Summer brings catering events, festivals, fairs, outdoor weddings, and community gatherings. These settings are great for business, but they also create real challenges when it comes to keeping food out of the temperature danger zone.
When you’re working out of tents, or temporary setups, maintaining proper hot and cold holding can be challenging. Maryland does allow an alternative in these situations: Time as a Public Health Control (TPHC) — but only when it’s implemented correctly.
In Maryland, time-only control isn’t something you can decide to use on the fly. It must be:
- Approved by your local health department for specific foods and conditions
- Included as a CCP in your HACCP plan
- Supported by written procedures and recordkeeping
Before food can be held using time alone, it must start at safe temperatures:
- Cold foods at 41°F or below
- Hot foods at 135°F or above
Once food is removed from temperature control, the 4‑hour rule applies:
- Food may be held for up to 4 hours total
- It must be clearly marked with a discard time
- Anything left at 4 hours must be discarded (or cooked if it’s part of preparation)
- It cannot be returned to hot or cold holding
The most common compliance issue is documentation. If you’re using time as a control, you need:
- A written procedure describing how it’s used
- Food clearly labeled with start and discard times
- Logs or records showing the procedure was followed
If it isn’t written down, it’s difficult to defend during an inspection.
Used correctly, TPHC can make off‑site events and high‑volume service more manageable without sacrificing food safety. Used incorrectly, it becomes a compliance problem quickly.
If your operation does catering, festivals, or off‑site events and you want to add Time as a Public Health Control to your HACCP plan — or make sure your current process would pass inspection — I can help you set it up or review what you already have.
If you have questions, reach out by phone or email.
Have a safe and successful summer season,
Sue Farace
