Food Cooling Rules: The 135 to 70 to 41 Two-Stage Method

The food cooling rules in the FDA Food Code are often called "135 to 70 to 41." Cooked food must drop from 135°F to 70°F within 2 hours, then to 41°F within 6 hours total. It sounds simple, but slow cooling is one of the most common causes of foodborne illness outbreaks linked to restaurants, especially with large batches of soup, chili, beans, rice, gravy and braised meat. This guide explains the rule, why it exists, how to cool food fast enough, how to log it, and what to do when cooling fails.

The limits come from section 3-501.14 of the FDA Food Code 2022. Your state may have adopted a different edition, so confirm with your health department. Any plan you build is a draft for them to review.

The food cooling rules in one table

| Food | Stage 1 | Stage 2 | Total | |---|---|---|---| | Cooked TCS food | 135°F to 70°F within 2 hours | 70°F to 41°F within the remaining time | 6 hours | | TCS food made from room temperature ingredients (for example canned tuna, reconstituted foods) | n/a | Room temperature to 41°F | 4 hours | | Food received at a temperature allowed by law above 41°F (for example milk, shellstock) | n/a | To 41°F | 4 hours |

Food Code 3-501.14 also covers food received hot. Read the section for the exact wording.

Why cooling is a critical step

Cooking kills most vegetative bacteria, but it does not kill spores. Clostridium perfringens and Bacillus cereus form spores that survive cooking. As food cools, the spores germinate and the bacteria grow. C. perfringens can multiply very quickly at warm temperatures, which is why it is so often linked to large batches of meat, gravy and beans that cooled slowly overnight. B. cereus is commonly associated with cooked rice.

The 2 hour first stage is short because growth is fastest between roughly 125°F and 70°F. Below 70°F growth slows, so the second stage gets more time.

CDC lists improper holding temperatures, which include slow cooling, among the main factors in foodborne illness. NACMCF guidance on HACCP principles shows cooling as a typical CCP for cooked foods.

Why large batches fail

Heat leaves food through its surface. A tall stockpot has a small surface compared with its volume, so the center stays hot for hours. A 5 gallon pot of chili placed in a walk-in may still be above 70°F many hours later. The walk-in is not broken. The pot is just too big.

The fix is always the same idea: increase the surface area, move heat out faster, or both.

Cooling methods that work

Shallow pans

Divide food into pans no more than about 2 inches deep. Place them in the walk-in or a reach-in uncovered or loosely covered, on the top shelf, with space around each pan. This is the most common and reliable method for dense foods.

Ice bath

Set the pot or pans in a sink or a larger container filled with ice and water. The ice water should come up to the level of the food. Stir the food often. Drain and add more ice as it melts. An ice bath moves heat out much faster than cold air.

Ice wands (cooling paddles)

Fill a plastic ice wand with water, freeze it, and stir it through the food. Ice wands work well for soups and sauces, especially combined with an ice bath.

Adding ice as an ingredient

For soups and stocks, cook a concentrated batch and add ice in place of some of the water at the end. This cools the food immediately. Adjust the recipe so the final product tastes right.

Blast chiller

A blast chiller blows very cold air at high speed over the food. It is the fastest method and the easiest to log, but it is a significant cost. Many cook-chill operations rely on one. See the cook-chill HACCP plan.

Cutting large items

Large roasts and whole birds cool slowly. Cut them into smaller pieces before cooling. Slice turkey off the bone. Cut a brisket into portions.

Combining methods

A common approach for chili: divide into 2 inch pans, set the pans in an ice bath and stir for 30 minutes, then move to the walk-in uncovered. This usually gets food below 70°F well within 2 hours.

Methods that do not work well

• Leaving a stockpot on the counter "to cool down before it goes in the fridge."
• Putting a full stockpot in the walk-in with a lid on.
• Stacking pans on top of each other.
• Wrapping food in plastic while hot.
• Putting hot food in a reach-in prep rail, which is designed to hold cold food, not cool it.

How to log cooling

A cooling log needs at least:

| Date | Item | Batch size | Start time | Start temp | 2 hr time | 2 hr temp | 6 hr time | 6 hr temp | Method | Action | Initials | |---|---|---|---|---|---|---|---|---|---|---|---|

Start the clock when the food reaches 135°F, or when it is removed from heat if it is already below that. Check at 2 hours and at 6 hours. Many kitchens also check at intermediate times, such as every hour, to catch problems early. A free printable version is on the cooling log page.

