U. S. Food and Drug Administration
Center for Food Safety and Applied Nutrition
FDA Prime Connection
FDA Opinion Index
RFPB INDEX OF OPINION LETTERS - 1980-1992 - (09/04/94)
IMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMM;
: :
: FDA PRIME CONNECTION :
: :
: INDEX OF OPINIONS :
: :
: RETAIL FOOD PROTECTION BRANCH :
: :
HMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMMM<
>>> NOTE <<<
Opinions are issued in response to questions about the
Model Food Codes and other retail food protection issues.
Opinions do not have the same level of research and
review as the formal Model Food Code Interpretations.
These opinions usually cover specific instances cited by the
requester and may not be universally applicable. Also with
the passage of time and with the adoption of new versions
of the Model Food Code, opinions may change. Users should
note that more than one opinion letter may exist on a particular
subject. They are provided with this caution to the FDA PRIME
CONNECTION users to promote more uniformity in retail
food protection programs.
Local regulatory program officials should contact their state
program officials for specific guidance on the application of
their retail food code. State officials should contact their
FDA Regional Retail Food Specialist for assistance with the FDA
Model Food Codes.
To search this index, use your browser's search capabilities (for
example, Netscape users will use the Find button. Charlotte users
should press PF9 until Search appears in the key definitions, then
press PF5.) Type in the phrase you wish to search on, and your
browser window should move to the next occurrence of that phrase.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1992
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Interstate conveyance refrigeration
BY: LEG
DATE: 7 DECEMBER 1992
SUMMARY: Certain interstate conveyance freezers are not capable
of maintaining an ambient holding temperature of 0xF or below
while in route. The model code states that frozen food shall be
kept frozen and should be stored at a temperature of 0xF or
below. An amendment as stated would be acceptable to the current
Comprehensive Compliance Plan for the firm.
SUBJECT: Interpretation of FDA's model food codes on proper
handling of shell eggs
BY: TLS
DATE: 4 DECEMBER 1992
SUMMARY: Interpretation includes the concept that one specific
"potentially hazardous food," namely shell eggs, can be delivered
to a retail establishment at an ambient temperature of 45xF,
whereas other foods must be delivered at an "internal"
temperature of 45xF. I believe that this "variance" or
"exception" for shell eggs can be justified scientifically.
First of all, our Interpretation is focused, because there is
only one type of microorganism, pathogenic to humans, which
appears to be passed transovarially. This would be Salmonella
species, definitely S. enteritidis and perhaps S. typhimurium.
Thus, we are not concerned with psychrophilic or psychrotrophic
microorganisms which would grow, though slowly, at refrigeration
temperatures. Because the Salmonella species of concern do not
grow at 45xF and grow only very slowly at 50xF, it is not
critical to insist on 45xF or below internal temperature.
Second, it is not possible, without damage to the food product,
to "rapidly" bring down the temperature from at least 90xF in the
egg washing and sanitizing process to 45xF. We are concerned
here with (1) the eggs developing cracks and/or checks because of
temperature gradients and (2) with excessive sweating which could
lead to absorption through the shell of microorganisms on the
surface. We are trying to be practical without condoning any
industry practice which unnecessarily extends the egg cooling
period. If asked, we always encourage procedures which shorten
the time eggs are in the "danger zone' for Salmonella.
You further, and very correctly, note that some egg industry
practices, such as packing eggs in styrofoam cartons - a practice
which effectively insulates the contents - prevent eggs from
reaching 45xF upon delivery. Both FDA and USDA, when asked, urge
egg producers to make cooling more rapid. When USDA's new
regulations, proposed on October 27, 1992, are in place, egg
producers will be required to place eggs into refrigeration at
45xF ambient as soon as possible after washing and sanitizing.
Third, limited work on the number of Salmonella likely to be
found in a newly-laid egg indicates the level to be ten organisms
or less (Humphrey). This is a relatively low initial load.
Fourth, the actual length of the lag phase for Salmonella in a
naturally infected shell egg, appears to be fairly long.
Research indicates that the organisms are physically located on
the exterior of the yolk membrane - in contact with the
bacteriostatic albumen. Growth does not appear to begin until
the yolk membrane is weakened by age or physically breached and
the yolk nutrients become available to the organisms. Thus,
nature seems to have given us a "cushion" of time in which there
is little or no growth.
Control of temperature must be initiated by the end of the lag
phase. If the eggs are put into 45xF ambient right after
packaging, they should slowly cool to 45xF internal. Certainly
this process is not ideal, However, it is obviously better than
storage at 55xF as currently recommended by USDA.
In summary, I do not believe reinterpretation of our August 22,
1990, Interpretation on proper egg handling is necessary at this
time. If, however, additional scientific data come to the
attention to FDA's attention, we stand ready to evaluate such
information and make whatever modifications to our
recommendations as are appropriate.
SUBJECT: Airline Attendant with Giardiasis
BY: LEG
DATE: 16 NOVEMBER 1992
SUMMARY: FDA's authority governing the health of persons
handling food on interstate passenger conveyances is contained in
the Code of Federal Regulations (21 CFR 1250.35)
The Agency's policy regarding the health of persons providing
food to the public is contained in FDA's 1976 Food Service Code.
Section 3-101 states in part, "No person, while infected with a
disease in a communicable form that can be transmitted by
foods***shall work in***food service***in any capacity in which
there is a likelihood of such person contamination food or food-
contact surfaces with pathogenic organisms or transmitting
disease to other persons."
Based on the forgoing, it is FDA's position that employees who
are experiencing symptoms of giardiasis are to be restricted from
working in any capacity in which there is a likelihood of
transmitting the disease to patrons or other employees through
contamination of food, utensils, food-contact surfaces, or food
packaging materials, i.e. airline attendants with symptoms of
giardiasis must not work in food and beverage service.
The management of persons after the disappearance of symptoms and
signs, i.e. asymptomatic persons-depends upon what pathogen they
were infected with. Persons who experience illness due to
Hepatitis A virus, Salmonella typhi, or Shigella need to be
considered differently from those who experienced infections with
other, less-transmissible agents such as Giardia lamblia.
Restrictions due to giardiasis may be removed without the need
for a medical examination once the employee is no longer
experiencing symptoms of the illness.
SUBJECT: Proper mechanism for reporting illnesses associated
with seafood products
BY: LCE
DATE: 10 NOVEMBER 1992
SUMMARY: Our Emergency and Epidemiological Operations Branch
(EEOB) of the FDA in Rockville, MD in addition to reporting the
cases to the CDC, states should contact the FDA District Office,
Investigations Branch to report the illness. The District office
will forward this information to the EEOB.
Accurate data of foodborne outbreaks is critical to knowing
whether we have a significant problem. EEOB is responsible for
monitoring illnesses and outbreaks associated with food
throughout our country. The protocol described above should work
well for state personnel as the Investigations Branch within each
FDA district makes sure to answer all incoming calls. Should you
or your colleagues ever need to contact the EEOB directly, they
can be reached at (301) 443-4467.
SUBJECT: Snow macaques (monkeys)
BY: LEG
DATE: 3 NOVEMBER 1992
SUMMARY: 42 CFR 71.53 addresses the issue of non-human primates
under the Federal Quarantine Regulations.
The FDA will review the Federal Quarantine Regulations and the
information supplied by your office to determine what follow-up
action may be indicated. Should the agency opt to revise the
current regulations (21 CFR 1240) in order to address the issue
of interstate shipment of non-primates, no time frame could be
determined at this time on how long that process would take.
SUBJECT: FDA Retail Food Codes
BY: ALB
DATE: 6 OCTOBER 1992
SUMMARY: The Public Health Service/Food and Drug Administration
has produced and periodically updated its model codes for more
than 60 years. Model code development and revision has always
been done in concert with input from a cross section of public
health professionals and industry representatives.
FDA considers the existing model food codes to be conceptually
sound. Notwithstanding this, the Agency is completing work on a
periodic revision of its model food codes. The revised edition
is designed to address new technologies and omissions identified
in the earlier versions. The new document specifically
accommodates HACCP programming and inspection. It is more
clearly written and better referenced.
As with previous model codes, temperature specifications are
being coordinated with USDA. (It is recognized, however, that
there may continue to be legitimate differences between
government specified food processing temperatures to be applied
at the manufacturing level where the product may be in storage,
in transit or otherwise held for an extended period, and those
specified for food preparation in a retail level operation where
food is being readied for consumption. There will also continue
to be differences between federal temperature recommendations
based on safety considerations, and those based on "desired
degree of doneness" by the typical US consumer.) The term
"thermometer" is being replaced with language that acknowledges
other temperature indication devices.
SUBJECT: FDA Personnel
BY: ALB
DATE: 6 OCTOBER 1992
SUMMARY: Not only have many field and headquarters personnel
spent their entire professional lifetimes working in the retail
foods arena, FDA code writers have exercised full access to the
scientific and technical resources of FDA's Center for Food
Safety and Applied Nutrition. They also have consulted with
technical resources at other federal agencies such as EPA, USDA
and USDC which have related responsibilities. With respect to
the new model codes's revision, the Agency also has benefit of
thousands of comments from academic, industry and regulatory
commentors. Although FDA continues to give HACCP training of
regulatory officials a high priority, certainly staffing
limitations are a concern to FDA.
SUBJECT: Industry Self-Control Programs
BY: ALB
DATE: 6 OCTOBER 1992
SUMMARY: FDA recognizes the responsibility that industry has in
assuring that the food it provides consumers is safe and
otherwise in conformance with food laws. The Agency encourages
and applauds industry efforts to provide up-to-date and focused
retail food training and programming.
We acknowledge that a HACCP based TQM program should not be
limited to food safety, but should include other food concerns
such as nutrition. We read with interest your goal to prove that
very few government inspectors will be required "when every
retail food operation is required first to have a HACCP program
before being given a license."
As you noted, FDA has previously reviewed your voluntary industry
HACCP based TQM program manual, and found it to be comprehensive
and suitable for use in conducting HACCP training necessary for
implementing voluntary industry self-control programs.
Understand, however, that FDA recognizes State and local
governmental agencies as having primary responsibility for
regulation the retail segment of the food industry. These
agencies approve plans, license, inspect and initiate needed
enforcement actions for retail food operations. Authority for
these activities is derived from State/local statutes,
regulations and ordinances. FDA serves in an advisory role by
providing model codes, technical support, training and program
evaluation.
The relevance of this to your program is that each of these
agencies will ultimately decide which, if any, of their code's
provisions they will waive or exempt in response to a firm having
a voluntary HACCP based self-control program in place. They will
also determine how often and when they will inspect, and the
qualifications of the officials conduction the inspections.
SUBJECT: FDA Assistance Requested
BY: ALB
DATE: 6 OCTOBER 1992
SUMMARY: It is FDA's opinion that regulatory authorities may
safely accept a combination of time and food temperature as a
public health control when based on accepted time/temperature
relationships and incorporated in a HACCP plan. The material
contained in the manual FDA reviewed along with the information
included in your letter is not complete enough for any Agency
decision about acceptability of the relationships that you
propose to use. FDA is available to review proposed
time/temperature relationships with supporting data for possible
acceptance.
FDA has always encouraged joint educational programming by the
food industry, the government and educational institutions. We
recommend that you endeavor to work cooperatively with
representatives of the State and local agencies. FDA will
continue to provide as much HACCP training and training support
as it can with its available resources.
SUBJECT: Inspection report on Cruise ship
BY: LEG
DATE: 5 OCTOBER 1992
SUMMARY: Ship in question, travels in international water and is
therefore inspected by the Public Health Service/Centers for
Disease Control (CDC). The FDA regulates passenger conveyances,
including ships, under Title 21 of the Code of Federal
Regulations. These regulations, however, only permit the FDA to
regulate those conveyances conducting interstate commerce. The
address for the Centers for Disease Control Vessel Inspection
Program is as follows:
US Dept. of Health and Human Services
PHS
CDC
Center for Environmental Health and Injury Control
Vessel Inspection Activity
1015 N. American Way, Room 107
Miami, FL 33132
(305) 536-4307
SUBJECT: Sale of lemon meringue pies at ambient temperature.
BY: RDB
DATE: 30 SEPTEMBER 1992
SUMMARY: Data for lemon meringue pies (8" and 10") was examined.
Food items intended for holding or display at ambient temperature
must be non-potentially hazardous. The data you have provided,
in support of your request to hold the lemon pies at ambient
temp., is based on ph levels of the components of the pie. You
indicate that the pH of the meringue and filling portions of the
pie are adjusted to a level below 4.6.
You have provided lab analyses to show that the meringue and the
filling have a pH below 4.6. This is also shown for the
interface between the meringue and the filling and the filling
and the crust.
Our opinion that lemon meringue pies, produced with the same
standardized formulation as the analyzed products, are acceptable
for display and sale at ambient temperature. Further, we
understand that the lemon meringue pies to be displayed at
ambient will be identified using the certain product codes and sold under the
specified brand name. The individual product identifier is necessary so it
can be readily determined which pies are non-potentially hazardous.
Regulatory personnel may contact you for a copy of the lab data
or request written assurance that a standardized formulation is
used to consistently deliver a product with the specified pH. In
addition, the regulatory authority has the option to sample the
product for analysis at any given time to verify that specified
levels are maintained.
SUBJECT: A copy of the study report on the shelf stability of
Pumpkin Pie
BY: RDB
DATE: 30 SEPTEMBER 1992
SUMMARY: Study report you request contains proprietary
information. as such, it is available only through the product
manufacturer.
