Cafeteria News
Clark County Public Health updates
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Some bacteria are still able to grow during refrigeration. To limit the risk of illness, WAC 246-215-03526 outlines the requirements for proper labeling of temperature and time control for safety, or TCS, foods. While many schools already implement some form of date marking, use this guide to ensure you are meeting the minimum standards as outlined in the latest code revision. As always, you can be more stringent than the code requires if that is the standard operating practice at your school/district.
Key terms:
- AMC - Active managerial control. Part of meeting the new code updates involves the PIC demonstrating AMC. Refer to our March 2022 newsletter for additional details on what all is involved with AMC.
- CFPM - Certified Food Protection Manager who is in charge of developing and/or training on food safety policies and procedures.
- PIC - Person in charge of maintaining food safety standards during food prep and service.
- RTE - Ready to eat foods. To be considered RTE, there will be no additional rinsing or cooking steps.
- TCS - Time and temperature control for safety foods. These food items were formally known as potentially hazardous foods.
What is required:
- RTE and TCS food items that are removed from original packaging, combined or prepared and will be held for over 24 hours must be date marked and then discarded at 7 days from opening/thawing. The day opened/thawed counts as day 1.
Food safety measures:
- Monitor temperature of cold holding units. All food must be maintained at the proper temperature for safe date marking to apply.
How do I date mark:
How you date mark is dependent on the rules of the kitchen PIC. The key is everyone in the kitchen must know what the dates mean.
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Select the marking method used: Decide if you will use stickers, color coding, markers or other method to mark the containers.
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Select the date that will be used: Will you be using the open date? Discard date? Date thawed? The key is to ensure AMC and that all applicable staff are appropriately trained.
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Identify staff: Who will be responsible for marking the items? Is it the PIC? The cook?
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Train staff: How will training be completed? How often?
What foods require marking:
The intent of marking is to reduce the growth of Listeria on our food items. Note that this list is limited to the high risk foods. Foods of concern include:
- deli meat (opened package);
- soft or semi-soft cheeses (such as brie, cream cheese, ricotta);
- pasteurized milk (opened package);
- house-made salads (such as garden/lettuce, potato, macaroni);
- cut produce (such as melon or lettuce cut in-house);
- cooked and cooled foods; and
- house-made dressings.
You do not need to date mark:
- Unopened commercial packages.
- Commercially made dressings, mayonnaise, and deli salads like potato salad.
- Whole uncut produce.
- Hard cheeses like parmesan and asiago.
You may chose as a school/district to require additional foods to be date marked and discarded within the 7 day timeframe based on internal policies and procedures.
How will food service staff be trained:
- This is up to the PIC and CFPM.
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Your date marking questions answered! |
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We have been collecting questions in the field and through email.
Please see the following and send us any more questions you may have!
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Are there foods that do not need to be date marked?
- Yes, there are foods that are exempt from the date marking requirement including non-TCS foods, TCS foods that will be kept refrigerated less than 24 hours, TCS foods that are not ready-to-eat (will be cooked or rinsed) and TCS foods that remain in the sealed commercial packaging. Additionally, hard cheeses and semi-soft cheeses with low moisture and cultured dairy (yogurt, sour cream, buttermilk) are exempt. For a full list of exempt dairy products, please visit https://doh.wa.gov/community-and-environment/food/food-worker-and-industry/food-safety-rules and click on the Date Marking AMC worksheet.
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Do I have to label things that are not required to be date marked?
- While it is recommended to label containers with at minimum the item name to ensure they are not misused, the date marking is only required for the identified TCS foods.
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Does date marking include canned foods, bread and cereal boxes?
- Shelf stable and sealed items are not required to be date marked as they are not known to harbor Listeria. Note that for food items that are TCS and require temperature control after they are opened, such as canned beans, will need to be date marked.
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How do you label something that was previously frozen? For example, frozen lunch meat, if you pull it out of the freezer how do you date mark it.
- Don’t count days food is frozen. Label food with the date it is frozen and the date it is put back in the refrigerator. Serve or discard food within a total of 7 days in the refrigerator. For example: If you refrigerate food for 2 days and then freeze it, you can later refrigerate it for 5 more days before you discard it.
- For sealed, prepackaged frozen items like lunch meat, the date marking is required once opened.
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What about thawed foods? Food is removed from the freezer marked with date they went into the freezer, do they need to be relabeled while thawing?
- Yes, the items should be labeled based on the the date they are pulled out to be thawed and discarded 7 days after they are removed from the freezer.
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What about foods being delivered from another kitchen. Do they need to come date marked?
- Labels are required for all applicable TCS foods. When coming from a production kitchen, day one is the date the original container is opened, including all ingredients. It is not the delivery date.
- It is the responsibility of both the production kitchen and the receiving kitchen to ensure proper date marking.
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How to date mark hard to mark items like lunch meat that is frequently rewrapped or bulk items like loaves of bread, where the product date is not on each individual bag.
- If you have carts or trays with the same item that does require date marking, one label per cart is adequate as long as the items are all served the same day. For items that require dates but are hard to mark, you can also work out with your inspector on a plan. Be prepared to demonstrate knowledge of the plan when asked for details during a routine inspection.
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What if we are mixing foods with different use-by or open dates. How do we mark those?
- Use the first opened ingredient date as day one.
- The day or date marked food may not exceed a manufacturer's use-by date from any single ingredient if the manufacturer determined the use-by date based on food safety.
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When marking, which date do we pick? Expiration dates? Date made? Etc.?
- This can be determined by your own internal processes. You may use the date prepared or the discard date. The key is consistency and education so all staff understand your system.
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What if we are using reduced oxygen packaging?
- For food items that were prepared, packaged and sealed in a food production plant (not a permitted kitchen) are to be labeled once opened.
- For food items that were packaged and vacuum sealed in your permitted kitchen, there is a special section of the code that outlines requirements. Note that reduced oxygen packaging requires a HACCP plan that the health department has reviewed and approved. If you would like to start a reduced oxygen packaging please refer to WAC 246-215-03540 and reach out to your inspector for more information.
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Can I get help developing our plan?
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The updated WAC 246-215 is now in effect! |
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Washington State Board of Health adopted proposed changes to chapter 246-215 WAC, Food Service. These changes went into effect March 1, 2022.
Over the next several months these newsletters will cover updates to the code that directly impact cafeteria food service. Please ensure you and your fellow food service team members are signed up to receive these newsletters!
The following resources are available to help answer any additional questions about the code revision:
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Have questions or comments? |
Have a topic in mind? Feel free to email us and we can see where to fit it in to our plan! |
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