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Appendix 2: Time as a control for potentially hazardous food
Potentially hazardous food must be kept under temperature control to minimise the
growth of foodborne pathogens and prevent the formation of toxins in the food. Toxin
formation is not limited to toxins produced by pathogens; toxins may also be formed in
foods through compositional degradation.
In practice in general terms, food must be kept at or below 5°C, or at or above 60°C,
unless the food business can demonstrate that another practice it uses is safe (as per
clause 25 of Standard 3.2.2). The temperature range between 5°C and 60°C is often
referred to as the ‘temperature danger zone’ because food poisoning bacteria can grow
rapidly in this range. However, short periods in this temperature range are unlikely to
allow foodborne pathogens to grow (or produce toxins) to unsafe levels.
This appendix provides science-based guidance on the use of time as an alternative
control for potentially hazardous food.
It is important to note that Standard 3.2.2A requires certain food service businesses
(including caterers) to substantiate food safety controls when handling potentially
APPENDICES
hazardous food. See the chapter on Standard 3.2.2A for further details.
General guidance on using time as an alternative control
If a business uses time to control potentially hazardous food, it must ensure food
handlers have and apply the appropriate skills and knowledge to use time correctly. This
skills and knowledge would include, for example:
• knowledge that a type of food is potentially hazardous and able to support the
Appendix 2: Time as a control for potentially hazardous food
growth of pathogenic microorganisms at temperatures between 5°C and 60°C
• knowledge that certain pathogens may be associated with certain foods
• knowledge that the time potentially hazardous food is kept between 5°C and 60°C is
important because bacteria multiply faster (exponentially) as this time extends
• skill to monitor the time that potentially hazardous food is between 5°C and
60°C, which may accumulate over multiple steps (e.g. over receipt, transport and
display periods)
• skill to manage the food correctly (e.g. use, refrigerate or discard it) depending on the
times and temperatures that have been used during food handling operations.
The business will need to carefully consider any risks of pathogen growth or toxin
production during its food handling practices. The growth rate of pathogens in
potentially hazardous food depends on the:
• pathogen of concern in the particular food — some pathogens may be intrinsically
present in the food because of its origins and other pathogens may have been
introduced by cross contamination. Each pathogen has its own temperature tolerance
and optimum growth temperature.
• characteristics of the food — its pH, water activity, solidity, complexity of ingredients,
etc. will determine how favourable the food environment is for each pathogen to
multiply or produce toxins
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• starting temperature that food is brought out of temperature control — that is,
whether it is refrigerated (5°C) or has been cooked (60°C)
• temperature of the environment — for example, temperatures greater than 21°C
would allow most foodborne pathogenic bacteria to grow faster than at 10°C.
Taking these factors into account, the final level of pathogens (or toxins they may
produce) will depend on the initial number of pathogens present in the food and the
total time the food is between 5°C and 60°C (note that food safety risks may be greater if
pathogen levels are higher to start with). The business will need to demonstrate that the
time it has kept food between 5°C and 60°C has not allowed pathogen or toxin levels to
adversely affect the safety of the food.
Ready-to-eat potentially hazardous food
As a general rule, the total time that a ready-to-eat potentially hazardous food can be
kept at temperatures between 5°C and 60°C is 4 hours. After this time the food needs to
be discarded.
Generally, cooked potentially hazardous foods should be either served immediately,
APPENDICES
hot held at temperatures of 60°C or above, or cooled for later use as per subclause
7(3) of Standard 3.2.2. However, it is recognised that there are some circumstances
where cooked food is kept at temperatures below 60°C; for example during further food
preparation or transport, or when displaying food for service for short periods (e.g. at a
temporary stall). In these circumstances, the food can be used or sold up to 4 hours but
once 4 hours has passed, it needs to be thrown out.
It is important to note that the total time is the sum of any periods that the hot food is
at temperatures below 60°C (i.e. the time is cumulative). For example, the time includes
Appendix 2: Time as a control for potentially hazardous food
any transport and display time at temperatures between 5°C and 60°C.
