or Opening
Foodborne Illness Risk Factors & Risk Control Plan Tool
What’s the Risk? Bacteria, viruses, parasites, or toxins can multiply rapidly on Time/Temperature Control for Safety (TCS) Food under certain conditions, such as warmth and moisture. Unless proper controls for date marking are used, food handlers and consumers might not be aware of the freshness or safety of the food, leading to potential contamination and foodborne illness. What's the Rule? Refrigerated, Ready- to-Eat (RTE), and TCS Food prepared/held in a food establishment for more than 24 hours shall be clearly marked to indicate the date or day by which the food should be consumed, sold, or discarded when held at a temperature of 5 ºC (41 ºF) or less for a maximum of 7 days. The day of preparation shall be counted as day 1.
Why Do You Need a Risk Control Plan? A Risk Control Plan can reduce your risk of causing a foodborne illness outbreak. The process has three parts: 1) identify your chronic issues, 2) determine the root causes, and 3) create a food safety management system. This guidance document can be used to complete an agreement between you and your local regulator to plan for long-term food safety success.
PART 1: Identify continuous or chronic out-of-compliance issues • List all date marking issues from previous inspection reports
• Identify any pattern or similarity among the citations • List the corrective actions that have already been tried PART 2: Use the table below to determine the root causes • Chronic issues can have multiple root causes • Identify all the people, equipment, economic, or procedural factors that play a role in your recurring issues • This table includes a few examples, but it might not include your specific root cause
PEOPLE
EQUIPMENT
ECONOMICS
PROCEDURES
People not trained on date marking procedure People not date marking open and prepared foods People not monitoring and discarding expired foods Person in charge is not a trained food protection manager People not trained to recognize items that must be date marked
Labeling supplies not placed where readily available Labeling machines not programed for proper dates
Insufficient time committed to train staff on procedures Insufficient staff scheduled to execute procedures Inadequate funding for date-marking equipment or supplies E xpired food not discarded due to cost impact
Written procedures not clear and correct
Written procedures not followed
Procedures are not monitored, monitoring is not documented No process for taking and documenting corrective actions Procedure not posted at the point of use
Old labels are not easily removable
Date marking system is not easy to use Date marks are not easy to read and verify
Expired food not discarded to avoid being out of stock
Refer to FDA Food Code: 3-501.17, 3-501.18
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