What Is TCS Food? Examples, Temperatures and Rules

TCS food means time/temperature control for safety food. It is the Food Code's name for food that will grow harmful bacteria, or let them make toxins, if it sits at the wrong temperature for too long. Raw chicken is TCS food. So is cooked rice, a cut cantaloupe, a sliced tomato, a baked potato and a jar of garlic in oil. Saltines, dry pasta and a whole uncut apple are not.

The term matters because almost every temperature rule in a kitchen applies only to TCS food: cold holding at 41°F or below, hot holding at 135°F or above, the cooling limits, the 7 day date mark, and the time limits when food is held without temperature control. This guide answers all of them in one place.

The definitions come from Chapter 1 of the FDA Food Code 2022, which your state adopts with its own changes, and the science behind them from the FDA Bad Bug Book.

TCS food meaning

The Food Code defines TCS food as food that requires time/temperature control for safety to limit pathogenic microorganism growth or toxin formation. Older books call the same thing "potentially hazardous food", and you will still see PHF on some state forms and older logs. The two terms mean the same thing.

Three properties decide whether a food is TCS:

• Moisture. Bacteria need water. Food scientists measure available water as water activity (aw). Food with aw above 0.92 to 0.95 can support pathogens.
• Acidity. Most foodborne bacteria struggle below pH 4.6. Pickles, vinegar dressings and properly acidified sushi rice are acidic enough to slow them.
• Nutrients and history. Protein-rich foods and foods that have been cooked are prime ground. Cooking kills vegetative bacteria but can leave spores of Clostridium perfringens and Bacillus cereus that wake up as the food cools.

The Food Code combines pH and water activity in two interaction tables. If a food falls in the "TCS" boxes of those tables, or has no testing and has a history of illness, it is treated as TCS food. A product that has been tested and falls outside them, such as a commercially made shelf-stable sauce, is not.

What are TCS foods? A full list with examples

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When in doubt, treat a food as TCS until your health department says otherwise. It costs you a cooler shelf; guessing wrong costs a lot more.

Why cut melons, tomatoes and leafy greens are TCS food

People are often surprised that a sliced tomato is in the same group as raw chicken. The reason is that the inside of fruits and vegetables has moisture, nutrients and a near-neutral pH, while the skin was protecting it. Once you cut through, any Salmonella or E. coli on the surface is pushed into the flesh, and there is nothing stopping growth. Outbreaks linked to cut cantaloupe and cut leafy greens are why the Food Code added these items.

Whole produce is not TCS. The rule kicks in the moment the knife goes in, so cut tomatoes on a sandwich line need either cold holding at 41°F or below or a time control procedure.

TCS food temperatures at a glance

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Why the limits are 41°F and 135°F

Most bacteria that cause foodborne illness grow fastest between about 70°F and 125°F, and they grow more slowly at the edges of the range. The Food Code treats 41°F to 135°F as the zone to keep food out of, except for short times during preparation, cooking and cooling.

At 41°F or below, growth of most pathogens is slow. Listeria monocytogenes is the important exception: it can still grow in the refrigerator, which is why ready-to-eat TCS food also has a 7 day date marking limit. See date marking under the Food Code.

At 135°F or above, the spore forming bacteria that survive cooking, Clostridium perfringens and Bacillus cereus, cannot grow well. Below 135°F they can, and C. perfringens can double in very short times at warm temperatures. That is why hot holding matters so much for chili, beans, gravy, rice and braised meat.

Hot holding: what the Food Code says

Section 3-501.16(A)(1) requires TCS food held hot to be at 135°F or above. There is one specific exception for roasts. Whole roasts of beef, corned beef, pork and cured pork, cooked under the roast cooking rules in 3-401.11(B), can be held at 130°F or above. This lets rare roast beef stay rare on a carving station.

Some states still use older editions of the code, which set hot holding at 140°F. Check your state.