How does this work in practice for hot food?
• Timing should start from when the temperature of the cooked ready-to-
eat potentially hazardous food drops below 60°C (e.g. as checked with a
probe thermometer).
• The cooked food can be used, sold or discarded within 4 hours.
• Once cooked food has been held for a total of 4 hours below 60°C, the time limit is
exceeded and the food needs to be discarded.
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Displaying hot food below 60°C
A food business owner prepares a variety of cooked meat and vegetarian dishes
and transports them to a market stall to display and sell over lunch. To keep the
food safe, the business does the following:
• The food is cooked in the morning and immediately placed in insulated
containers to keep it hot.
Example
• The food is transported to the stall and placed in display units.
• The display units at the stall can keep food warm, but cannot hold the food at
temperatures of 60°C or above. Because of this, the business knows that the
food should not be kept for more than 4 hours.
• The business needs to monitor when the food first cools below 60°C (e.g. 11
a.m.). The business adds 4 hours to this time so it knows when the 4-hour
period will be up (3 p.m.), and makes a note of this time.
• Once the 4-hour limit is reached (3 p.m.) any remaining food is removed from
display and discarded.
APPENDICES
The 2-hour/4-hour rule for ready-to-eat potentially hazardous food
brought out of refrigeration
The 2-hour/4-hour rule is a rule of thumb that has been designed to help businesses
deal with some of the practicalities of handling refrigerated ready-to-eat potentially
hazardous food. It recognises there may be several circumstances where this type of
food is brought out of refrigeration and held at temperatures above 5°C for convenience;
for example while preparing food at a kitchen bench or displaying food for service for
Appendix 2: Time as a control for potentially hazardous food
short periods.
The rule provides options for what can be safely done with ready-to-eat potentially
hazardous food brought out of refrigeration, depending on how long it has been at
temperatures above 5°C.
If the total time is:
• less than 2 hours, the food may be used, or refrigerated for later use
• between 2 and 4 hours, the food may still be used
• 4 hours or longer, the food needs to be thrown out.
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Figure 1 : The 2-hour/4-hour rule for potentially hazardous food brought out of
refrigeration (image provided courtesy of SA Health)
Appendix 2: Time as a control for potentially hazardous food
The rule is designed so that once the 2-hour mark has been passed, the food cannot be
re-refrigerated for later use: the business must use it or discard it before the total 4-hour
time limit.
It is important to note that the time is cumulative: all time periods where the food is at
temperatures between 5°C and 60°C need to be counted. This includes food preparation
time (e.g. making sandwiches or sushi), any subsequent transport time (e.g. transferring
from a caterer’s business to the place of consumption, or from a preparation kitchen to
a market stall) and any time periods that food is held for service or display between 5°C
and 60°C.
How does the 2-hour/4-hour rule work in practice?
• Timing should start from when ready-to-eat potentially hazardous food is brought out
of refrigeration (at 5°C or below).
• If food is held for no more than 2 hours above 5°C, it can be put back in the
refrigerator to use later.
• Once food is held for more than 2 hours above 5°C, it needs to be used, sold or
discarded before the total time of 4 hours is exceeded.
• Once food has been held for a total of 4 hours above 5°C, the time limit is exceeded
and it must be discarded.
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An example template that may be helpful for logging time as a control is provided in
Appendix 8.
Extra caution may be necessary in some cases. Some foods should not be kept at higher
ambient temperatures (e.g. > 25°C) for 4 hours; a maximum of 2 hours is advised. For
example, the Australian Egg Corporation (AECL) recommends that egg products that
are to be held warm (e.g. foods with a hollandaise or béarnaise sauce) are prepared
just before service and held only for that service period (generally up to 2 hours) (AECL
2015). See also Appendix 4. Extra caution is advised with foods served to vulnerable
people (young, elderly, ill or pregnant).