Tips for better cooling records

• Set a phone timer or kitchen timer when cooling starts.
• Use a dedicated probe thermometer for cooling checks.
• Probe the center of the thickest pan.
• Hand off cooling at shift change, so the next cook knows a batch is cooling and when the next check is due.
• Have a manager review the log the next morning.

What to do when cooling fails

| Situation | Action | |---|---| | Above 70°F at 2 hours | Reheat to 165°F and restart cooling with a faster method, or discard | | Below 70°F at 2 hours, above 41°F at 6 hours | Discard | | Food from room temp ingredients above 41°F at 4 hours | Discard | | No record of cooling | Treat as unknown; discard if you cannot show it cooled in time |

The Food Code reheating option for a missed first stage is only available when the food is caught at the 2 hour check. After that, discard is the safe answer. See HACCP corrective actions examples.

Cooling by food type

Soups, stocks and sauces

Liquids cool reasonably fast if stirred. Use an ice bath with an ice wand, or add ice at the end of cooking. Divide large batches.

Chili, beans and stews

Thick foods cool slowly because they do not circulate. Use shallow pans and an ice bath. Stir often.

Cooked rice

Spread rice in a thin layer on sheet pans and cool uncovered. Rice is one of the foods most associated with Bacillus cereus. Sushi rice that is acidified has its own rules. See HACCP plan for sushi rice.

Roasted and braised meat

Cut into smaller pieces. Separate liquid from solids and cool them separately. Large cuts cooked for slicing later should be cooled in portions.

Mashed potatoes and dense purees

Spread in thin layers. These are among the slowest foods to cool.

Cooked pasta

Rinse with cold water if your recipe allows, or spread on sheet pans.

Cooling as a CCP in your HACCP plan

In most restaurant plans, cooling is a CCP for any cooked TCS food that is not served right away. The plan entry looks like this:

| CCP | Hazard | Critical limit | Monitoring | Corrective action | Records | |---|---|---|---|---|---| | Cooling | Growth of C. perfringens, B. cereus | 135°F to 70°F in 2 hrs; to 41°F in 6 hrs total | Probe at start, 2 hrs and 6 hrs | Reheat to 165°F and restart if above 70°F at 2 hrs; discard if above 41°F at 6 hrs | Cooling log |

See critical control point examples and the HACCP critical limits chart.

Planning cooling capacity

Many cooling failures are capacity problems, not training problems. A walk-in sized for deliveries may not have the spare cooling power to pull down several pans of hot food at once, especially on a summer afternoon when the door opens constantly. Before you add a new batch-cooked menu item, ask:

• How many pans of hot food will be cooling at the same time on the busiest day?
• Is there top-shelf space with airflow for all of them?
• Will warm pans raise the temperature of other food nearby?
• Is there ice available in the quantities an ice bath needs? A single ice bath for a large batch can use a lot of ice.
• Who is on shift for the 2 hour and 6 hour checks? If cooling starts at 9 p.m., the 6 hour check is at 3 a.m.

That last question catches many kitchens. If nobody is there for the 6 hour check, either cool earlier in the day, use a faster method so the food reaches 41°F before closing, or use a data logger probe that records the temperature overnight. A logger record is accepted by many health departments as monitoring, but confirm with yours.

What inspectors ask about cooling

Inspectors often ask the cook directly, not the manager. Typical questions:

• "How do you cool your soup?" They want to hear a method, such as shallow pans and an ice bath, not "we put it in the walk-in."
• "What are the time and temperature limits?" The answer is 135°F to 70°F in 2 hours, and to 41°F in 6 hours total.
• "Show me your cooling log." They look for real readings, times that make sense, and corrective actions when a limit was missed.
• "What is cooling right now?" They may probe a pan and compare it with the log.

A cook who can answer these questions calmly is often the difference between a clean cooling section and a violation. Practice the answers during training.

Why reheating does not fix slow cooling

It is tempting to think that reheating food to 165°F before serving makes any cooling problem go away. It does not. Reheating kills vegetative cells of C. perfringens, but B. cereus can produce a toxin that heat does not destroy, and very high bacterial loads are not always fully reduced. Food that cooled too slowly is not made safe by reheating alone. That is why the Food Code limits the reheat option to food caught at the 2 hour check, and why food that misses the 6 hour limit is discarded. See reheating food to 165°F.

Cooling food made from room temperature ingredients

The 4 hour rule catches people out. Tuna salad made from canned tuna, pasta salad made with dressing from a shelf-stable jar, and reconstituted foods such as rehydrated beans start at room temperature, not at 135°F. They must reach 41°F within 4 hours. The best practice is to chill the ingredients before mixing, so the finished food starts cold. Then this rule is easy to meet.

