A deli operator uses 'time as a public health control' (TPHC) for sliced turkey held at room temperature on a sandwich line. The turkey starts at 41°F at 10:00 AM. By what clock time must any remaining turkey be served or discarded?
Explanation
Under California Retail Food Code HSC §114000, TCS food held without temperature control using TPHC may be held for a maximum of 4 hours from the time it is removed from temperature control, after which it MUST be served or discarded — it may not be returned to refrigeration for later use. Sliced turkey starting at 41°F at 10:00 AM must therefore be served or discarded by 2:00 PM. The 4-hour limit assumes the food was at or below 41°F when the clock started; if the food starts warmer than 41°F (between 41°F and 70°F), the maximum is only 4 hours from when it first exited refrigeration AND it must not exceed 70°F at any point. Option A confuses TPHC with the 2-hour danger-zone exposure rule for non-TPHC operations. Option B is not a defined limit. Option D (8 hours) misremembers an older FDA provision; the current code allows up to 6 hours only if the food starts at 41°F and never exceeds 70°F, and that 6-hour option requires temperature monitoring — most operators use the simpler 4-hour rule. TPHC requires a written procedure on file and clearly labeled time stamps.
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