Food prepared and displayed at ambient temperature
A business prepares sushi and displays it for sale at ambient temperature on a
conveyor belt. The sushi rice the business uses has been acidified to pH 4.6 so is
not in itself a potentially hazardous food. However, meat, seafood and vegetable
fillings are added to this rice, so the final product is potentially hazardous. To
display the food safely, the business uses the 2-hour/4-hour rule as follows:
APPENDICES
Examples
1. The time the fillings are removed from refrigeration is noted, as this is the start
of the 2-hour/4-hour period (e.g. 11 a.m.). The fillings are added to the sushi
rice and the final products displayed for sale.
2. Before the 2-hour mark (1 p.m.) the business assesses how well the sushi is
selling, and decides whether to put some sushi back into refrigeration for later
use.*
3. At the 4-hour mark (3 p.m.), the business discards any remaining sushi on
display.
Appendix 2: Time as a control for potentially hazardous food
*If leftover re-refrigerated sushi is brought out to display later, the business needs to sell it
within 2 hours (since this makes a total of 4 hours out of refrigeration) or discard it.
Applying time as a control for potentially hazardous food
How can businesses keep track of the time?
It is a good idea to keep records of the times that food is out of temperature control,
and/or to identify displayed food with time stickers or colour-coded plates, etc. These
measures will help the business keep track of how long food has been held in the
temperature danger zone, and also to demonstrate the safety of their practice with
potentially hazardous foods as per clause 25 of Standard 3.2.2. An example template for
logging the time that ready-to-eat potentially hazardous food is out of refrigeration is
provided in Appendix 8.
What if cooked food has been cooled – does the cooling time count?
No, cooling is a separate process. The 2-hour/4-hour rule only applies to ready-to-
eat potentially hazardous food once it has been removed from refrigeration. It can
be applied to previously cooked foods that have been cooled according to clause 7(3)
of Standard 3.2.2, because this cooling process ensures pathogens that survived the
cooking process will not be able to multiply to dangerous levels as the food cools. So,
when this food is removed from refrigeration it can still be safe for up to 4 hours.
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What if the food has been prepared by another business?
If a food business wishes to use the 2-hour/4-hour rule for ready-to-eat potentially
hazardous food it has not itself cooked or otherwise processed to ensure its safety, they
will need to know the temperature history of the food; for example, whether the food
spent any time in the temperature danger zone during storage, preparation, or transport.
If any of the available time has been ‘used up’ before the business receives the food, this
time needs to be counted towards the total 4-hour period. If the business does not know
this history, it should not make use of the 2-hour/4-hour rule and the food will need to
be kept at or below 5°C or at or above 60°C.
Preparing food using cooked ingredients from another supplier
A café purchases precooked and chilled meats from a supplier to make salads and
wraps that will be displayed at ambient temperature over the lunch period. To
demonstrate this practice is safe, the cafe receives advice from the meat supplier
Examples
that the cooked meat was cooled as per subclause 7(3), and has spent less than 30
minutes between 5°C and 60°C by the time it is delivered.
APPENDICES
The café notes that it takes another 30 minutes to prepare the salads and wraps,
leaving less than 3 hours for safe display for sale at ambient temperature. The
salads and wraps are identified with stickers on wrapped food or on the display
platters that indicate they are to be sold within 3 hours’ time or discarded.
Can food be brought in and out of temperature control more than once?
Yes, as long as the periods are for less than 2 hours each and the total time out of
Appendix 2: Time as a control for potentially hazardous food
temperature control is no longer than 4 hours. The business should keep track of each
time period the food is between 5°C and 60°C so it is sure when the total 4 hours is used
up. A sample template for logging times is provided in Appendix 8.
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Displaying potentially hazardous food at room temperature more than once
A café cooks and cools chickens the day before they are used to make sandwiches.