SUBJECT: Meringue Topped Creamed Filled Pies Produced at
Retail.
BY: CSO
DATE: 21 SEPTEMBER 1992
SUMMARY: The information you submitted concerning refrigeration
of cream filled pies produced at retail has been reviewed and we
concur with your comments. The pies were made in the retail food
stores form creme pie filling and meringue mix. Letters on this
specific issue written by the Retail Food Protection Branch on
Oct. 5, 1987 and on Aug. 26, 1988. The conclusions stated in
these letters about the variability of production at retail and
the need to evaluate the finished products on a case-by-case
basis for exception from the 1986 Potential Hazardous Food
Definition Interpretation are still applicable.
SUBJECT: Clarification on the difference between an opinion
letter issued by the FDA RFPB and a FDA model code
interpretation.
BY: CSO
DATE: 31 AUGUST 1992
SUMMARY: FDA opinion letters can be used by State and local
programs as guidance, along with other information they are
collecting on the subject, in making their own decisions on
similar questions. The FDA model food codes are not amended by
FDA's opinion letters.
FDA recognizes State and local food protection agencies as having
primary responsibility for the regulation of the retail segment
of the food industry. These agencies license, inspect and
enforce their own food statutes, regulations and ordinances, most
which are based on FDA's model food codes. FDA serves in an
advisory role and provides guidance based on its model codes and
Title 21, Code of Federal Regulations (CFR)
An interpretation is developed in response to a broad public
health concern that is not covered current FDA model food codes.
The development process includes extensive research and
consultation with FDA and other recognized experts in the
particular area of concern.
A draft of the proposed interpretation is submitted for review
and comment to our FDA regional specialists, to representatives
from professional associations and industry, and to anyone else
who has expressed a particular interest in the proposal. The
comments are collated, reviewed and then incorporated in the
final document which is submitted for formal clearance with FDA
components and with the other federal agencies that have related
interests and capabilities.
The FDA model food code interpretations which are published and
widely circulated provide detailed guidance on dealing with the
public health concern and sufficient scientific and other
background information to support its conclusions. It is FDA's
intention that the FDA model food code interpretations amend the
applicable sections of the FDA model food codes.
In the case of a subject that is specifically covered in the
code, the interpretation even takes on greater authority than the
original code provision. This type of interpretation represents
more current technical information and policy. Examples of this
type of interpretation include the potentially hazardous food
interpretation and the shell egg interpretation.
We also recognize that some State's or local's administrative
procedures require varying degrees of formal adoptions of FDA
interpretations, before they can be implemented in their own
regulations or ordinances which are based on the FDA model food
codes.
Opinion letters are FDA's responses to written requests for
guidance on subjects which are already included in the existing
model food codes. The letters generally deal with specific
circumstances or situations and our response summarizes the
relevant facts.
Similar previous requests are reviewed, the appropriate person
knowledgeable in the area is identified and consulted and a
response is prepared. An opinion simply represents our very best
experienced opinion based on available knowledge at FDA's CFSAN
at a given time.
Opinion letter responses do not receive the high level of
research and comment that an FDA model code interpretation does.
It is not further researched or peer reviewed outside the Center,
nor is it customarily cleared by anyone other than CFSAN's Div.
of Regulatory Guidance or Div. of Microbiology. It does
represent agency policy, but it does not carry the weight of
either a model code provision or and interpretation for those
agencies which are utilizing the model food codes.
SUBJECT: Storm Water Detention Ponds at Airport
BY: LEG
DATE: 13 AUGUST 1992
SUMMARY: You included a set of schematics showing the proposed
location of detention ponds and adjacent catering firms at the
new airport facility.
The detention ponds are specifically designed to contain storm
runoff water from the surrounding area and will not contain
sewage. The approximate 400-600 foot distance between the pond
and the kitchen facility appears adequate. In our opinion, the
ponds do not pose a hazard to food preparation in this
facility.
SUBJECT: Cleaning closed lines of product delivery systems by
recirculating cleaning solutions
BY: RDB
DATE: 11 AUGUST 1992
SUMMARY: This device controls the existing cleaning cycle in a
different manner. The flow of cleaning solution through the
lines consists of alternating pulses of compressed air and the
cleaning solution.
It is our opinion that the device is acceptable for cleaning and
sanitizing equipment if it is established that the device will
routinely render equipment clean and provide adequate sanitizing
treatment. The sanitizing treatment follows the cleaning process
with application of sanitizing solutions identified in the Code
of Federal Regulations, Title 21, Section 178.1010.
SUBJECT: The term "direct flight" and the airlines failure to
change the linen covers on the headrests
BY: LEG
DATE: 22 JULY 1992
SUMMARY: This office does not address the issue of "direct
flights", but does address the sanitation aboard domestic
airlines. The regulations governing the sanitation of passenger
conveyances, caterers, and support facilities are given in the
Code of Federal Regulations (21 CFR Parts 1240 and 1250). These
regulations, although not specifically requiring that airlines
provide changeable or disposable linen cloths on headrests, do
require that all areas of a conveyance be kept clean while in
transit.
SUBJECT: The entering and holding of foreign food products
aboard foreign aircraft for use on return flights
BY: LEG
DATE: 22 JULY 1992
SUMMARY: The FDA would not object to food from non-U.S. sources
being held on board foreign flag aircraft at U.S. airports for
use in outbound international flights as long as the food is safe
and is held under sanitary conditions. Such food would be
considered as remaining in non-import status for purposes of
FDA's interstate travel sanitation program operations. FDA
would, however, expect the carrier company to establish and
operate a quality assurance program to assure that critical
elements such as food temperature control are met for all such
occurrences. Deviations from sanitation guidelines will invoke
more restrictive requirements.
SUBJECT: Silicone baking forms
BY: RDB
DATE: 17 JULY 1992
SUMMARY: You specifically inquired which item in Sec.
175.300(b)(3)(xxvii)(c) [Silicones and their curing catalysts] of
title 21, Code of Federal Regulations (CFR), applied to your
product. We consulted with the Indirect Additives Branch of the
Division of Food and Color Additives and we concur with your
assumption that item (4) is appropriate with respect to your
product. This item states:
"(4) From coating intended for repeated use, and employed
other than as a component of a container, not to exceed 18
milligrams per square inch of coated surface."
SUBJECT: Butter Blend-A Potentially Hazardous Food
BY: RDB
DATE: 17 JULY 1992
SUMMARY: Information obtained relating to the recent butter
blend Staphylococcus intermedius outbreak indicates that the
product may contain two to 33 per cent butter. Butter may be a
component of butter blends that renders such products potentially
hazardous.
The Retail Food Protection Branch regards butter as a potentially
hazardous food. The decision, as to whether or not a product is
potentially hazardous, is base on the Retail Food Protection
Program Information Manual interpretation dated May 9, 1986.
Of particular importance with respect to butter are the factors
of pH and aw. The literature indicates that the pH of butter may
range between 6.1 and 6.4 and the aw value is well above 0.90.
The salt content of butter may be assumed to act as an
antimicrobial constituent. However, the antimicrobial property
of the salt content usually found in butter does not appear to be
significant in controlling microbial growth.
An article entitled "Effects of time and temperature on
Salmonellae in Inoculated Butter" appeared in the Journal of Milk
and Food Technology, Vol. 32, No. 12, 1969. This article
concludes, through experimentation and with varying salt content,
that butter will readily support Salmonella growth at room
temperature.
Other ingredients that may be used in butter blends include whey
powder, dried buttermilk powder or non-fat dry milk. Any of
these in reconstituted form are considered potentially hazardous.
It is our opinion that butter blends are potentially hazardous
foods that are subject to time and temperature control. An
exception is made to the refrigeration requirements in products
having a pH level of 4.6 or less, an aw of 0.85 or less, or
laboratory results of inoculation studies showing that
combinations of factors preclude growth of inoculated
organisms.
SUBJECT: Recently developed pumpkin pie formulation
BY: RDB
DATE: 2 JULY 1992
SUMMARY: You submitted information to establish that the new
pumpkin pie produced by your firm is not a potentially hazardous
product. This information demonstrated, based on an inoculation
study, that the product does not support the growth of the
inoculated organisms, even at the interface of the filling and
the crust.
The pumpkin pie filling formulation used in this study contained
a specified concentration of preservative in combination with a
controlled pH level.
Based on the lab results you provided, it is our opinion that
pumpkin pies manufactured with a filling formulation containing
the specified preservative and pH level, is not a potentially
hazardous food under the provisions of FDA's model food codes.
We recommend that pie manufacturers clearly identify each of
their pies (based on specific formulation) as requiring
continuous cold storage (potentially hazardous product which must
be maintained frozen or refrigerated), or suitable for room
temperature storage (non-potentially hazardous).
The pie tin is embossed in the bottom center with 1/4 inch high
characters as a unique identifier code for the non-potentially
hazardous pumpkin pie.
Some regulatory personnel or retailers may request to see a copy
of the study report or require written assurance that a
standardized formulation is used to consistently deliver a
product with the specified preservative and pH. Further, the
regulatory authority has the option to sample the product for
analysis at any given time to verify that the specified levels
are maintained.
SUBJECT: Galvanized shelving in vessel chill/freezer rooms.
BY: LEG
DATE: 24 JUNE 1992
SUMMARY: There is little public health significance on the use
of galvanized shelving in vessels chill/freezers. We would not
object to the use of galvanized shelving in these areas.
SUBJECT: Displaying baked pumpkin pies at room temperature.
BY: RDB
DATE: 19 JUNE 1992
SUMMARY: These data are deemed to be inadequate for the
following reasons:
- The levels of potassium sorbate and sodium benzoate used in
the formulation of the pies should be provided.
- The maximum pH level of the product prepared from a specific
formulation should be indicated.
- A pumpkin pie formulation and processing protocol that will
deliver consistent product needs to be in place.
- A one pie study is not adequate. Perhaps the study could include pies
from different runs on subsequent days to further verify that
preparation of the formulation remains consistent.
It is noted that there was a nearly total reduction of counts of
the various test organisms, even at day one of the test. Since
the preservatives you are using are bacteriostatic, perhaps there
are other ingredients or factors that appear to produce a
bacteriocidal effect on the test organisms.
SUBJECT: Bottled water and ice
BY: ALB
DATE: 18 JUNE 1992
SUMMARY: FDA regulates domestic bottled water plants under
authority of the Food, Drug and Cosmetic Act (21 USC 342, 348,
371, 374), the Public Health Service Act (42 USC 264) and the
Code of Federal Regulation (CFR), "Processing and Bottling of
Bottled Drinking Water" (21 CFR 129). FDA also classifies and
regulates bottled water as a food, under the provisions of the
Safe Drinking Water Act of 1974. This is done in keeping with a
Memorandum of Understanding between FDA and the Environmental
Protection Agency (EPA).
Ice plants are covered by FDA under authority of the FD&C Act,
the PHS Act, and the CFR, "Current Good Manufacturing Practice in
Manufacturing, Packaging, or Holding Human Food" (21 CFR 110).
Preparation and handling of ice at retail is also covered under
FDA's model codes (76 Food Service Sanitation, 78 Food and
Beverage Vending, 82 Retail Food Store Sanitation).
SUBJECT: Rabbit industry's concern over the possible effects of
viral hemorrhagic disease (VHD)
BY: LEG
DATE: 17 JUNE 1992
SUMMARY: Inquiry would come under the jurisdiction of the USDA's
Animal and Plant Inspection Service. In addition, OSHA and NIOSH
should be contacted with regard to employee protection in the
rabbit industry with regard to VHD.
SUBJECT: Potentially Hazardous Nature of Pepperoni Bread
Product
BY: RDB
DATE: 11 JUNE 1992
SUMMARY: Information is provided to support the point that
pepperoni, by itself, does not support the rapid and progressive
growth of infectious or toxigenic microorganisms. However, no
data is provided to show that such growth will not occur when the
pepperoni is combined with a bread product.
The issue is whether or not the combined "meat" and bread product
is in a form capable of supporting the rapid and progressive
growth of infectious or toxigenic microorganisms during
preparation or after baking.
Based on Retail Food Protection Program interpretation relating
to potentially hazardous food, unless the final bread product is
non-potentially hazardous due to pH or water activity, it appears
necessary to inoculate the product with test organisms, if it is
proposed to prepare and market the products without
refrigeration.
Staphylococcus aureus is recommended to determine if toxin could
be produced during the preparation or proofing process. The
toxin produced by this organism is heat stable and would be found
in the baked product of it were produced during the proofing
process.
S. aureus and Salmonella are suitable organisms for post baking
inoculation. If there is no growth of the inoculated organisms,
the product is considered non-potentially hazardous and time-
temperature management is not be required.
SUBJECT: Procedure proposed for maintaining the temperature of
pasteurized liquid egg mix.
BY: RDB
DATE: 10 JUNE 1992
SUMMARY: Firm proposed to use an insulated polyethylene device
filled with ice and water to hold egg mix cartons at preparation
stations during the breakfast period.
Primary concern relates to Section 2-301(e) of the model code
which states in part that "Packaged food shall not be stored in
contact with water or undrained ice." It is our opinion that the
egg mix cartons in question are a packaged food within this
definition.
The principal reason for the long standing prohibition against
wet storage is to prevent contamination of food contained in
submerged containers. This can be due to unopened packages which
leak, or to previously opened containers which tip over allowing
contaminated liquid to enter the carton.
