Reheating Food to 165°F: Food Code Rules for Hot Holding

Reheating food to 165 degrees Fahrenheit is the Food Code rule for cooked and cooled food that is going back into hot holding. Soup made yesterday, chili from Monday's batch, braised short ribs cooked ahead: if it goes in the steam table, it must first reach 165°F for 15 seconds, and it must get there within 2 hours. This guide explains when the rule applies, the exceptions, the equipment to use, and how to record it.

The rules come from sections 3-403.10 and 3-403.11 of the FDA Food Code 2022. States adopt the code on their own schedule, so check your state. Any plan you build is a draft for your health department to review.

When reheating food to 165 is required

The 165°F rule applies when all of these are true:

• the food is TCS (time/temperature control for safety)
• it was cooked and then cooled in your establishment
• it is being reheated to be hot held, such as in a steam table, soup well, hot box or chafing dish

It does not apply when:

• the food is reheated for immediate service to one customer, such as a single portion heated to order (3-403.10)
• the food is a commercially processed, ready-to-eat product from an intact package, which only needs 135°F for hot holding (3-403.11(C))
• the food is an unsliced roast cooked under the roast rules, which can be reheated using the original roast oven parameters (3-403.11(E))

Read the code section for the exact conditions.

The Food Code reheating rules in a table

| Situation | Requirement | Section | |---|---|---| | Cooked and cooled TCS food reheated for hot holding | 165°F for 15 seconds | 3-403.11(A) | | Same, reheated in a microwave | 165°F, rotate or stir, cover, stand 2 minutes | 3-403.11(B) | | Commercially processed RTE food from intact package, for hot holding | 135°F | 3-403.11(C) | | Time to reach temperature | Within 2 hours | 3-403.11(D) | | Unsliced roasts cooked under 3-401.11(B) | Original roast oven parameters | 3-403.11(E) | | Food reheated for immediate service | Any temperature | 3-403.10 |

Why the rule exists

Cooked food that is cooled and stored is never sterile. Spores of Clostridium perfringens and Bacillus cereus survive cooking, and if cooling was even a little slow they can grow. Listeria can grow slowly during refrigerated storage. Reheating to 165°F reduces vegetative bacteria before the food spends hours in hot holding.

The 2 hour limit matters as much as the temperature. Food reheated slowly spends time in the warm range where bacteria grow fastest. A pot of soup put in a steam table cold and left for 3 hours to warm up may grow more bacteria during reheating than it had before.

Reheating does not fix every problem. Some toxins, such as the emetic toxin of B. cereus and the toxin of Staphylococcus aureus, are heat stable. That is why cooling and cold storage controls still matter. See food cooling rules.

Equipment for reheating

Stovetop

The most common method. Use a heavy pot and stir to avoid scorching. Heat a smaller amount at a time if needed. Probe the center after stirring.

Oven

Good for casseroles, braised meats and items in hotel pans. Cover to hold moisture. Probe the center of the thickest piece.

Steam kettle or tilt skillet

Fast for large batches of soup, chili and sauces.

Combi oven

Combines steam and convection heat. Fast and even for many foods.

Microwave

Allowed under 3-403.11(B) with specific conditions:

• heat to at least 165°F in all parts
• rotate or stir during heating
• cover to retain heat
• let stand covered for 2 minutes after heating

Microwaves heat unevenly, so the stand time and stirring matter. Probe several spots.

Not suitable: steam tables, heat lamps, holding cabinets

These hold food that is already hot. They do not have the power to reach 165°F within 2 hours for most foods. Using them to reheat is a common violation.

How to check reheating temperature

Use a calibrated probe thermometer. For soups and sauces, stir and then probe in the center. For solid foods, probe the thickest part. For a full hotel pan, probe several spots, because the corners heat faster than the middle. Hold the reading at 165°F or above for at least 15 seconds. See the thermometer calibration log for keeping your probe accurate. USDA FSIS has a useful page on using food thermometers.

How to log reheating

A reheating log is short:

| Date | Item | Start time | Time at 165°F | Final temp °F | Method | Initials | |---|---|---|---|---|---|---|

If reheating is a CCP in your plan, log every batch. Some kitchens combine reheating and hot holding on one log, with the first entry being the reheat temperature. Blank logs are on the free logs page.

Corrective actions when reheating falls short

| Situation | Action | |---|---| | Below 165°F, under 2 hours since start | Continue heating until 165°F | | Not at 165°F at 2 hours | Discard | | Reheated in steam table by mistake | Check temperature; if under 2 hours, move to a stove and finish to 165°F; otherwise discard | | No record of reheating | Re-check now; if time cannot be confirmed, follow your plan, often discard |

See HACCP corrective actions examples.