Hot holding is not reheating

Hot holding equipment keeps hot food hot. It is not built to heat cold food quickly. Food Code 3-403.11 requires TCS food that was cooked, cooled and reheated for hot holding to reach 165°F for 15 seconds within 2 hours. Steam tables rarely do that. Reheat on the stove, in an oven, or in a kettle, then move the food to hot holding. See reheating food to 165°F.

Practical hot holding tips

• Preheat the equipment. A steam table should be at temperature before food goes in.
• Keep water in the wells at the level the manufacturer says. Dry wells hold poorly.
• Use lids between services. Uncovered pans lose heat from the surface.
• Stir thick foods. The center of a deep pan of mashed potatoes or refried beans can be much cooler than the edge.
• Use smaller pans and replace them more often instead of one huge pan that sits all day.
• Put food in hot. Food should go into hot holding at or above 135°F, preferably well above.
• Do not mix old and new batches. Combining food resets nothing and makes discard decisions harder.

Cold holding: what the Food Code says

Section 3-501.16(A)(2) requires TCS food held cold to be at 41°F or below. Shell eggs are covered by a separate rule that allows them to be held at an air temperature of 45°F or below. Some older state codes allowed certain existing equipment to hold at 45°F; most states have phased this out.

Practical cold holding tips

• Do not overload units. Cold air must move around the food.
• Keep doors closed. A reach-in opened every minute during a rush cannot keep up.
• Chill pans before filling a prep rail. A warm pan raises food temperature.
• Do not overfill rail pans above the cold zone. Food sitting above the rail line can be several degrees warmer.
• Use ice baths correctly. Ice should come up to the level of the food, and melted ice should be drained and replaced.
• Put food in cold. A prep rail is not designed to cool food. Cool first, then hold.
• Check door gaskets and defrost cycles. A torn gasket or a frosted coil slowly raises temperatures.

How often to check holding temperatures

The Food Code does not set a checking frequency. Your plan sets it. Two common approaches:

Every 2 hours for hot holding. If food is found below 135°F and the last good reading was within 2 hours, many plans allow it to be reheated to 165°F and returned to holding. If you check only every 4 hours, any drop has an unknown duration and the safe choice is often discard.

Every 4 hours, or a continuous logger, for cold holding. Cold holding problems usually build slowly. A data logger that records every few minutes is the best record and makes it possible to say exactly how long food was above 41°F after a failure.

What to do when holding temperatures drift

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Your plan sets the exact rules. See HACCP corrective actions examples.

Time instead of temperature for TCS foods

TCS food does not always have to be under temperature control. The Food Code allows time as a public health control: up to 4 hours, or 6 hours for cold food that stays at or below 70°F, then the food is served or discarded. Our guide to how long food can be held without temperature control covers the labels and written procedures you need.

Date marking TCS foods

Most bacteria grow very slowly at 41°F. Listeria monocytogenes is different: it can grow at refrigeration temperatures. Over days, a small amount of Listeria in a ready-to-eat food such as deli meat, soft cheese, cooked chicken salad or smoked fish can reach levels that make people sick. Listeria is especially dangerous for pregnant women, older adults and people with weakened immune systems. CDC describes Listeria as a serious infection for these groups on its prevention pages.

The 7 day limit at 41°F is the Food Code's way of keeping that growth within safe bounds without testing every container. Ready-to-eat food matters most because it will not be cooked again before eating.

How to count 7 days

The day of preparation is day 1. Count forward 7 days. The food must be used or discarded by the end of day 7.

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A simpler way to remember: prep day plus 6. Food made Monday the 3rd is discarded at the end of Sunday the 9th.

The label can show either the preparation date or the discard date. Many kitchens show both to avoid confusion. Whatever you choose, use it consistently and train staff on it.