It then prepares the sandwiches with the cold chicken and displays them at
ambient temperature (about 21°C) over the lunch period. If sales are slow, the
business would like to refrigerate some sandwiches for sale the following day. To
make sure this practice is safe, the business:
1. cools the cooked chickens according to the temperatures and times specified
in Standard 3.2.2 subclause 7(3) (this cooling period does not count towards
the 2-hour/4-hour rule);
Examples
2. records the time when the cooled chicken is first removed from refrigeration
on the next day to make the sandwiches (this is when the 2-hour/4-hour rule
starts);
3. adds 2 hours to this time and notes that this will be the time the chicken
sandwiches are to be put back into refrigeration for use the next day (using
the 2-hour part of the rule);
4. adds a further 2 hours to note that this will be the time any remaining chicken
sandwiches are to be discarded (using the 4-hour part of the rule).
APPENDICES
If the business chooses to keep any sandwiches for use the following day, the
chicken must not have been out of refrigeration for more than 2 hours the first
day. When the chicken sandwiches are removed from refrigeration for sale the
following day, they need to be sold or discarded within 2 hours (so the total is less
than 4 hours).
What if a business uses time periods other than those specified in this
appendix?
Appendix 2: Time as a control for potentially hazardous food
A business may still use any temperature/time combination with any potentially
hazardous food if it can demonstrate the practice it uses is safe (as per clause 25 of
Standard 3.2.2).
What is the origin and science behind using time as a control?
The advice on using time as a control provided in this appendix was originally developed
from information in the US Food Code 1999 and the UK Food Safety (Temperature
Control) Regulations 1995. The US and UK guidance is incorporated into, respectively,
the US Food Code (US FDA 2020) and guidance from UKFSA accompanying European EC
Regulation 852/2004 The Food Hygiene Regulations 2006 (UK FSA 2007).
The guidance is largely based on scientific modelling and food experiments conducted
in the US. This research included looking at worst-case scenarios, to predict the growth
of target pathogens in food allowed to sit at ambient temperatures, and in hot foods
removed from 60°C control. FSANZ conducted modelling on pathogen growth in foods
brought out of refrigeration. Details are provided below.
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A. Cold foods held out of refrigeration:
• US modelling simulated Listeria monocytogenes growth in food held constantly at a
range of temperatures including ambient (23.9°C) and warmer (35°C). Results showed
that growth of this pathogen is slow enough over 4 hours to not adversely affect the
food’s safety.
• FSANZ modelling simulated Salmonella growth in chilled food exposed to a range of
temperatures from 5°C up to 30°C, for 2 hours and for 4 hours. For most temperature
scenarios the growth was considered slow and low risk. However, as temperatures
rose and times extended, the growth of Salmonella significantly increased. These
results indicate some high-risk foods may need to be treated with extra caution when
applying the 4-hour limit at warmer temperatures.
• The US and FSANZ worst-case modelling scenarios were based on liquid broths held
constantly at warm temperatures, so the results exaggerate the pathogen growth
rate in actual food. In most cases, foods would equilibrate more gradually with the
surrounding environment’s temperature, so generally pathogen growth is likely to be
slower than modelling suggests.
APPENDICES
B. Hot foods held below 60°C:
• The US Food and Drug Administration conducted in-house laboratory experiments
with Clostridium perfringens as the pathogen of concern in cooked foods allowed to
cool to ambient conditions.
• C. perfringens spores were inoculated into foods that were cooked and then cooled to
temperatures that promote rapid pathogen growth. The growth data indicated that
food should remain safe in these conditions over 4 hours.
The 2-hour component of the 2-hour/4-hour rule in Safe Food Australia has been
Appendix 2: Time as a control for potentially hazardous food
incorporated to allow for the practicalities of businesses displaying refrigerated ready-to-
eat food for short periods. It provides a safe, science-based option of re-refrigerating the
food for later use.
Further information
Information on the US scientific work is available in Annex 3 of US Food Code 2013.
Enquiries on the FSANZ modelling work may be made by contacting FSANZ.
For recommendations on the use of eggs, refer to AECL 2015 The Culinary Uses of Eggs.
Identification of Raw/Low-Cooked Egg Dishes that May be of Food Safety Concern.
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