Reheating as a critical control point

In most restaurant HACCP plans that use the cook, cool, reheat process, reheating is a CCP. It is often the last step before hot holding that reduces bacteria. The plan entry:

| CCP | Hazard | Critical limit | Monitoring | Corrective action | Records | |---|---|---|---|---|---| | Reheating for hot holding | Survival of vegetative pathogens | 165°F for 15 seconds within 2 hours | Probe each batch | Continue heating; discard if not reached in 2 hours | Reheating log |

The NACMCF HACCP guidelines describe how to decide whether a step is a CCP. See critical control point examples.

Reheating for immediate service

A cook heats one portion of yesterday's chili in a sauté pan to order and puts it straight on a plate. Under 3-403.10 this can be served at any temperature, because it is going directly to the customer and will not sit in hot holding. In practice most kitchens still heat it thoroughly because customers expect hot food, but the 165°F rule does not apply.

If that same chili were heated in a batch for the lunch steam table, the 165°F rule would apply.

Reheating commercially processed foods

Canned chili, frozen soups from a manufacturer, packaged precooked sausages and similar products that come from a commercial processor in an intact package only need to reach 135°F for hot holding. The manufacturer's process already controlled the hazards. Once you open the package and the food has been handled, cooled and stored in your kitchen, treat it like your own cooked food.

Reheating roasts

Unsliced roast beef, corned beef and pork roasts cooked under the roast rules can be reheated for hot holding using the same oven time and temperature used to cook them. This keeps a rare roast rare. Once sliced, the roast is treated like other cooked food.

Reheating on food trucks and at catered events

Food trucks often reheat food that was cooked and cooled at a commissary. Make sure the truck has enough burner capacity to bring food to 165°F within 2 hours. Reheating several large pans at once on a two burner range rarely works. Reheat in batches before service, then hold.

Caterers face the same issue at venues. If the venue kitchen has no range, food may need to be reheated at your kitchen and transported hot at 135°F or above. Plan this in advance and write it into your plan. See the food truck HACCP plan and the catering HACCP plan.

A worked example: Monday chili, Wednesday lunch

1. Monday: chili is cooked, cooled using shallow pans and an ice bath (logged), labeled with the date and stored at 41°F.
2. Wednesday, 9:30 a.m.: one pan of chili is moved to the range in a heavy pot. The start time is recorded.
3. 10:05 a.m.: after stirring, the chili reads 168°F in the center. Held for 15 seconds. Recorded.
4. 10:10 a.m.: chili is moved to a preheated steam table well at 135°F or above. Hot holding checks begin.
5. 2:30 p.m.: leftover chili is discarded under the house rule of one reheat only.

This is the cook, cool, reheat process most restaurants run every day. See HACCP flow diagram examples.

Reheating in cook-chill and sous vide operations

Kitchens that cook in bulk, chill quickly and reheat portions during service rely heavily on reheating. A cook-chill kitchen may reheat dozens of bags of soup or braised meat every day. A sous vide program may cook proteins, chill them in the bag, and reheat to order.

For these kitchens, reheating needs two kinds of control. When portions are reheated to order for one customer, the immediate service rule applies, and quality drives the temperature. When bags are reheated in bulk and held in a water bath or steam table for service, the 165°F rule applies, or the reduced oxygen packaging rules and any variance you hold set different conditions. Write down which items fall in which group so staff do not have to guess.

Reheating in a water bath held below 165°F is common in sous vide kitchens for quality reasons. If the food is then held hot for service rather than served immediately, check with your health department how your plan or variance treats it. See the sous vide HACCP plan, the cook-chill HACCP plan and HACCP variance requirements.

Questions to settle before writing a reheating procedure

Before you write reheating into your plan, decide:

• Which items are reheated for hot holding, and which only to order? List them.
• What equipment is used for each? Range, oven, kettle, combi or microwave.
• What batch size reliably reaches 165°F within 2 hours? Time it.
• How many times can an item be reheated? A one-reheat house rule is simple.
• Who records the reheat, and where? One log near the range works for most kitchens.
• What happens at shift change? If a batch is mid-reheat, who finishes it and records the final temperature?

Answering these turns the Food Code rule into something staff can actually follow.

Reheating versus cooking temperatures

Reheating to 165°F is separate from the cooking temperatures. Chicken is cooked to 165°F under 3-401.11, so it is easy to confuse the two. Fish is cooked to 145°F, but once cooked, cooled and reheated for hot holding, it also needs 165°F. The reheating temperature does not depend on the original cooking temperature of the food. See the HACCP critical limits chart for both sets of limits side by side.

