Time as a Public Health Control (TPHC)
Updated October 27, 2026
Some food operations hold TCS food using time alone instead of temperature control, for example on a buffet or a display. The FDA Food Code allows this under strict rules, called time as a public health control (TPHC). Food protection manager exams expect you to know them. Here’s a summary, followed by free practice questions.
The details depend on the edition of the Food Code your local regulator has adopted, so check your local rules.
The two options
| 4-hour option | 6-hour option (cold food only) | |
|---|---|---|
| Starting temperature | 41°F or lower, or 135°F or higher | 41°F or lower |
| While held | No temperature limit | Must not go above 70°F |
| When time is up | Serve, sell or discard the food within 4 hours | Serve, sell or discard the food within 6 hours |
Requirements
- Mark the food with the time it was removed from temperature control and the time it must be thrown out.
- Discard unmarked food and food past its time limit.
- Keep written procedures on site and make them available to the regulatory authority.
- Operations that serve highly susceptible populations, such as hospitals and nursing homes, have extra restrictions.
Free TPHC practice questions
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Under the 4-hour TPHC option, hot food must start at what temperature before it's removed from temperature control?Answer: BUnder the 4-hour option, hot TCS food must be at 135°F or higher (or cold food at 41°F or lower) when it's removed from temperature control.
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Under the 6-hour TPHC option for cold food, the food must not rise above:Answer: DCold food held under the 6-hour option must start at 41°F or lower and must not go above 70°F.
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What must happen to food held under TPHC that has no time label?Answer: AFood held under TPHC must be marked with its discard time. Unmarked food must be thrown out.
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Under the 4-hour option, what happens to food at the end of 4 hours?Answer: CUnder the 4-hour option, the food must be served, sold or thrown out within 4 hours. It can't go back under temperature control.
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What does an operation need to keep on site to use TPHC?Answer: BOperations using TPHC must have written procedures, kept on site and available to the regulatory authority.
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