It is our opinion that the proposed practice does not meet the
intent of the model food protection codes relative to acceptable
storage procedures and protection from contamination.
SUBJECT: Chain's beef cooking temperatures may be in conflict
with model food protection codes
BY: RDB
DATE: 27 MAY 1992
SUMMARY: With respect to the cooking of roast beef, the model
codes specify parameters for oven temperature, internal
temperature and holding times for various internal temperatures.
(A copy of Section 2-403(c) relating to beef roasts is enclosed).
Based on Chains the convection oven is maintained between 200x
and 220x F when cooking roasts. The model codes specify an oven
temperature of either 350x or 250x F depending on the size of the
roast to be cooked. We have been asked if there is an exception
to the code's oven temperature specification relating operating
instructions. We have nothing in our files to serve as a basis
for an exception.
SUBJECT: Catsup Bottle vs Reusable Squeeze Bottle
BY: RDB
DATE: 27 MAY 1992
SUMMARY: A catsup bottle is designed to be used once then
discarded. Further, it is generally accepted that these bottles
are not designed to be easily cleanable.
The same design criteria applies to reusable squeeze bottles.
However, in the letter, states "Although the nozzle is small, it
has been shown to be easily cleanable". Ease of cleaning appears
related to the concept that the nozzle can be removed from the
container.
The letter is seeking support for guidelines that can be used to
determine of the design of a bottle is adequate to allow reuse.
It has superbly identified key components necessary to render a
decision. Among these components are materials, durability,
design and disassembly features.
While no design specifications are available relating to size of
openings, etc., the construction components cited in the previous
paragraph can be used to render a decision relative to reusable
squeezable bottles.
It can be determined, by obtaining information from the
manufacturer, that materials are safe from a food additives
viewpoint. Durability can be assessed through observation and
design for cleanability can be determined fairly readily by
scrutiny of the part or parts requiring cleaning.
SUBJECT: Proposed Memorandum of Understanding (MOU) between FDA
and the Conference for Food Protection (CFP)
BY: LRL
DATE: 21 MAY 1992
SUMMARY: FDA looks to the National Conference on Interstate Milk
Shipments (NCIMS), Interstate Shellfish Sanitation Conference
(ISSC) and the Conference for Food Protection (CFP) for their
"one State/one vote" process in connection with FDA's recommended
model ordinances/codes, manuals of operation, interpretations,
program procedures and methods intended for State and local
adoption and implementation.
However, FDA recognizes the importance and vital contributions of
the many organizations that share common interests around FDA's
full spectrum of mandates, including those in the retail foods
area. The Agency appreciates their counsel, the forums for
information exchange that they provide, and their mutual efforts
in support of public health and food safety.
SUBJECT: April 8 FDA/USDA packet of information on preventing
foodborne illness which listed different temperatures (160xF,
165xF, 180xF) for cooking poultry.
BY: ALB
DATE: 20 MAY 1992
SUMMARY: The different temperature recommendations are the
result of the two federal agencies having: different primary
constituencies; related objectives which are not inconsistent,
but different; and a desire to inform each of our constituencies
about what we and other organizations (JAMA, CDC, and the
National Advisory Committee on Microbiological Criteria for
Foods) are each recommending.
We are not aware of the reference you make to 160xF for cooking
poultry.
The Public Health Service and FDA have traditionally specified
165xF for the cooking of poultry in the model food codes. The
many editions of these model codes have been widely adopted by
the some 3,000 food control agencies at all levels of government
for regulation commercial and institutional food service, retail
food stores and food vending operations. This temperature is
based only on what is required for food safety, i.e. destruction
of anticipated possible levels of Salmonella and other human
pathogens. It continues to be the temperature FDA recommends for
the cooking of poultry by retail level food establishment
operators, and the temperature it recommends that food regulatory
officials enforce in retail food establishments.
USDA has traditionally recommended 180xF to consumers for the
cooking of poultry. We believe this temperature goes well beyond
those required to assure food safety and are intended to address
additional considerations such as the "desired degree of
doneness" among many American consumers.
Certainly both recommendations for cooking poultry are
appropriate considering the different audiences and objectives.
The confusion results when the separate recommendations are
combined and provided to each of the groups for "informational
purposes so each will be informed about what the other is being
advised".
SUBJECT: Electronic fly control systems advertisements
BY: RDB
DATE: 19 MAY 1992
SUMMARY: Inquiry referenced an advertising claim that states
"FDA accepted for use in sensitive areas such as in and above
food preparation".
We can find no record of correspondence where FDA declared that
such systems could be used as specified in the above quote. We
are very concerned with the usage of any insect control system or
device above food preparation (surfaces or equipment).
SUBJECT: The pH Factor of Pastry Products-Potentially Hazardous
Food
BY: RDB
DATE: 8 MAY 1992
SUMMARY: Pastry product may or may not be potentially hazardous,
based on different formulations. Even a specific firm, such as
the one mentioned in you inquiry, may produce both types.
Food regulatory officials should base their decision, as to
whether or not a product is potentially hazardous, on the Retail
Food Protection Program Information Manual interpretation dated
May 9, 1986. The interpretation is entitled: DEFINITIONS-
POTENTIALLY HAZARDOUS FOOD.
The information you provided suggests that pH is the factor being
relied upon to exclude the product in question from the
potentially hazardous category.
Usually, a product having a pH level of 4.6 or less is not
considered to be potentially hazardous and laboratory evidence
derived form challenge testing is unnecessary. Under these
circumstances the manufacturer can be expected to provide written
assurance that a standardized formulation will consistently
result in a product with the specified pH level. Further, the
regulatory authority has the option to sample the product for pH
analysis at any given time to verify that the specified level is
maintained.
With respect to the data supplied by the manufacturer, it is
deficient in one detail. There is no mention of the pH of the
pastry or, more critically, of the interface where the pastry and
the filling meet. A pH analysis of the interface of the finished
product may indicate that the level of 4.6 or less is attained at
that juncture. If so, the product would be considered non-
potentially hazardous.
If the pH level of 4.6 or less is not achieved at the interface
it may be necessary to challenge test the pastry product with
toxigenic staphylococci to establish whether or not growth and
subsequent toxin production occurs. Staphylococcus aureus is the
organism of concern in this product because of the product's
relatively low pH and Aw.
The influence of an unknown amount of potassium sorbate added as
a preservative may be difficult to determine except as part of a
challenge study.
We recommend that pastry manufacturers clearly identify each of
their pastry products (based on specific formulation) as
requiring continuous cold storage (potentially hazardous product
which must be maintained frozen or refrigerated), or suitable for
room temperature storage (non-potentially hazardous).
For firms doing challenge testing, FDA is available as needed to
assist in the review of laboratory testing protocol, or in the
evaluation of the study report.
SUBJECT: Food items prepared in foreign catering kitchen for
service aboard domestic and international airline flights which
originate in the U.S.
BY: LEG
DATE: 30 APRIL 1992
SUMMARY: The FDA's Interstate Travel Sanitation program is
charged with ensuring that environmentally sound sanitary
conditions, including food service sanitation, are maintained by
interstate (domestic) passenger conveyances. The authority for
the ITS program is found under the Public Health Service Act in
accordance with Title 21 of the Code of Federal Regulations
(CFR), Parts 1240 and 1250.
Catering firms which provide food for domestic flights are
required to conform to the above mentioned regulations, as well
as the code provisions listed in the Food Service sanitation
manual. These firms are subject to routine FDA inspection to
insure compliance with the regulations.
Under the current Federal regulations, food prepared at catering
firms located in another country cannot be used in food service
operations aboard U.S. domestic airline flights. The existing
regulations do not currently address the issue of food service
aboard international flights.
SUBJECT: Deterioration in hygienic conditions of toilets of
large aircraft
BY: LEG
DATE: 29 APRIL 1992
SUMMARY: Although Federal regulations do not directly address
the issue of flight attendants being designated to monitor and
maintain a basic level of hygiene in aircraft toilets, 21 CFR
1250.49 states that "conveyances while in transit shall be kept
clean..." and 21 CFR 1250.50 states that "where toilets and
lavatory facilities are provided on conveyances they shall be so
designed as to permit ready cleaning...". The majority of
domestic flights are less than 3-4 hours in duration, however,
some flights, particularly those from coast to coast occasionally
exceed 4 hours. The onboard cleaning of toilet facilities, as
well as the remainder of the aircraft interior, is usually
conducted between flights and at the termination of the scheduled
flight. In addition, concerning your comment that flight
attendants are also food handlers; flight attendants are required
to wash their hands prior to serving food or beverages as
outlined under 21 CFR 1250.32.
FDA Interstate Travel Sanitation Specialists are located
throughout the U.S. at various FDA District offices. These
Specialists conduct routinely scheduled, unannounced sanitation
inspections of all conveyances, conveyance support facilities and
various water operations. In addition, we rely upon passengers,
such as yourself, to act as our extra "eyes and ears" in
reporting any problems you may encounter while traveling.
The FDA has the responsibility of enduring a safe food supply
aboard all domestic passenger carriers. Food sanitation
inspections of all domestic airline catering firms are conducted
routinely and also as deemed necessary by the inspection FDA
district office. At present, foreign catering firms are not
routinely inspected by the FDA.
SUBJECT: Nylon Product as a Coating on Commercial Foodservice Shelving Which
Encounters Direct Food Contact
BY: RDB
DATE: 16 April 1992
SUMMARY: A fundamental concern relates to the issue of "safe materials".
Materials supplier states that the ingredients of the material are included
under several identified sections of the Code of Federal Regulations
pertaining to food additives. Samples provided meet the criteria of the
model codes with respect to corrosion resistance, smoothness and ease of
cleanability.
SUBJECT: Food and Drug Administration's (FDA) Position With Regard to
Stainless Steel Scrubbers
BY: RDB
DATE: 15 April 1992
SUMMARY: FDA has not taken a position to preclude the use of stainless
steel scrubbers in food service establishments. It continues to be FDA's
position that such scrubbers can be used as part of the cleaning process if
accomplished in compliance with the provisions of the model Food Service
Sanitation Code. Compliance is achieved by rinsing equipment and utensils
free of detergent and abrasives as specified in Section 5-103(d)(3) of said
Code.
SUBJECT: Clarification of a Claim Relating to Electronic Fly Control Systems
Advertisements
BY: RDB
DATE: 15 April 1992
SUMMARY: Question if the advertising claim "FDA accepted for use in
sensitive areas such as in and above food preparation" is true or not. We
can find no record of correspondence where FDA declared that such systems
could be used as specified in the above quote. We are very concerned with
the usage of any insect control system or device above food preparation
(surfaces or equipment).
SUBJECT: Food Items Prepared Properly and Cooked and Not Consumed for a
Period of Up to One Hour
BY: RDB
DATE: 26 March 1992
SUMMARY: Time is a factor in determining whether or not pathogens can grow
to a point where foodborne illness is likely to occur. In the situation
presented the food descends to a temperature of 100x F in a period of one
hour. Apparently, consumption occurs at this pint. The "time" factor is
short enough under these circumstances that growth of pathogens is not likely
to pose a threat of foodborne illness. Since "time" becomes the control
factor a method of monitoring must be provided to ascertain that this control
factor is not exceeded. Our opinion is that using "time" as a control is
acceptable and meets the intent of FDA's model food protection codes when
applied in conformance to the following provisions:
The time must not exceed four (4) hours;
The product is marked to indicate the time after which it will be
discarded;
The marked time commences when the product is removed from temperature
control;
Written procedures relating to the above items are available to food
regulatory officials and to operators of establishments using time as a
control; and
Unmarked product shall not be served. If unmarked product is observed
it shall be discarded.
SUBJECT: Are There Any Concerns in Regards to Serving Fresh Raw Vegetables
Such as Carrots, Bell Peppers, Etc., where the Temperature May Have Risen to
40x- 45x F. After a Two Hour Period
BY: RDB
DATE: 26 March 1992
SUMMARY: Fresh vegetables, such as carrots or bell peppers, are not likely
to be implicated in foodborne illness outbreaks attributable to rapid and
progressive growth of infectious or toxigenic organisms. There should be no
problem with these products if the temperature were to rise to 45 - 55x F.
SUBJECT: Rethermalization of Sous Vide Prepared Food.
BY: RDB
DATE: 26 February 1992
SUMMARY: It is our opinion that rethermalization of the commercially
processed (fully cooked) product can be accomplished in either of two modes.
First, a product, rethermalized in response to an individual consumer order,
may be reheated to any temperature for immediate service to that consumer.
Secondly, commercially prepared food that is rethermalized and held hot prior
to service must be reheated to 140x F, or more, and maintained at that
temperature during the holding process. In the first mode, safety is
provided by virtue that no significant amount of time elapses between the
rethermalization of a ready-to-eat product and its consumption. In the
second mode, a safety factor is necessitated since the product is held for an
unspecified time span. The safety factor, in this case, is the temperature
of 140xF.