Storing food after cooling

Once food reaches 41°F, cover it, label it, and store it so it stays cold. Ready-to-eat TCS food held more than 24 hours needs a date mark, with a 7 day limit at 41°F counting the day of preparation as day 1. See date marking under the Food Code. Store cooled cooked food above raw meat and fish to prevent drips. Keep a little space between containers so the walk-in can maintain temperature.

If cooled food is going to be reheated for hot holding, the reheating rules apply: 165°F for 15 seconds within 2 hours. If it is going to be served cold, such as potato salad or cold noodles, it goes into cold holding at 41°F.

Cooling and the rest of your HACCP plan

Cooling connects to several other steps. Cooking sets the starting point. Cold storage keeps the food safe after cooling. Reheating and hot holding come after. A plan that gets cooling right but has no reheating or date marking control still has gaps. Draw your flow diagram so each step is visible, and check that each step has a control. See HACCP flow diagram examples.

Cooling in a food truck, ghost kitchen or catering kitchen

Food trucks often lack the refrigeration capacity to cool large batches. Most cook and cool at a commissary instead. Ghost kitchens running several brands in one space need to plan walk-in capacity carefully so cooling batches do not compete for space. Caterers who cook ahead for events should treat cooling as one of their most important CCPs, because almost all of their food is cooked, cooled, stored and reheated. See the catering HACCP plan and the ghost kitchen HACCP plan.

Common cooling violations

• A stockpot of soup cooling in the walk-in with a lid on.
• Pans stacked tightly on a speed rack.
• No cooling log, or a log with times that do not make sense.
• Rice cooling in a deep container on a counter.
• Food placed in a prep rail to cool.

See the health inspection food safety checklist.

A worked example: cooling 6 gallons of chili

A restaurant makes 6 gallons of chili every Monday for the week. Here is how a manager might write the cooling procedure:

1. When the chili finishes cooking, turn off the heat and record the time and temperature.
2. Divide into six 4 inch hotel pans, each half full so the food is about 2 inches deep.
3. Set the pans in the prep sink filled with ice and water. Stir every 10 minutes for 30 minutes.
4. Check the temperature of the warmest pan. Record.
5. Move the pans to the top racks of the walk-in, uncovered, with space between them.
6. At the 2 hour mark, probe and record. Must be 70°F or below.
7. At the 6 hour mark, probe and record. Must be 41°F or below. Cover and label with the date.

The first time you run a new procedure, record temperatures every 30 minutes. That tells you how much margin you have and whether the method works in your kitchen with your equipment. Once it works reliably, the 2 and 6 hour checks are enough.

Validating your cooling method

Validation means showing that your method actually meets the limits. You do not need a lab. Run the procedure three times with a full batch, on a busy day, and record temperatures every 30 minutes. If every run meets the limits with room to spare, the method is validated for that item and batch size. If you change the batch size or the equipment, validate again. Keep the records with your plan. See HACCP verification and record keeping.

Training cooks on cooling

Cooling usually fails because someone did not know the method or forgot to check. Training should cover:

• the two time limits and what they protect against
• how to divide and cool each common item
• where the cooling log is and when to check
• what to do if a check is missed or a limit is not met
• how to hand over cooling at the end of a shift

See HACCP training for restaurant staff.

Build cooling into your plan

The HACCP builder creates a cooling CCP with the Food Code limits, monitoring steps, corrective actions and a printable cooling log for each process you add. Free blank logs are on the free logs page. For all processes, see the Plan Pack. The plan is a draft for your health department to review.

Frequently asked questions

What are the food cooling rules?

Food Code 3-501.14 requires cooked TCS food to cool from 135°F to 70°F within 2 hours and to 41°F within a total of 6 hours. Food prepared from room temperature ingredients must reach 41°F within 4 hours.

Why is the first stage only 2 hours?

Bacteria such as Clostridium perfringens grow fastest in the upper part of the temperature danger zone. Getting through that range quickly matters most.

Can I put hot food directly in the walk-in?

Yes, and it is often the right move once food is in shallow pans. Leave pans uncovered or loosely covered until cold, and do not stack them. A large pot of hot food in a walk-in will cool too slowly and can warm other food.

Do I have to log cooling?

If cooling is a CCP in your HACCP plan, yes. Even without a plan, inspectors often ask how you cool food, and a log is the best evidence.