Poke Kiosk: Time as a Public Health Control, Parasites and the Consumer Advisory
A new poke bowl kiosk in a food hall plans to hold marinated raw ahi tuna and salmon cubes over rice on a cold bar, but the pans will sit in a 72°F room and the owner wants to use time as a public health control (TPHC) instead of ice. The plan is to portion the fish at 9:00 a.m., mark each pan with a 6-hour time, and discard at 3:00 p.m. The fish is received frozen; the salmon is farm-raised Atlantic and the tuna is wild yellowfin. The rice is seasoned with vinegar to pH 4.2. The owner also wants to serve the raw fish at a children's party and has no consumer advisory on the menu. The kiosk has two calibrated thermometers and a pH meter. The local regulator requires written TPHC procedures before approval. The owner asks what to fix.
1. Evaluate the proposed 6-hour TPHC plan and state what the requirements would be.
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Under time as a public health control, the 6-hour option is available only if the food starts at 41°F or less and never exceeds 70°F during those six hours. The plan leaves the fish in a 72°F room, so the ceiling is breached and the 6-hour clock is invalid; the limit is 4 hours, marked with the time the food was removed from temperature control and discarded at the end of that period. TPHC also requires written procedures approved by the regulator before use, time marks on every pan, no combining old and new pans, and a log. Even then it is a fallback, not an excuse: an ice bed or a refrigerated cold bar would hold the fish safely with far less documentation.
2. What must the kiosk do about parasite destruction for the tuna and the salmon?
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Raw fish served without a kill step must be frozen for parasite destruction unless it qualifies for an exemption. The usual schedules are -4°F for 7 days (168 hours) in a freezer, or -31°F for 15 hours, verified with a thermometer and a log. Wild yellowfin tuna is one of the species the Food Code exempts from the freezing requirement. Farm-raised Atlantic salmon may also be exempt if it was raised on formulated feed and the kiosk can produce written documentation from the supplier; without that letter it must be frozen. Fish that arrives frozen is not automatically compliant unless the supplier verifies the time and temperature that was used. Get the letter or freeze it.
3. What is required for the consumer advisory, and how does the acidified rice affect the plan?
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The menu must carry a consumer advisory for raw or undercooked animal foods: a disclosure that the item is raw or undercooked, for example an asterisk next to the item with a footnote, plus a reminder that eating such foods may increase the risk of foodborne illness. There is no separate age restriction in the Code, but the advisory applies to the children's party food as it does to everything else, and staff should not tell a parent the raw fish is safe for children. As for the rice, vinegar to pH 4.2 removes it from TCS control only if the pH is measured and recorded; without records the rice is a TCS food and needs its own temperature or time control.