SUBJECT: Pumpkin Pies Sold at Ambient Temperatures
BY: RDB
DATE: 28 January 1992
SUMMARY: Pumpkin pies may or may not be potentially hazardous, based on
different formulations. Even a specific firm may produce both types. Food
regulatory officials should base their decision, as to whether or not a
product is potentially hazardous, on the Retail Food Protection Program
Information Manual interpretation dated May 9, 1986, DEFINITIONS -
POTENTIALLY HAZARDOUS FOOD. The data supplied makes no mention of the pH of
the crust or, more critically, of the interface where the crust and pie
filling meet. If the pH level of 4.6 or less is not achieved at the
interface it may be necessary to challenge test the baked pie with toxigenic
staphylococci to establish whether or not growth and subsequent toxin
production occurs. Staphylococcus aureus is the organism of concern in this
product because of the product's relatively low pH and Aw. The influence of
an unknown amount of sorbic acid added as a preservative may be difficult to
determine except as part of a challenge study.
SUBJECT: Evaluation of Cheese Danish to Determine Potentially Hazardous
Status
BY: RDB
DATE: 13 January 1992
SUMMARY: The firm's microbiological data indicates that these products are
microbiologically safe when held at ambient temperature for a period of two
days, provided the products are not subject to gross abuse. It appears that
microbiological tests were conducted on finished product without benefit of
inoculation with challenge organisms. Chemistry tests reveal pH values for
the cheese of 4.84 or higher. The water activity (Aw) of the cheese varies
from a level of 0.930 to 0.965. There is no information relative to the pH
or Aw values of the composite product or at interfaces of cheese and crumb.
Lacking any data to the contrary, the cheese danish discussed herein appears
to be a potentially hazardous food and is subject to the temperature controls
specified in the model food protection codes. A microbiological challenge
test of the product, preferably with toxigenic Staphylococcus aureus and
evaluation for subsequent toxin production, can provide a basis to
re-evaluate the potentially hazardous nature of the product.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1991
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Objections to Certain Verbiage Contained in Brochures Advertising
Flying Insect Control Devices
BY: RDB
DATE: 12 December 1991
SUMMARY: A statement quotes FDA as asserting that "because it does not use
a high voltage charge which could impel dead insects away from the trap, it
is acceptable for use above and around food areas under the codes and
guidelines for restaurants." We can find no record of correspondence where
FDA declared that such systems could be used as specified in the above quote.
We are very concerned with the usage of any insect control system or device
above food preparation (surfaces or equipment).
SUBJECT: Temperature of Frozen Food
BY: RDB
DATE: 14 November 1991
SUMMARY: The model code does state that frozen food should (not
shall) be stored at a temperature of 0~F. This temperature is
based on typical retail freezer temperature settings and on food
quality (no safety) considerations. This temperature is not based
on public health considerations since pathogens of concern
demonstrate no appreciable growth during the frozen state,
regardless of the frozen temperature. The model code frozen food
temperature provisions specify only that frozen food shall be
"maintained" frozen.
SUBJECT: Pumpkin Pie
BY: RDB
DATE: 8 October 1991
SUMMARY: A firm's specific proposal requested that they be allowed
to sell unrefrigerated pumpkin pies based on product reformulation,
the addition of potassium sorbate and scientific testing to
demonstrate the bactericidal effect of the preservative and the
lowered pH. The report does not mention the pH and Aw of the crust
or of the interface where the crust and the pie filling meet.
Also, there is no information provided relative to the potassium
sorbate levels of the crust or interface. Further, there is no
scientific evidence that staphylococci or other foodborne pathogens
will not grow in the crust or at the interface of the crust and
filling. It is the agency's opinion that further data must be
developed to support the theoretical speculation that the pie crust
(and interface) will not support the growth of toxigenic
staphylococci and subsequent toxin production.
SUBJECT: Electronic Fly Traps
BY: RDB
DATE: 23 September 1991
SUMMARY: The system brochure states in part "...FDA accepted for
use in sensitive areas such as in and above food preparation. The
statement apparently quotes FDA as asserting that "because it does
not use a high voltage charge which could impel dead insects away
from the trap, it is acceptable for use above and around food areas
under the codes and guidelines for restaurants. We, at FDA, have
not declared that such devices could be used over or above food
preparation areas or food contact equipment.
SUBJECT: Vacuum Packaged Potato Product in Brine
BY: RDB
DATE: 23 September 1991
SUMMARY: Vacuum packaged potatoes need to be refrigerated. The
supporting microbiological data appears to show that vacuum
packaged potatoes in brine do not support the growth of C.
botulinum up to 10x C (50x F). The concern is that the data do not
rule out the possibility of toxin production at a higher
temperature.
SUBJECT: Vegetable Bread Products
BY: RDB
DATE: 23 September 1991
SUMMARY: The vegetable breads in question are products containing
broccoli, spinach or zucchini/tomato and baked as specified by the
manufacturer. The products tested indicate water activity levels
ranging from 0.93 to 0.95. The pH level is not indicated for the
bread products. However, there is no information provided to
indicate that the end product is acidified or that it will have a
pH level of 4.6 or less. It is our opinion that the vegetable
bread products fall within the category of potentially hazardous
foods. The product should be held under refrigeration, 45x F or
less, at all times to prevent growth of organisms that may
contaminate the bread after baking.
SUBJECT: Microbiological Analyses of Vacuum-Packaged Foods
Containing a Botulinum Barrier
BY: RDB
DATE: 22 July 1991
SUMMARY: In a letter date January 31, 1989 to Mr. Peter R. Buss,
Bizerba, Inc., Mr. Thomas L. Schwarz (FDA), provided
recommendations relating to vacuum-packaging in retail food
operations. The question relates to the need to test for viable C.
botulinum on a routine basis. It is our view that there is no
necessity to perform this test on a routine basis for the following
reasons: (1) only foods that do not support the growth of C.
botulinum can be vacuum-packaged at retail; (2) the ten (10) day
shelf life provides a further parameter of safety with regard to
this product; and, (3) the food processing operation has controls
to assure that the criteria which preclude growth of C. botulinum
are in place.
SUBJECT: Quaternary Ammonium Compounds - Concentration (ppm)
BY: RDB
DATE: 21 June 1991
SUMMARY: Questions have emerged concerning acceptable use of
quaternary ammonium compound (QAC) sanitizers. There are three
issues that have been questioned: use at double strength, accuracy
of test strips, and a safe range of concentration for this
compound. It is quite clear that sanitizers applied at the single
strength, temperature and time specified in the Code are
efficacious for all sanitization applications, including rinsing,
spraying or swabbing. Since this double strength requirement is
not based on known scientific justification, it is no longer
recommended. Test strips are being used as a "field check" to
confirm that chemical sanitizer is present in the sanitizing rinse
water and to determine the approximate concentration. The
concentration, in parts per million, is determined to assure that
the strength of the solution is adequate to be effective but not so
great as to create food additive problems. The accuracy of test
strips, which are designed for use with a specific chemical
sanitizing compound, is deemed acceptable for field test purposes.
Reagent type kits provide quantitative readings and are like to be
more accurate. Related to the issues of the test strips, are
requests for recommendations on the conditions of use for test
strips - for example, time, temperature, and water hardness
conditions. The QAC listed under paragraph (b) of 21 CFR 178.1010
and the concentration or range of concentration now allowable are
as follows:
21 CFR 178.1010(b) Minimum-Maximum Concentration (ppm)
( 9) 200*
(11) 200*
(16) 200*
(17) 150*
(18) 200*
(22) 150 --- 400
(23) 150 --- 200
(32) 150 --- 400
(33) 150 --- 400
For single-point concentration QAC formulations [identified with an
asterisk (*) above], it is the Retail Food Protection Branch's
opinion that a sanitizing solution complies with the model food
code provisions when the test strip reads closer to the 200 ppm
level (150ppm for #17) than the next higher or lower comparator
level.
SUBJECT: Balut -- (Embryonated Egg)
BY: RDB
DATE: 19 June 1991
SUMMARY: Baluts are derived from fertile eggs, generally chicken
or duck eggs, which are incubated for a period of time shorter than
is necessary for hatching. The period of incubation is generally
14 to 18 days. The eggs, containing a developing embryo, are then
removed from incubation and development ceases as the temperature
drops below the incubation temperature. Issues relating to retail
sale of the product include consideration of sources, temperature
specifications and labeling. The States, in a cooperative
agreement with USDA, regulate balut production by way of their egg
laws or applicable regulations. It has been reported that
Salmonella enteritidis (S.e.) has been isolated from the contents
of intact shell eggs. S.e. may, therefore, be present in the
developing embryo and continue to generate after the embryonated
egg is removed from the incubator.
SUBJECT: Gloves, Masks and Hairnets for Food Handlers
BY: RDB
DATE: 14 June 1991
SUMMARY: The model codes FDA provides for State and local adoption
contain criteria relating to handwashing and hair restraints.
Section 3-201: This section contains the criteria applicable to
handwashing. Section 3-301(b) Effective hair restraint
requirements are included herein. Section 2-504 This item
specifies that suitable dispensing utensils and single-service
articles must be used to avoid unnecessary manual contact with
food. It is this item that provides for the use of gloves, when
necessary, if no other means of preventing contact with food are
available. There is no specification relating to the use of masks
in the model codes and we are not aware of such requirements in any
State or local code or ordinance.
SUBJECT: Asbestos Contamination of Water Line Due to Break in the
Line
BY: LEG
DATE: 11 June 1991
SUMMARY: Asbestos is considered to be in a non-hazardous state
when ingested through either food or drink, as would be the case in
this situation. However, asbestos becomes a serious health hazard
when breathed.
SUBJECT: Popcorn Used as a Packaging Material -- Follow-up to Our
Memorandum of 13 February (1991) on This Subject
BY: RDB
DATE: 31 May 1991
SUMMARY: In our 13 February 1991 memorandum, we provided the FDA
recommendation relating to the use of popcorn as a packing
material. The agency recommendation, at the time, permitted use of
popcorn as a packing material provided a package insert or flyer
was placed in the shipping carton clearly stating that such popcorn
is "not fit for human consumption". This recommendation was
modified with the issuance of subsequent letters by the Division of
Regulatory Guidance (DRG). The Agency's policy essentially
precludes the use of popcorn as a packaging material.
SUBJECT: Use of a Heated Transfer Unit with "Time" as a Public
Health Control
BY: RDB
DATE: 31 May 1991
SUMMARY: Procedures involving the use of a heated transfer unit to
store finished cooked assembled and packaged products for a brief
time prior to sale to customers. Time of residence for each type
of sandwich is set at 5, 10 or 20 minutes. A properly cooked
potentially hazardous product is expected to contain few pathogens.
The time necessary for any surviving pathogens to multiply to
hazardous proportions will exceed the twenty minute hold time
included in your procedures. It is our opinion that the holding
procedures described are acceptable and conform to the intent of
FDA's model food protection codes, provided: the product is marked
to indicate the maximum time it is to be maintained at an
uncontrolled temperature; the marked time commences before a hot
product temperature descends below 140x F; unmarked product and
product for which the marked time has expired is discarded; and,
written procedures relating to the above items are available to
regulatory officials and to all operators of establishments using
time as a control.
SUBJECT: Reuse of Cardboard Boxes and Carriers for Inflight
Service
BY: LEG
DATE: 16 May 1991
SUMMARY: Cardboard boxes may be used for shipment of not-in-use
equipment provided the equipment is washed and sanitized at the
new location prior to its being used. Individual cartons or boxes
are to be used once and then discarded. Snack boxes, snack bags
and other secondary food containers may be transported in original
carton or cardboard box as long as the carton or box remains free
of contamination. Open trays of food can be boarded using clean,
unused cardboard boxes as temporary carriers. Food shall be kept
covered or completely wrapped so as to be protected from
contamination. Individual cartons or boxes are to be used once and
then discarded.
SUBJECT: Use and Storage of Common Hand Towels
BY: RDB
DATE: 14 May 1991
SUMMARY: Specific question relates to Section 6-503 of the model
food protection codes which prohibits common towels. A firm's new
procedure for use of "alley hand towels" (The "alley" is an area
of the kitchen used heavily by servers) was reviewed. The towels,
referred to as "common towels", are immersed in a sanitizing
solution and then wrung out until almost dry. The towel is then
hung in the alley where it is available to several individuals for
wiping hands. The intended use of the cloth towel is to remove
from hands any food spills, e.g.,: spill of condiments on fingers.
Section 6-503 of the model codes specifically prohibits common
towels. A common towel is interpreted to mean a multi-use towel
that is used for hand wiping by more than one person between
launderings. It is our opinion that the use of "alley hand towels"
constitutes a violation of the criteria prohibiting common towels
as specified in Section 6-503 of the codes. The codes are quite
clear on restrictions concerning the use of towels.
SUBJECT: Holding Procedures for Various Sandwiches
BY: RDB
DATE: 14 May 1991
SUMMARY: After adequate cooking, the sandwich is either served to
the customer immediately or -- after being marked to indicate the
time -- is placed on a heat chute for a maximum of ten minutes
holding prior to customer service. All sandwiches held in this
manner are discarded if not sold within the ten minute hold time.
The holding procedure described is acceptable and conforms to the
intent of FDA's model food protection codes, provided: (1) product
is marked to indicate the maximum time it is to be maintained at an
uncontrolled temperature; (2) unmarked product and product for
which the marked time has expired is discarded; and (3) written
procedures relating to the above items are available to regulatory
officials and all operators of establishments using time as a
control.
SUBJECT: Hair Nets
BY: LEG
DATE: 10 May 1991
SUMMARY: Food served aboard passenger aircraft is covered after
preparation and stored prior to boarding. Catering personnel are
required to wear effective hair restraint, including hair nets,
during food preparation. Flight attendants handle the food a
minimal amount of the time while serving passengers. Food becoming
contaminated with hair at this point, would present more of an
aesthetic problem than a health hazard. According to Section 3-
301(b) of the Food Service Sanitation Manual "employees shall use
effective hair restraints to prevent the contamination of food...".