Exemptions from date marking

The Food Code exempts certain products, mainly because their acidity, salt, low water activity or other factors limit Listeria growth. The exemptions include, in summary:

• deli salads such as ham salad, seafood salad, chicken salad, egg salad, pasta salad, potato salad and macaroni salad when manufactured in a food processing plant regulated by a food regulatory agency
• hard cheeses and certain semi-soft cheeses made under federal standards
• cultured dairy products such as yogurt, sour cream and buttermilk
• preserved fish products such as pickled herring and dried or salted cod, and other acidified fish products
• shelf-stable, dry fermented sausages such as pepperoni and Genoa salami that are not labeled "keep refrigerated"
• shelf-stable salt-cured products such as prosciutto and Parma ham that are not labeled "keep refrigerated"
• shellstock

Read 3-501.17 for the full list and the conditions. Note that a deli salad made in your own kitchen is not exempt; the exemption is for salads made in a regulated processing plant.

Combined foods

When you combine ingredients with different dates, the combined dish takes the date of the earliest ingredient. If you make chicken salad on Thursday using chicken cooked on Monday, the chicken salad must be discarded by the end of Sunday, because the chicken's clock started Monday.

This is one of the most common date marking mistakes, because the person making the dish naturally writes today's date. Train prep staff to check the dates of components before labeling.

Product temperature vs air temperature

The Food Code limits apply to the food, not the air. A refrigerator thermometer showing 38°F does not prove that food is at 41°F, especially in a busy unit. Air temperature changes quickly when doors open, while food changes slowly. Many kitchens log air temperature of units twice a day and probe actual food during service. Both are useful. When there is a question, the food temperature is what counts.

Some kitchens keep a "product simulator" in the unit, such as a probe in a bottle of glycol or water, to get a reading closer to food temperature without opening packages.

A quick TCS food check for your menu

Go through your menu item by item and ask three questions. Does the item contain an animal food, a cooked plant food, cut produce, sprouts or garlic in oil? Is it held for any period before serving? Is it kept outside 41°F to 135°F at any point? If the first two answers are yes, it is TCS food and needs a holding temperature or a time control on your line.

How TCS food fits into a HACCP plan

In a HACCP plan, TCS food is what turns ordinary prep steps into critical control points. Cooking raw chicken, cooling a batch of rice, hot holding soup and cold holding cut melon are all steps where a limit on time or temperature is the only thing between the food and an outbreak. The HACCP principles guide shows how those limits become a plan, and the restaurant temperature log and cooling log show how you prove them.

Common TCS food mistakes

• Leaving cut tomatoes or lettuce at room temperature on the line without a time label.
• Cooling cooked rice in a deep covered container, which keeps it in the danger zone for hours.
• Making garlic in oil in house and keeping it on the counter.
• Treating plain cooked vegetables as low risk; cooked vegetables are TCS food.
• Logging cooler air temperature but never probing the food itself.
• Forgetting that sauces like hollandaise are TCS food and need a time limit when held warm below 135°F.

Track your TCS foods in one plan

Home producers face different TCS rules: since 2025 the Texas cottage food law allows TCS foods with registration and temperature control.

The HACCP plan builder asks which TCS foods you handle and writes the holding, cooling and date marking controls for each process, with printable logs. Your first process is free. Treat the plan as a draft for your health department to review.

Frequently asked questions

What does TCS food mean?

Time/temperature control for safety food. It is food that can support rapid bacterial growth or toxin formation if it is not kept cold or hot, or used within a time limit.

What are examples of TCS foods?

Meat, poultry, seafood, eggs, dairy, cooked rice and pasta, cooked beans and vegetables, baked potatoes, tofu, sprouts, cut melon, cut tomatoes, cut leafy greens and garlic or herbs in oil.

Is bread a TCS food?

Plain bread is not. Bread with a cream, custard or meat filling usually is.

What temperature must TCS food be held at?

41°F or below for cold holding and 135°F or above for hot holding under the FDA Food Code.

How long can ready-to-eat TCS food be kept?

Up to 7 days at 41°F or below, counting the day of preparation as day 1, then it must be discarded.