Reheating on buffets and in self-service

Buffets often run all day with food refreshed from the kitchen. Every pan that goes out should be at temperature before it leaves the kitchen: 165°F if it was reheated, or straight from cooking if it was just made. Never top up a buffet pan with reheated food added to food that has been sitting out. Bring a fresh pan and take the old one back. If a buffet pan drops below 135°F, follow your plan, which usually means reheating in the kitchen within the time allowed or discarding.

Self-service soup kettles are a special case. Many are sold as "rethermalizers" that can reheat from cold. If the manufacturer states the unit can bring food to 165°F within 2 hours, and you have checked that it does with a full load, it may be acceptable. Test it and record the result before relying on it.

Common reheating mistakes

• Reheating in the steam table. The most frequent violation.
• Reheating too much at once. A full stockpot takes too long. Reheat smaller batches.
• Probing only the edge. The center is the coldest.
• Mixing new and old batches. Add new food to a clean pan, not on top of leftovers.
• Reheating more than once. Not banned by the Food Code, but each cycle adds risk. A one-reheat rule is simple and common.
• Not logging. If reheating is a CCP, the log is the evidence.

How reheating fits with hot holding

After reheating to 165°F, food goes into hot holding at 135°F or above. See cold holding vs hot holding temperatures. If the food then drops below 135°F, your plan decides whether it can be reheated again or must be discarded. Many plans allow one reheat to 165°F if the food was below 135°F for less than 2 hours.

Reheating and food quality

Reheating to 165°F is about safety, but it also affects quality. A few tips:

• Add a little liquid to soups and sauces to prevent scorching.
• Cover pans in the oven to prevent drying.
• Reheat rice with a splash of water and a lid.
• Undercook vegetables slightly when cooking ahead, so they hold up after reheating.
• Reheat fried foods in an oven or fryer, not a microwave, to keep them crisp.

Reheating different foods: practical notes

Each food behaves differently, and the method that works for soup will not work for lasagna.

Soups and broths reheat quickly and evenly if stirred. The risk is a cook putting a full 22 quart container straight into a soup well. Reheat on the range in a pot, then transfer.

Thick stews, chili and beans scorch on the bottom before the center is hot. Use moderate heat, stir often, and add a small amount of liquid. Reheat in smaller pots if needed.

Gravy and cream sauces can break if heated too fast. Whisk while reheating. Gravy is a classic C. perfringens vehicle, so take reheating seriously.

Cooked rice dries out. Add water, cover and steam or microwave with stirring. Reheat only what you need for the next few hours.

Casseroles and lasagna are dense and heat slowly in the center. Reheat covered in the oven, probe the center, and consider cutting into portions first so heat reaches the middle faster.

Whole cuts of braised meat reheat better in their braising liquid, covered, in the oven. Slice after reheating if you can, or reheat slices in hot liquid.

Mashed potatoes need gentle heat and stirring. Add milk or butter to restore texture.

Pulled pork and shredded chicken reheat well in a covered pan with some liquid.

For each item you reheat regularly, write a short note in your plan: the method, the batch size and roughly how long it takes to reach 165°F. Time the first few batches so you know your method will meet the 2 hour limit with room to spare.

Training staff on reheating

Cooks should know:

• the difference between reheating for hot holding (165°F) and reheating for immediate service
• which equipment to use and which not to use
• the 2 hour limit
• how to probe and record

See HACCP training for restaurant staff.

What inspectors look for

Inspectors often walk the line and probe steam table food. If a pan of soup reads 120°F, they will ask whether it is being reheated or held. If the answer is "it's warming up," that is usually a violation. They may also ask to see the reheating log and how long it takes to reheat a batch. See the health inspection food safety checklist.

Build reheating into your plan

The HACCP builder adds a reheating CCP for any cook, cool and reheat process, with the Food Code limit, monitoring, corrective actions and a printable log. Try one process free or get them all in the Plan Pack. The plan is a draft for your health department to review.

Frequently asked questions

Why 165°F for reheating?

Food that was cooked and cooled has had time for bacteria to grow. The Food Code sets 165°F for 15 seconds for reheating to hot holding to reduce those bacteria before the food is held.

Can I reheat food in a steam table?

Steam tables are not designed to reach 165°F within 2 hours. Reheat on a stove, in an oven, in a kettle or in a microwave, then transfer to hot holding.

Do I have to reheat to 165°F if I am serving the food right away?

No. Food Code 3-403.10 allows cooked and cooled food reheated for immediate service to one customer to be served at any temperature. The 165°F rule is for food going into hot holding.

Can I reheat food more than once?

The Food Code does not set a specific limit, but each cool and reheat cycle adds risk and lowers quality. Many kitchens have a house rule of reheating food once only.