Since the code specifies the use of "effective hair restraints",
any decision to require hair nets over other means of effective
restraint, would have to be made by the airline company.
SUBJECT: Regulations Pertaining to Commercial Coffee Makers and
Refrigerated Cases for Storage of Ice
BY: LEG
DATE: 3 May 1991
SUMMARY: There are no specific FDA regulations governing these two
types of equipment. It is recommended that: (1) The equipment
conform to the Code Specifications listed in Chapter 4 of the 1976
Food Service Sanitation Manual; and (2) that the equipment be
evaluated by a third party equipment evaluation firm whose function
is to evaluate and list items of equipment conforming to specific
design and construction standards. Examples of such firms include
the National Sanitation Foundation, ETL and others.
SUBJECT: Potentially Hazardous Status of Home Style Garlic Bread
BY: RDB
DATE: 22 April 1991
SUMMARY: The product consists of bread and a garlic spread. It
has been ascertained that the water activity (Aw) of the garlic
spread and the bread are, respectively, 0.880 and 0.915 at 25x C.
No information is provided on the pH of the products. The product
was challenge tested with Staphylococcus aureus. It is suggested
that growth of S. aureus may be suppressed because of the inherent
inhibitory nature of the garlic and the rapidly increasing number
of acidophiles in this sample. It is our opinion that this
specific product is not a potentially hazardous food.
SUBJECT: Refrigeration of Eggs at Retail
BY: ALB
DATE: 16 April 1991
SUMMARY: There is no potentially hazardous foods "list." Shell
eggs now meet the model food codes definition for "potentially
hazardous food" and are, therefore, subject to the codes'
time/temperature requirements. Food shall be obtained from sources
that comply with applicable food safety laws and be received at
retail in conformance with model codes provisions. Regulatory
action against a retail establishment permit holder is very
unlikely where: shell eggs, at the time they are received at
retail, are at or below a refrigeration temperature specified by
law for eggs during their wholesale distribution; eggs are
immediately placed under retail refrigeration and stored to
facilitate air flow around the individual cartons; and the
refrigeration units are sized and being operated so that foods
stored therein are consistently being held at the required 45x or
below.
SUBJECT: Information that FDA plans to revise this interpretation
to mean the ambient temperature of the egg carton will be
considered as the internal product temperature.
BY: ALB
DATE: 16 April 1991
SUMMARY: The model codes and interpretation provisions pertaining
to the temperature of potentially hazardous foods have
traditionally meant and continue to mean internal product
temperature, not ambient temperature. There are no plans to
reissue the 8/22/90 interpretation to exempt shell eggs from this
policy.
SUBJECT: Shell Eggs - Interpretation Issues
BY: ALB
DATE: 16 April 1991
SUMMARY: At retail, shell eggs may be considered out of compliance
where they are received at a temperature above that specified by
the law governing eggs in wholesale distribution, or where they are
held above 45x F for more than four hours. Menu items with a pH
below 4.6 should not be exempted from the Interpretation's
prohibition against their containing raw eggs. The pH control is
relied upon to prevent growth, not to destroy microorganisms. An
infective dose may already be present. With the increased
incidence of foodborne illness due to s.e., pooled eggs are more
likely than an individual egg to contain Salmonella. The
Interpretation provides the egg cooking times recommended by
Cornell University, the American Egg Board, and the Egg Nutrition
Center. Thermocouples meet the intent of model code provisions
which specify "metal stemmed." There is concern that the hot
holding requirements contained in this section of the
Interpretation might also be applied by regulatory officials to
eggs or egg-containing foods intended for cold holding. We do not
believe that public health officials are being confused on this
point, or that they are trying to prevent the products you
mentioned from being stored at proper cold temperatures.
SUBJECT: Sous Vide Process and the Spraying or Misting of Fruit
and Vegetables
BY: Raymond D. Beaulieu
DATE: 27 March 1991
SUMMARY: Concerns are based on various aspects of microbiological
safety relating to foods packaged and stored under vacuum. Letter
of January 13, 1988 to Mr. Robert E. Harrington outlines these
concerns. Letters to Mr. Peter Buss dated January 31 and March 6,
1989 provide current guidelines for reduced oxygen packaging foods
at the retail level with minimal risk of botulinum toxin
development. Formulating a model food protection code
interpretation that will combine into one document information
relating to the safety of reduced oxygen packaging processes.
There are no specific regulations to spraying or misting of
fruits/vegetables. There have been no known problems with fruit
and vegetables that have been sprayed or misted to keep them fresh.
However, a problem did occur a year or so ago that involved an
outbreak of Legionnaires' disease originating from an improperly
maintained fruit and vegetable "fogging" system.
SUBJECT: Use of the Phrase "The information in this program meets
FDA model food protection codes and specifications."
BY: Raymond D. Beaulieu
DATE: 27 March 1991
SUMMARY: We have no objection to this phrasing.
SUBJECT: Double Strength Application of Quaternary Ammonium
Sanitizers
BY: Raymond D. Beaulieu
DATE: 25 March 1991
SUMMARY: Quite clear that sanitizers applied at the strength,
temperature and time specified in the Code are efficacious for all
sanitization applications, including rinsing, spraying or swabbing.
Double strength requirement is not based on known scientific
justification, it is no longer recommended.
SUBJECT: Certain Pumpkin Pies -- Not "PHF"
BY: Raymond D. Beaulieu
DATE: 26 February 1991
SUMMARY: Microbiological stability of the pies is based upon a
consistent compliance to the primary barrier condition of pH. If
this company's pumpkin pies with a uniform pH of less than 4.6 and
have shown this through adequate laboratory analyses and data,
further testing is unnecessary. Regulatory agencies do have the
option to obtain an occasional sample, for pH determination to
verify that the product is maintained in the acceptable pH range.
SUBJECT: Jewelry Permitted for Food Handlers
BY: Raymond D. Beaulieu
DATE: 22 February 1991
SUMMARY: Employees engaged in food preparation and washing
operations shall thoroughly wash their hands. Most jewelry worn on
fingers is viewed as an impediment to the thorough washing of
hands; rings with stones are not easily cleaned and can serve as a
possible contamination source. Settings secured by prongs may
become detached and render food injurious. Only plain rings, such
as a wedding band, are permitted to be worn by food employees while
on duty. No specification prohibiting the use of nail polish in
model codes. Chipped or cracked nail polish hinders washing of
fingers and does establish a basis for a violation of Section 3-
201. Use of artificial nails presents a potential for "hard
foreign objects" getting into food. "Food handler" is defined as
an individual working with unpackaged food, food utensils or food-
contact surfaces."
SUBJECT: Exemption of Hot Detergent Solution Temperature
Requirement in the Manual Cleaning of Drinking Glasses
BY: Raymond D. Beaulieu
DATE: 21 February 1991
SUMMARY: Current FDA policy regarding request is accurately
presented in Memo of November 21, 1983.
SUBJECT: Popcorn Used as Packaging Material
BY: Raymond D. Beaulieu
DATE: 13 February 1991
SUMMARY: FDA policy allows for the use of popcorn as a packing
material, if the popcorn is used in the same manner for packing and
shipping as are the styrofoam peanut chips or other similar
materials. The agency recommends that a package insert or flyer be
placed in the shipping carton clearly stating that the popcorn is
"NOT FIT FOR HUMAN CONSUMPTION." If these criteria are met,
popcorn may be used as a packing and shipping material. Material
considered to have been subject to contamination and may not be
sold or served as food (Section 2-101). Once opened, popcorn
packing material is to be stores and properly disposed to prevent
the harborage and feeding of insects and rodents (Sections 6-602,
6-603, and 6-701). OPINION REVISED AND RESCINDED IN LATER MEMO .
SUBJECT: Disposable Towels Treated with an Anti-microbial Agent
BY: Raymond D. Beaulieu
DATE: 11 February 1991
SUMMARY: The active ingredient in the antimicrobial agent is not
authorized in the Code of Federal Regulations as a food contact
surface sanitizing agent. Product may not be used by itself or in
conjunction with 178.1010 sanitizers on food contact surfaces as
specified in Section 5-102 (a) and (b) of the Food Service
Sanitation Code. No objection to the use of the treated towel on
non-food contact surfaces as specified in Section 5-102 (c) of the
Code.
SUBJECT: Food Warmer Through Exothermic Reaction
BY: Raymond D. Beaulieu
DATE: 1 February 1991
SUMMARY: Design of the pouch provides a functional barrier to the
migration of the components that make up the pouch. Substances
used in the compartment which result in the exothermic reaction are
generally recognized as safe (GRAS). The product can be used in
compliance with the intent (Food Protection, Section 2-201) of
model food protection codes based on its GRAS status and intended
use.
SUBJECT: Serving Carafes of Milk on the Breakfast Bar
BY: Raymond D. Beaulieu
DATE: 31 January 1991
SUMMARY: It is our opinion that potentially hazardous food,
including milk in containers, may be safely displayed and provided
for customer service provided the food is protected from
contamination by container covers, food shields, display cases or
other effective means. Further, the temperature of milk or similar
products must be properly maintained. Finally, there is a need to
remove emptied carafes or other containers of food (milk) to the
washing area for washing, rinsing and sanitizing prior to being
refilled.
SUBJECT: Rosin Baked Potato
BY: Raymond D. Beaulieu
DATE: 31 January 1991
SUMMARY: There is no regulation authorizing the use of rosin as a
medium for cooking potatoes. This represents an unapproved use of
this food additive. Users should be asked to provide evidence that
this use is safe, or that the rosin does not become a component of
the potato. Related issues such as exposure to rosin, how long the
rosin is in continuous use, how heating rosin to 365 degrees F or
184.4 degrees C affects rosin, and what chemical changes, if any,
occur during the heating of rosin and the baking of potatoes in
rosin.
SUBJECT: Determining Whether Foods are Shelf Stable
BY: Raymond D. Beaulieu
DATE: 14 January 1991
SUMMARY: A food having a pH or water activity below specified
levels would be considered non-potentially hazardous or shelf-
stable, at least from the standpoint that pathogens capable of
causing food borne illness would not grow rapidly or progressively.
Specifically, if the pH is 4.6 or below or the water activity is
0.85 or below, the need for continuous time/temperature controls
(45 degrees F or less, or 140 degrees F or above) can be
eliminated.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1990
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Acceptability of Woven Wood Products
BY: RDB
DATE: 12/21/90
SUMMARY: The issue of safe materials has been addressed by the manufacturer
of the resin used in processing this brand of woven wood products. The resin
is sanctioned for use as a food contact surface of molded articles in
accordance with the CFR (21 CFR 177.1460). The samples (platter, plate and
bowls) submitted for evaluation comply with code provisions.
SUBJECT: Self-service of Raw Seafood & Shellfish From Bulk Bins
BY: RDB
DATE: 12/18/90
SUMMARY: The added risk for the spread of pathogens from customer handling
necessitates that no raw meat, raw poultry or raw fishery products be
provided for customer self service. In a PHF self-service operation, the
equipment must be in compliance, product temperatures must be maintained and
oversight responsibilities must be assigned to personnel trained in safe
operating procedures.
SUBJECT: Waiver of Code Provisions For Heat Treatment Dispensing Freezers
BY: ALB
DATE: 12/03/90
SUMMARY: NSF Std #6 on Dispensing Freezers now provides detailed criteria
for heat treatment dispensing freezers. These criteria address the public
health concerns of build-up of residues, growth of pathogens and growth of
undesirable spoilage organisms. Model codes' requirements for cleaning
frequency may be waived for freezers that meet the criteria in Std. #6.
SUBJECT: Is there a standard for the frequency of refiltering fat in a
deep-frying operation? What criteria should be applied to determine the
safety/cleanliness of the fat? Where do you debit if it is determined that
the fat is not safe or clean?
BY: RDB
DATE: 11/26/90
SUMMARY: There is no standard frequency for filtering fat used in a deep-
frying operation. The presence of off-odors or visible evidence of foreign
material, filth or other adulterants should be considered in making a
determination. Item 1 (sound condition) would be debited if it is determined
that the fat contains foreign material or filth. Item 8 is debited if the
fat is not protected from contamination during use, storage or filtering
operations.
SUBJECT: Is fresh fruit (ie., apples, pears, bananas etc.) on a cafeteria
service line required to be individually wrapped?
BY: RDB
DATE: 11/26/90
SUMMARY: No.
SUBJECT: Are backflow prevention devices required on plumbing fixtures in
establishments which use well water or have a private water supply?
BY: RDB
DATE: 11/26/90
SUMMARY: Yes. The potential for contaminating the water supply still exists.
SUBJECT: If a backflow prevention device is installed at the main service
connection, are the fixtures in the establishment required to be protected?
BY: RDB
DATE: 11/26/90
SUMMARY: Yes, providing there is a potential for a cross-connection. The
device at the main service connection protects the public water supply from
contamination arising within the establishment. The water supply within the
establishment must also be protected from potential contamination since
backflow or backsiphonage may occur due to pressure differentials in
the on-premise water system.
SUBJECT: Is it acceptable to display fish and other seafood directly on ice
at the retail level? On paper over the ice?
