Cooking, Reheating, and Hot Holding from a Regulatory POV by Melissa Vaccaro



Improper holding of time/temperature controlled for safety (TCS) foods has been identified by the CDC as one of 5 Foodborne Illness Risk Factor; however, we cannot fully discuss hot holding unless we address cooking and reheating.  
 
Foods must first be properly cooked to reduce pathogen that may be present on the food. Cooking does not necessarily destroy all organisms, may not destroy spores and will not destroy toxins that may have been produced by bacteria in response to temperature abuse. Cooking food properly is very important. Keeping cooked foods hot to prevent significant regrowth of heat-injured microorganisms and prevent recontamination with bacteria that could be newly introduced is very important as well.
 
Reheating food is a common practice in most food establishments. Most reheating is followed by hot holding. The potential for growth of pathogenic bacteria is greater in reheated cooked foods than in raw foods. This is because spoilage bacteria, which inhibit the growth of pathogens by competition on raw product, are killed during cooking. Additionally, when food is held, cooled, and reheated in a food establishment, there is an increased risk from contamination caused by personnel, equipment, procedures, or similar. This subsequent recontamination allows pathogens to grow without competition if temperature abuse occurs. If food is held at improper temperatures for enough time, pathogens could multiply to dangerous numbers.
 
Proper cooking and reheating both provide a significant degree of guarantee that pathogens will be reduced or eliminated. Proper hot holding assures that any pathogens still lingering around will not grow to levels of concern for illness.
 
Proper cooking temperature for TCS foods can be found in the FDA Food Code §§3-101.11 – 3-401.13

§3-403.11 Reheating for Hot Holding.
 
(A) TCS that is cooked, cooled, and reheated for hot holding shall be reheated so that all parts of the food reach a temperature of at least 165oF for 15 seconds.
 
(B) TCS reheated in a microwave oven for hot holding shall be reheated so that all parts of the food reach a temperature of at least 165oF and the food is rotated or stirred, covered, and allowed to stand covered for 2 minutes after reheating.
 
(C) TCS food that has been commercially processed and packaged in a food processing plant shall be heated to a temperature of at least 135oF when being reheated for hot holding.
 
(D) Reheating for hot holding as specified under shall be done rapidly and the time the food is between 41ºF and the temperatures specified may not exceed 2 hours.
 
(E) Remaining unsliced portions of meat roasts that are cooked as specified may be reheated for hot holding using the same cooking procedures as was originally used during the cook step.


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