BY: RDB
DATE: 11/26/90
SUMMARY: Display directly on ice is acceptable providing the ice is from a
potable water source and is continuously drained. The display on paper over
ice is acceptable providing the paper is made from food grade materials and
is clean. The liquid from melting ice shall be continuously drained.
SUBJECT: Would you debit green potatoes under Item 1, sound condition?
BY: RDB
DATE: 11/26/90
SUMMARY: The concern with "green" potatoes has been that such potatoes may
contain solanine, a toxic compound. However, there is no apparent
correlation between the green color of certain potatoes and their solanine
content. The green coloration is likely to be the result of the
photosynthetic process occurring in potato skin which protrudes above the
surface of the soil. Therefore, it would not be advisable to debit such
potatoes under Item 1, Sound Condition.
SUBJECT: Please review options for storing ice cream scoops between use.
BY: RDB
DATE: 11/26/90
SUMMARY: Ice cream scoops can be stored as designated in Section 2-506 of
the model food protection codes. Basically, that provides the following
options:
1. Storage in the ice cream with the handle extending out of the ice
cream container.
2. Stored clean and dry.
3. Stored in a running water dipper well.
SUBJECT: What are concerns relating to European style (open) seafood
display counters and seafood cases open on the service side?
BY: RDB
DATE: 11/26/90
SUMMARY: The primary concern is that of temperature maintenance of the
seafood on display. Other concerns relate to protection from contamination.
Preferably, seafood items would be removed from open displays during the
hours that the business is closed.
SUBJECT: May empty returnable containers be stored in a walk-in cooler
containing packaged food? ....store room containing packaged
food/single service items?
BY: RDB
DATE: 11/26/90
SUMMARY: See answer to next question. Same principles apply. In addition,
floor care becomes a crucial issue since such containers may contain liquid
residues that drip or drain onto floors of the storage area.
SUBJECT: Do we debit baled cardboard in a walk-in freezer?
BY: RDB
DATE: 11/26/90
SUMMARY: Storage of baled cardboard in a walk-in freezer is a practice
that would not be encouraged. However, there exists little public health
concern if such a practice is conducted in a way that potential contamination
of food or food contact surfaces is precluded. It is recommended that a
specific area within the freezer is identified for the storage of baled
cardboard if the practice is to be conducted in a food establishment.
SUBJECT: Bulk water vending machines are becoming popular. Other than what
is already in the model vending code, is there any new information,
directives, etc.?
BY: RDB
DATE: 11/26/90
SUMMARY: Additional information is available in the Listing of Certified
Food and Vending Machines published by the National Automatic Merchandising
Association (NAMA). They are located at 20 N. Wacker Drive, Suite 3500,
Chicago, Illinois 60606. This association also publishes standards for the
design and construction of food and beverage vending machines. The
construction standard includes criteria for water vending machines.
SUBJECT: If a drain in a reach-in refrigeration unit is clogged and the
back-up is causing mold on the bottom shelf of the unit, where is the debit
taken? Plumbing or unclean food contact surfaces?
BY: RDB
DATE: 11/26/90
SUMMARY: Item 22-Unclean food contact surface-is debited. This is an
equipment issue, not a plumbing problem.
SUBJECT: What is the minimum temperature requirement for hot water in a
foodservice establishment?
BY: RDB
DATE: 11/26/90
SUMMARY: The answer to this depends on the hot water uses in the
establishment. Mechanical warewash machines require certain water
temperatures for proper operation. These requirements would dictate the
minimum requirement. There is no minimum requirement at establishments with
manual warewash operations; however, a water temperature that can liquify
fats or grease, preferably 105xF (41xC) or higher, is recommended.
SUBJECT: With the increasing availability of refrigerated processed foods,
how does a sanitarian determine the temperature requirements for reheating
these foods for service?
BY: RDB
DATE: 11/26/90
SUMMARY: In general, commercially processed, fully cooked, refrigerated
foods may be served safely at any temperature for immediate consumption. The
same food intended for reheating and hot holding should be heated to 140xF
(60xC) and held at that temperature. In all instances, the manufacturer's
label instructions should be read and followed (provided temperature
recommendations comply with code specifications).
SUBJECT: What is the minimum water volume required to satisfy the
requirement for storage of dispensing utensils in cool, potable running
water?
BY: RDB
DATE: 11/26/90
SUMMARY: There is no established minimum volume or flow of water to
satisfy this requirement. The volume should be adequate to cover the
utensils' surfaces which contact food. The flow should be sufficient to
remove and flush particulates from the utensil and reservoir.
SUBJECT: What are safe temperatures for cooking and reheating foods in a
microwave oven?
BY: RDB
DATE: 11/26/90
SUMMARY: The model 1982 Retail Food Store Sanitation Code recommends that
pork, when cooked in a microwave oven, be heated to an internal temperature
of 170xF (77xC). This is the only reference to microwave cooking temperature
requirements in the model codes. The proposed Food Protection Unicode
discusses more fully the recommended temperatures for cooking raw animal
products in a microwave oven. In general, raw animal products shall be
cooked to an internal temperature of 25xF (13.9xC) higher than with
conventional methods to compensate for shorter cooking times. The Unicode
further proposes that poultry, poultry products, pork, pork products and
stuffing containing poultry or pork products be cooked by conventional
methods to 165xF (74xC). These potentially hazardous foods reheated in a
microwave oven, should be reheated to a temperature of 25xF (13.9xC) higher
than required under conventional methods, that is, 190xF (88.2xC).
SUBJECT: Can a detergent-sanitizer requiring a potable water rinse be used
as the detergent in the first compartment of a two-step manual warewash
operation?
BY: RDB
DATE: 11/26/90
SUMMARY: Yes. The sanitizer used in the 2nd compartment must be compatible
with the detergent-sanitizer and the sanitizer must be listed in 21 CFR
178.1010. A detergent-sanitizer requiring a potable water rinse could not
be used as the sanitizing agent.
SUBJECT: What is an approved detergent-sanitizer?
BY: RDB
DATE: 11/26/90
SUMMARY: An approved detergent-sanitizer is one in which the sanitizer is
listed in 21 CFR 178.1010. The product must be registered with EPA and
labeled for use as a sanitizer on food contact surfaces. FDA does not list
acceptable detergents.
SUBJECT: Is household bleach acceptable for use as a sanitizer for food
contact surfaces?
BY: RDB
DATE: 11/26/90
SUMMARY: Chemicals that qualify for use as santizers on food contact
surfaces are EPA registered and are labeled with instructions for their use.
Household bleach may contain the same concentration as an institutional
bleach sanitizer but it does not bear the proper labeling and instructions
required of an EPA registered sanitizer.
SUBJECT: Are lead crystal bowls safe to use with acidic foods?
BY: RDB
DATE: 11/26/90
SUMMARY: Under current tolerance levels for leachable lead, these bowls are
safe to use with acidic foods. This issue is under review and a proposal to
lower tolerance levels may result in bowls manufactured under current methods
unacceptable.
SUBJECT: Is it acceptable for cream in stainless steel pitchers to be
removed from the table and re-served later?
BY: RDB
DATE: 11/26/90
SUMMARY: No. This violates Section 2-507 ( PHF shall not be re-served) of
the 1976 Food Service Sanitation Manual.
SUBJECT: Is shellfish from an intra-state licensed plant acceptable for use
in a food service establishment?
BY: RDB
DATE: 11/26/90
SUMMARY: Yes, provided the shellfish are received in non-returnable packages
identified with the name & address of the original shell stock processor,
shucker-packer, or repacker, and the certification number issued by the
state according to law.
SUBJECT: Acceptable Raw, Undercooked or Partially Cooked Eggs
BY: RDB
DATE: 11/26/90
SUMMARY: It is acceptable to cook shell eggs, cracked at the time of the
order, to less than 140xF only if an individual customer specifically
requests raw, partially cooked, or undercooked eggs.
SUBJECT: Natural Cool Air Circulation Systems For Walk-in Refrigerators
BY: R A Duffill
DATE: 11/26/90
SUMMARY: An energy saving concept for suitable climates is not new. An
example is the filtered air standard in Appendix H, Sect. II, page 98, (Air
Under Pressure - Milk & Milk Contact Surfaces) of the Grade "A" PMO 1989
Revision. Guidelines & piping diagrams are contained in the document.
SUBJECT: Bacteriological Requirement for Ingredient Water and Ice
BY: RDB
DATE: 11/19/90
SUMMARY: There are no specified requirements for bacteriological evaluations
of water at the point of use (faucets, coffee makers, etc.). Codes state
water must be from a source constructed, maintained and operated according
to law.
SUBJECT: Family Style Meals -- Head Start
BY: RDB
DATE: 10/26/90
SUMMARY: This may be permitted providing: (1) training on safe food handling
practices and handwashing is given; (20) milk served family style is for only
one sitting; and (3) unused PHF (including milk) and unwrapped non-PHF are
discarded after service to a single group of children.
SUBJECT: Factors in Maintaining a "working supply" of Fresh Eggs
BY: RDB
DATE: 10/22/90
SUMMARY: Factors to be considered: (1) time out of temperature; (2) cooking
temperature; (3) proximity of working supply to heat source; (3) rotation of
supply; (4) amount: and (6) intensity of customer orders. Factors (1) & (2)
are critical. Time of working supply between 45xF & 140xF must not exceed
4 hours. Mark time on supply so that elapsed time is known.
SUBJECT: Pourable Salad Dressings With a pH Below 4.6
BY:RDB
DATE: 10/11/90
SUMMARY: A commercially processed salad dressing that has documented
laboratory evidence indicating that its pH is 4.6 or lower does not need
refrigeration. If mixing with other foods results in a pH above 4.6, the
mixture must be refrigerated if not consumed immediately after preparation.
SUBJECT: Permitted Use of Continuous Cloth Towels
BY: RDB
DATE: 9/17/90
SUMMARY: Properly operating and maintained continuous cloth towel dispensers
which provide successive clean towel segments meet code provisions. If a
loop of soiled towel remains accessible when the roll of clean toweling is
exhausted, this towel segment becomes a common towel and is in violation of
the code.
SUBJECT: Improper Use of Tumblers as to Dispense Pizza Ingredients
BY: CSO
DATE: 8/3/90
SUMMARY: The use of these tumblers results in hands coming in contact with
the ingredients being dispensed during pizza making operations. This
practice is in violation of code provisions which require the use of suitable
dispensing utensils which minimize hand contact with food.
SUBJECT: Scatter Free Fly Traps Exempt From Five Foot Rule
BY: ALB/RDB
DATE: 7/24/90 & 9/17/90
SUMMARY: Fly traps determined by research to be scatter-free may be exempt
from the code requirement that electronic fly traps be installed no closer
than five feet from exposed items.
SUBJECT: Listeria monocytogenes & Lettuce as a PHF
BY: ALB
DATE: 7/19/90
SUMMARY: There is insufficient evidence that uncooked vegetables (except raw
seed sprouts) should be designated as potentially hazardous foods requiring
refrigeration at retail.
SUBJECT: Handwashing Facilities in Produce Sections
BY: RDB
DATE: 7/13/90
SUMMARY: The produce section where fruit & vegetables are cut, trimmed or
washed does meet the intent of Section 6-501 with respect to food preparation
areas.
SUBJECT: Coloring Agent Derived From Annatto & Tumeric
BY: RDB
DATE: 7/11/90
SUMMARY: Annatto is a food color additive and can not be added as a coloring
agent to bread, rolls, and buns. The CFR states that coloring agents are
obtained from spices, spice oil & spice extract.
SUBJECT: Glass Fabric/Silicon Mold as Food Additive
BY: RDB
DATE: 7/9/90
SUMMARY: Upon initial review of test results, specific product appears to
meet CFR requirements. However, this is applicable only if the product meets
composition requirements of the regulations. Additional formulation
information must be submitted.
SUBJECT: Production & Service of Yogurt
BY: R.A. Duffill
DATE: 7/3/90
SUMMARY: Production and service of yogurt in a food establishment is not
recommended for two reasons. (1) The potential for cross-contamination in
a foodservice establishment is greater than in a dairy processing plant
because of the number of foods handled during service and preparation. (2)
Yogurt requires long periods of incubation at temperatures in which pathogens
grow (Section 2-201). During this process when the pH is above 4.6,
pathogenic organisms, such as Listeria and Staphylococcus, may grow. Toxins
produced at this time will remain after the pH has been reduced below 4.6.
SUBJECT: Processing of Wild Game
BY: M.G. Slein/RDB
DATE: 7/2/90
SUMMARY: Processing of wild game for noncommercial consumer uses (not for
retail sale) may be processed provided safeguards are followed. Certain code
provisions such as Sections 2-201 & 5-101 (a) (3) & (d) must be complied with
and the viscera and hide of the animal must be removed and discarded prior
to entering the establishment. The processing of wild game must be done at
the end of normal retail operations.
SUBJECT: Multiple Code Items
BY: RDB
DATE: 5/22/90
SUMMARY: #1. Item NO. 10 applies to "in-use" utensils stored with handles
contacting food.
#2. Item NO. 12 applies to rings other than plain band types.
#3. Nail polish is not prohibited.
#4. Hand towel and/or toilet tissue dispensers are not required.
#5. Water spotting is not a debitable item. If tableware contains food
after washing, it is a violation of Item NO. 22. Item NO. 16 is debited
if there is a maintenance, operational or design problem.
#7. If frozen food has thawed (except for staging/preparation for service),
it is a violation of Item NO. 3.
#8. No interpretation exists on the maximum temperature of tempered water.
#9. Santizers must be properly labeled and meet CFR requirements.
#10. In-use laundry receptacles need not be located out of the kitchen or
storage areas.
SUBJECT: Multiple Code Items
BY: RDB
DATE: 5/5/90
SUMMARY:
#1. Sealed concrete may be used as a floor covering in walk-in
refrigerating units and in food preparation, food storage and utensil
washing areas.
#2. Painted (baked enamel) heavy gauge shelves are not precluded from use
in dry storage areas.
#3. A deli area is a food preparation area. Ceiling requirements may be
relaxed in delis in which there are no cooking, frying or warewashing
operations.
#4. Both mechanical dishwashers and three compartment sinks are not required
in case one becomes inoperable.
SUBJECT: Responsibility For Water
BY: ALB
DATE: 5/8/90
SUMMARY: The water authority (federal and local) has responsibility for the
water supply to the building. The food regulatory authority has
responsibility for the building plumbing and protecting the water used in the
establishment.
SUBJECT: Acceptability of a Non-Sanitizing Glasswashing System
BY: HCC/ALB
DATE: 4/24/90 & 7/19/90
SUMMARY: Glasswashers follow cleaning with a clear water
rinse as a final step. The RFPB has stated that these types of machines must
have a final sanitization step to be in compliance with model codes and state
and local codes.
SUBJECT: Tuna Waiver From Freezing When Eaten Raw
BY: JSB/LRL/HCC/ALB
DATE: 4/9/90, 4/16/90, 4/26/90
SUMMARY: Tuna shall not be exempt from freezing when intended to be eaten
raw. Tuna may have a lower parasitic infection rate, but it is not infection
free. Studies support FDA's position.
SUBJECT: The Need For a 1/4 in. IPS Valve
BY: RDB
DATE: 4/6/90
SUMMARY: IPS valves are needed on dishmachines in which final rinse water
pressure is supplied from the building. This pressure varies and must be
between 15 and 25 lbs/sq in. The IPS valve is not needed on pumped
recirculated rinse machines.
SUBJECT: Reheating Precooked Packaged Processed Food
BY: RDB
DATE: 4/5/90, 4/6/90, 4/6/90, 4/9/90
SUMMARY: 165 degrees F may be waived for precooked, packaged foods obtained
from regulated food manufacturing plants. Rapidly reheat such foods to 140
degrees F.
SUBJECT: Reuse of Pizza Delivery Boxes
BY: RDB
DATE: 3/26/90
SUMMARY: Boxes used by a distribution center to individual stores may be
reused for home delivery providing food protection criteria are met.
SUBJECT: GRAS Meat Tenderizer and Menu Reference
BY: ALB
DATE: 3/9/90
SUMMARY: A meat tenderizer with GRAS ingredients and used properly does not
have to be referenced on the menu.
SUBJECT: Glasswashing System without Sanitizer Step
BY: RDB
DATE: 2/20/90
SUMMARY: This system is a two step detergent wash and fresh water rinse
process. It does not have a sanitizing process and, therefore, does not meet
the provisions of FDA model codes.
SUBJECT: Promotional Material on Hand Sanitizer
BY: RDB
DATE: 2/8/90, see 1/26/90
SUMMARY: The label for this product is misleading (implies that hands do not
have to be washed) and shows and improper installation above an ice bin.
SUBJECT: Low Voltage Fly Killers Placement and Operation
BY: ALB
DATE: 1/30/90, see 1/4/90
SUMMARY: Ongoing studies of these types of insect killers may modify FDA's
recommendations.
SUBJECT: Hand Sanitizers as an Adjunct to Handwashing
BY: ALB
DATE: 1/26/90, see 2/8/90
SUMMARY: They are not food additives if used per label instructions.
These supplement proper handwashing and are used on clean hands.
SUBJECT: Routine Health Exams For Food Handlers
BY: ALB
DATE: 1/24/90
SUMMARY: The USPHS does not recommend routine health testing of food
handlers. It can't be justified on safety, epidemiological or economic
grounds. The WHO has published a review of this issue.
SUBJECT: Pumpkin Pies are PHF
BY: ALB
DATE: 1/17/90
SUMMARY: These pies support the growth of Staphylococcus & Salmonella sp.
See interpretation on 5/6/86.
SUBJECT: Low Voltage Fly Trap With Adhesive Surface Acceptability
BY: ALB
DATE: 1/4/90, see 1/30/90
SUMMARY: The code installation requirement of more than 5 feet to food is
not applicable for fly traps without a voltage charge that could impel dead
insects away from the trap.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1989
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Revision to State Food Regulations
BY: ALB
DATE: 12/27/89
SUMMARY: 2 conflicts with FDA model food codes: acceptance of residential
kitchens & exemption of private clubs.
SUBJECT: Holding Parboiled Potatoes at Room Temperature
BY: LEG
DATE: 12/6/89
SUMMARY: Heat treated vegetables are phf & must be temperature controlled
or discarded. The maximum time maintained in an unsafe temperature zone is
not to exceed four hours.
SUBJECT: Letter to Association on FDA's Role & Code Provisions For Pumpkin
Pies
BY: ALB
DATE: 10/31/89
SUMMARY: Soft pies, unless demonstrated to be non-phf, must be held at 45
degrees F or below. Frozen pies meet this requirement.
SUBJECT: Fish Fillet Sandwich Prep
BY: RDB
DATE: 10/26/89
SUMMARY: The procedure for preparation and cooking of fish fillets meets
code requirements.
SUBJECT: NSF Standard #3 & a 10 Second Chemical Sanitizing Rinse
BY: JJK
DATE: 10/23/89 (2 letters)
SUMMARY: The 10 sec. requirement for the sanitizing rinse applies to new
machines. Older machines are ok if they are operated in accordance with
manufacturer specifications.
SUBJECT: Pumpkin Pies Challenge Tests
BY: TLS
DATE: 10/23/89
SUMMARY: We can't accept tests due to recipe changes & inconsistent data.
No studies to date indicate that these pies are not phf.
SUBJECT: Pumpkin Pies Results of Challenge Tests
BY: TLS
DATE: 10/20/89
SUMMARY: Inoculated pies supported rapid growth. These pies are phf.
SUBJECT: Aseptically Packaged Tofu
BY: TLS
DATE: 10/4/89
SUMMARY: This brand is aseptically packaged and intact packages are shelf
stable. Intact packages are not phf. The brand has an FCE number.
SUBJECT: Shredded or Cut Raw Fruits and Vegetables (Cabbage)
BY: TLS
DATE: 9/26/89
SUMMARY: No reason to change position that these aren't phf (cabbage is an
exception).
SUBJECT: Unrefrigerated Pumpkin Pies
BY: ALB
DATE: 9/18/89 & 9/26/89
SUMMARY: No evidence that pies are not phf. No inoculation after baking.
SUBJECT: Analytical Protocol for Pumpkin Pies
BY: TLS
DATE: 8/28/89
SUMMARY: Suggestions for the challenge microbial tests.
SUBJECT: Frozen Convenience Entrees (blanched or precooked)
BY: RDB
DATE: 8/13/89
SUMMARY: Properly thawed may be heated to 140 degrees F. 2nd heating must
be rapid to 165 degrees F.
SUBJECT: Heat Treatment Dispensing Freezers
BY: ALB
DATE: 8/3/89
SUMMARY: Code provisions may be waived for freezers complying with NSF Std
#6.
SUBJECT: Can Detergent-Sanitizer Product be Used in 1 Step Cleaning &
Sanitizing for Milk Shake Machines?
BY: ALB
DATE: 7/31/89
SUMMARY: No. Codes require at least 2 steps or a continuous process.
Operator may be unclear after reading label.
SUBJECT: Design & Construction of Pizza Screens (Code Req.)
BY: RDB
DATE: 7/27/89
SUMMARY: No definite Code criteria; cast iron is exempt from construction
criteria.
SUBJECT: Hush Puppy Batter is Not a PHF
BY: ALB
DATE: 6/21/89
SUMMARY: Submitted data shows that batter doesn't support growth.
SUBJECT: Questions on Vacuum Pkg
BY: TLS
DATE: 6/13/90
SUMMARY: >38 degrees , Premises temp., Film permeability Non-pathogenic
competing organisms.
SUBJECT: Sale of Pumpkin Pies at Ambient Temperature
BY: ALB
DATE: 5/26/89
SUMMARY: The submitted data does not show that these pies are not phf.
SUBJECT: Reconstitution of Whey Dry Frozen Dessert Mix
BY: ALB
DATE: 5/18/89
SUMMARY: Listed code sections and specified handling procedures.
SUBJECT: Is a Light or Warning Signal for Temperature Adequate?
BY: RDB
DATE: 5/11/89
SUMMARY: A warning light or signal does not meet code requirements of q3
degrees .
SUBJECT: What Does "Facility Mean?
BY: RDB
DATE: 5/11/89
SUMMARY: Facility in 2-303 means a piece of equipment.
SUBJECT: Shellfish Holding Tanks and Unmet Requirements
BY: ALB
DATE: 5/11/89
SUMMARY: Complex public health criteria to be used when approving systems.
SUBJECT: Use of Styrofoam Containers CFC (chlorofluorocarbons)
BY: RDB
DATE: 5/1/89
SUMMARY: FDA approves HCFC-22 as a CFC and substitute for CFC. Styrofoam
is safe material.
SUBJECT: Time/Temperature Control Using Heat Lamps
BY: RDB
DATE: 4/17/89
SUMMARY: Heat lamps can't maintain temperature. Discard food after 4 hours
out of temp.
SUBJECT: Wicker Display Trays and Baskets
BY: RDB
DATE: 3/31/89
SUMMARY: Woven wicker and synthetic wicker do not comply with cleanability
requirements for food contact or non-food contact surfaces.
SUBJECT: Shelf Life
BY: TLS
DATE: 3/6/89
SUMMARY: Shelf life dated from packaging and expressed as "Sell By."
SUBJECT: Safety of Sushi
BY: TLS
DATE: 2/27/89
SUMMARY: Spotting parasites; heating and freezing requirements; marinating
doesn't kill parasites in fish.
SUBJECT: Vacuum Packaging
BY: TLS
DATE: 1/31/89
SUMMARY: Do not allow unless 6 control steps are followed and labeling.
SUBJECT: Contact Time for a Chemical Sanitizing Rinse
BY: RDB
DATE: 1/11/89
SUMMARY: Quoted interpretation stating seconds is required.
SUBJECT: Vacuum Breaker Device at a Utility Sink
BY: RDB
DATE: 1/11/89
SUMMARY: Factors that may contribute to failure.
SUBJECT: Drop-in Cold Plates in Potable Ice Bins
BY:
DATE: 1/3/89
SUMMARY: Relevant code provisions; they are OK if in compliance with code.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1988
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Bread Forms Used for Baking Submarine Sandwich Buns
BY: RDB
DATE: 12/6/88
SUMMARY: Woven material reinforced and coated with silicone, new sample
submitted acceptable.
SUBJECT: Are Ready-to-Use Pie Fillings PHF?
BY: ALB
DATE: 11/28/88
SUMMARY: Subject pie fillings are not phf but other ingredients may be.
SUBJECT: Salmonella and Rendering Plants
BY: RJR
DATE: 11/1/88
SUMMARY: Feed mills use Salmonella free ingredients and poultry producers
use protein free feed.
SUBJECT: Customer Refilling of In-use (Reuse) Cups
BY: RDB
DATE: 9/15/88
SUMMARY: OK provided refilling operations are contamination free; no contact
with activators or nozzles.
SUBJECT: Coins, Currency and Handwashing
BY: ALB
DATE: 8/18/88
SUMMARY: Inks contained antimicrobials but now paper is treated; money not
a fomite.
SUBJECT: Hand Sanitizers Are Not Additives
BY: TLS
DATE: 7/27/88
SUMMARY: If used per label results in minimum exposure to food.
SUBJECT: Decorative Materials Use in Display Cases
BY: RDB
DATE: 7/25/88
SUMMARY: They do not comply with cleanability requirements; may cross-
contaminate.
SUBJECT: Health Concerns of Excessive Sanitizer (Additives)
BY: RDB
DATE: 7/25/88
SUMMARY: Sodium hypochlorite is corrosive and may become a food additive.
SUBJECT: Refrigeration of Shell Eggs (Salmonella)
BY: RDB
DATE: 7/25/88
SUMMARY: It may become necessary to recommend refrigeration.
SUBJECT: Running Water Dipper Wells (Temperature 110 degrees F)
BY: RDB
DATE: 7/25/88
SUMMARY: Critical concern is running water of enough velocity
SUBJECT: Electrocuting Flying Insect Devices
BY: TLS
DATE: 7/19/88
SUMMARY: Can interpretation be enforced in food processing establishments
inspected by FDA.
SUBJECT: Vacuum Packaging (Sous Vide) at Retail Level
BY: TLS
DATE: 7/11/88
SUMMARY: Concerns in anaerobic environments; Violation of Sections 2-101
SUBJECT: Hepatitis A Employees Excluded from Establishment
BY: TLS
DATE: 6/29/88
SUMMARY: Quoted code Sections 3-101 and 10-501
SUBJECT: Recessed Tracks on Wall Panels for Shelving Attachment
BY: CSO
DATE: 6/27/88
SUMMARY: New submission may meet code requirements if properly installed and
maintained.
SUBJECT: Cooking PHF Temperatures
BY: CSO
DATE: 6/17/88
SUMMARY: Provided manufacturer with code temperatures for cooking and
reheating.
SUBJECT: Acceptability of Animals in Food Establishments
BY: CSO
DATE: 5/10/88
SUMMARY: Variances for performing animals depends on many factors.
SUBJECT: Management Training and Certification
BY: RJR
DATE: 5/4/88
SUMMARY: FDA believes in training and third party testing.
SUBJECT: Consumption of Raw or Undercooked Eggs
BY: ALB
DATE: 5/4/88
SUMMARY: Suggest they use an alternative to raw eggs.
SUBJECT: Reconstitution of Dry Non-Dairy Frozen Desserts
BY: RDB
DATE: 4/27/88
SUMMARY: Should not exceed 1 gallon for chilling, also prechill ingredients.
SUBJECT: Recessed Tracks on Wall Panels for Shelving Attachment
BY: CSO
DATE: 4/4/88
SUMMARY: Does not conform with requirements in the model codes.
SUBJECT: Review of Smoker Oven
BY: TLS
DATE: 3/29/88
SUMMARY: Directions not in conformance with acceptable food safety
principles.
SUBJECT: Association Request for Packaged Ice Code
BY: ALB
DATE: 3/29/88
SUMMARY: Motivation is not related to public health; another code is
unnecessary, though may modify existing codes if needed.
SUBJECT: Time with Temperature as Public Health Control
BY: ALB
DATE: 3/25/88
SUMMARY: Letter to Association stating time as a public
health control - responsive to needs, consistent with public health
principles and relatively simple.
SUBJECT: Review of Decision to Lock Doors Below Salad Bar
BY: RDB
DATE: 3/23/88
SUMMARY: Alternatives to precluding storage beneath the salad bar.
SUBJECT: Evaluation of An Insect Electrocution System
BY: TLS
DATE: 3/22/88
SUMMARY: Five issues of concern - won't modify interpretation without
evidence.
SUBJECT: Self-Service Refilling of Glasses or Cups
BY: RDB
DATE: 3/21/88
SUMMARY: Not acceptable if lip surface contact trip lever. Only
contamination free process can be used. Code addresses contamination for
control of process.
SUBJECT: Chemical Sanitization
BY: RDB
DATE: 3/17/88
SUMMARY: Recommended changes NSF Standard #3 (5 log kill and table with
variables).
SUBJECT: Silicon Bread Forms
BY: RDB
DATE: 3/15/88
SUMMARY: Requests local evaluation of a bread forms in-use to determine
durability.
SUBJECT: Management Training and Certification
BY: ALB
DATE: 3/9/88
SUMMARY: Letter to organization on FDA position.
SUBJECT: Plastic Wraps and Containers when Cooking in Microwave Ovens
BY: TLS
DATE: 3/3/88
SUMMARY: Food contact surfaces must be of safe materials, interpretation
doesn't deal with microwave use of these containers.
SUBJECT: Air Curtains (Controlled Air Currents)
BY: RDB
DATE: 2/9/88
SUMMARY: Air currents are effective in minimizing entrance of flying
insects.
SUBJECT: Single-use Perforated
BY: RDB
DATE: 1/20/88
SUMMARY: Bags meet intent of model codes for the packaging of hard crust
bread and rolls.
SUBJECT: Reconstitution of Dry Milk Products for Drinking Purposes
BY: RDB
DATE: 1/20/88
SUMMARY: Recommend against reconstitution of milk products except as
permitted in model codes.
SUBJECT: Vacuum Packaging Systems (Sous Vide)
BY: TLS
DATE: 1/13/88
SUMMARY: System is contrary to existing code provisions and not acceptable
in this country.
SUBJECT: Fly Paper or Glue Fly Traps
BY: RDB
DATE: 1/11/88
SUMMARY: Products can be used provided that they are not located over food
or food contact surfaces nor in a manner that permits employees to
accidentally contact product during their routine activities.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1987
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Chain's New Food Bar - Review
BY: RDB
DATE: 12/3/87
SUMMARY: Food bar construction does not meet requirements of model code.
SUBJECT: Proposed "Time/Temperature" Guidelines for Cooling Heated
Products
BY: TLS
DATE: 12/2/87
SUMMARY: Specific comments of questions are noted in opinion;
concern over the use of the word "adulteration."
SUBJECT: Plastic Flatware and Food Service Tray
BY: CSO
DATE: 11/27/87
SUMMARY: Products appear to meet design and construction
requirements of model code.
SUBJECT: Electrocuting Flying Insects Interpretation
BY: TLS
DATE: 10/30/87
SUMMARY: Clarification given to a paragraph in interpretation.
SUBJECT: Chicken Salad and Tuna Salad - Handling
BY: RDB
DATE: 10/18/87
SUMMARY: Portions must be under constant refrigeration.
SUBJECT: Meringue Topped Creme Pies - Refrigeration
BY: TLS
DATE: 10/5/87
SUMMARY: Cannot make blanket statement regarding refrigeration
because of the many varieties.
SUBJECT: Airline Meals for Use in Charitable Feeding Programs
BY: DJS
DATE: 10/5/87
SUMMARY: Would support initiative if temperature control could be
assured.
SUBJECT: Plastic Draining Board for Drying/Storing of Bar Glasses
BY: RDB
DATE: 9/25/87
SUMMARY: Materials and construction appear to be acceptable for
intended use and product is easily cleanable.
SUBJECT: Bread Wrap and Perforated Bread Bags
BY: RDB
DATE: 9/21/87
SUMMARY: Products appear to meet intent of Section 2-503 of model
code and "Bulk Food" Interpretation for protection from
contamination during display.
SUBJECT: Ham and Cheese Croissants
BY: RDB
DATE: 9/3/87
SUMMARY: Consider product to be potentially hazardous and must be
maintained at safe temperature specified in codes.
SUBJECT: Silicone Bread Forms
BY: RDB
DATE: 8/31/87
SUMMARY: Bread form is not considered an acceptable food contact
surface since it does not comply with criteria for easily cleanable
design and construction.
SUBJECT: Hand Sanitizing Lotion
BY: RDB
DATE: 8/26/87
SUMMARY: Label contains no information relative to components
formulating the product.
SUBJECT: Videotapes on Sanitation and Hygiene - Review
BY: TLS
DATE: 7/23/87
SUMMARY: Generally programs were well done, concentrating on
important issues and portraying sanitation problems accurately.
SUBJECT: Tempering of Butter
BY: ALB
DATE: 7/23/87
SUMMARY: If detailed controls on source and time are proposed,
regulatory jurisdictions could waive temperature requirements for
tempering of butter.
SUBJECT: French Fry Slacking Procedure
BY: ALB
DATE: 7/23/87
SUMMARY: Protocol should include use of B. cereus spores which
have been heat shocked.
SUBJECT: Labs Standards for Food Service Equipment
BY: ALB
DATE: 6/25/87
SUMMARY: Equipment standards in model codes. FDA does not
evaluate for accreditation.
SUBJECT: Fresh Fish in Shrink Wrap Packaging
BY: RDB
DATE: 5/29/87
SUMMARY: Certain vacuum packed products permit development of
toxin before spoilage of product.
SUBJECT: Paper Thermometers for Evaluating Low Temperature
Dishwashers
BY: RDB
DATE: 5/28/87
SUMMARY: Use indicating thermometer to check temperature of
solutions in dishwasher tanks or affix paper thermometer to rinse
line at point of entry into machine.
SUBJECT: Plastic Bulk Food Bins
BY: RDB
DATE: 5/28/87
SUMMARY: Product does not meet intent of "Bulk Food"
Interpretation with regard to lid height above the floor.
SUBJECT: French Fry Tempering Procedure
BY: ALB
DATE: 5/27/87
SUMMARY: Cannot assure that french fried potatoes are not
potentially hazardous.
SUBJECT: Air Temperature of Cabinets and Internal Product
Temperature of Foods Stored in Refrigerators
BY: RDB
DATE: 5/26/87
SUMMARY: Codes presently only require maintenance of product
temperature at 45 degrees F or less.
SUBJECT: Frozen Convenience Entrees - Reheating
BY: RDB
DATE: 5/26/87
SUMMARY: Reheating temperature of 140 degrees is adequate.
SUBJECT: Paper Thermometers for Evaluating Low Temperature
Dishwashers
BY: RDB
DATE: 5/19/87
SUMMARY: +3 degrees Standard for accuracy is considered
acceptable.
SUBJECT: Plastic Bread Forms for Submarine Sandwich Buns
BY: WPW
DATE: 5/15/87
SUMMARY: Plastic bread forms do not meet intent of Section 4-
201(a) of model code; screen openings are not conducive for
cleaning.
SUBJECT: Hand Sanitizers
BY: TLS
DATE: 3/15/87
SUMMARY: Have no objection to these chemical in a hand sanitizer
product.
SUBJECT: Isolation Procedures for Food Service
BY: WPW
DATE: 4/7/87
SUMMARY: FDA supports policy of complete usage of disposable food
service items (single service articles).
SUBJECT: Label Use Instructions for Cooked Shrimp
BY: WPW
DATE: 4/1/87
SUMMARY: Label use thawing instructions should be revised to
comply with model codes.
SUBJECT: Self-Service Donuts
BY: RDB
DATE: 3/27/87
SUMMARY: Display unit in question is not suitable for this type
of self-service operation.
SUBJECT: Serving Potentially Hazardous Food from Food Carts
BY: RDB
DATE: 3/24/87
SUMMARY: Operations of cart must comply with all applicable FSSO
items and carts design must follow criteria of NSF Standard No. 59.
SUBJECT: Ozone Generating Device
BY: WPW
DATE: 3/5/87
SUMMARY: Can only use ozone on food in manner provided by the
regulation 21 CFR 184.1563.
SUBJECT: Tofu - Refrigeration
BY: WPW
DATE: 3/3/87
SUMMARY: Temperature requirements depend upon whether the tofu is
considered a potentially hazardous food.
SUBJECT: Tofu
BY: WPW
DATE: 2/13/87
SUMMARY: Any moist soy protein products, including tofu, are to
be considered potentially hazardous, if they meet phf definition, and must
follow the corresponding temperature requirements.
SUBJECT: Rehydrated Dried Onions
BY: WPW
DATE: 2/12/87
SUMMARY: Rehydrated dried onions should be treated as potentially
hazardous.
SUBJECT: Plastic Utensils
BY: WPW
DATE: 2/5/87
SUMMARY: Should review alternatives for design/fabrication of
cover in order to meet intent of cleanability.
SUBJECT: Roach Control Product
BY: LC
DATE: 2/5/87
SUMMARY: If product does not have EPA regulatory number but makes
no claims for roach control, FDA sees no health risk associated
with use of product.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1986
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Self-Service of Potentially Hazardous Food
BY: WPW
DATE: 12/30/86
SUMMARY: "Sleeve box" did not meet requirements for plastics for
design/fabrication.
SUBJECT: Plastic Reusable Flatware and Drinkware
BY: WPW
DATE: 12/8/86
SUMMARY: Samples of utensils are acceptable according to model codes.
SUBJECT: Covering Foods Stored on Trays
BY: RDB
DATE: 12/5/86
SUMMARY: Food may be stored uncovered on trays that are supported
from their edges, or placed on solid shelves of enclosed reach-in
refrigeration or hot holding equipment.
SUBJECT: Food Bags
BY: WPW
DATE: 12/4/86
SUMMARY: Not assured that use of product will offer necessary
protection from the ubiquitous fly.
SUBJECT: "Tandoor" Oven
BY: WPW
DATE: 11/14/86
SUMMARY: Clay oven interior is not acceptable as a food contact
surface.
SUBJECT: Frozen Egg Rolls - Thawing
BY: WPW
DATE: 10/27/86
SUMMARY: Thawing of potentially hazardous food at room temperature
is not an acceptable option.
SUBJECT: Single Use Plastic Perforated Bag
BY: WPW
DATE: 10/21/86
SUMMARY: Consider sample bag to be acceptable with model code criteria.
SUBJECT: Roach Control in Mop Water Solution
BY: WPW
DATE: 10/14/86
SUMMARY: If product is used in accordance with instructions, it
should be considered an acceptable ingredient for mop water.
SUBJECT: Self-Service Beverage Vending Unit
BY: RDB
DATE: 10/9/86
SUMMARY: Appears well designed from food protection and operation
standpoint.
SUBJECT: Proposed Live Shellfish and Live Lobster Holding Systems
BY: WPW
DATE: 10/2/86
SUMMARY: Tank prefilter may not be of easy, cleanable multi-use
construction; question as to whether prefilter is designed for
single use and is made from non-toxic materials.
SUBJECT: "Pizza Serving Screen"
BY: WPW
DATE: 9/23/86
SUMMARY: Does not meet requirements of model codes for
cleanability and imperfections.
SUBJECT: Skim Milk Powder in Fortification of Milk Beverages
BY: WPW
DATE: 9/22/86
SUMMARY: Leads to an unnecessary potential for contamination.
SUBJECT: Manual Cleaning and Sanitizing Food Contact Surfaces of
Food Equipment
BY: WPW
DATE: 9/17/86
SUMMARY: Meets intent of Section 5-103 of model code for fixed
food contact surfaces of equipment.
SUBJECT: Pumpkin Pies - Storage
BY: WPW
DATE: 9/16/86
SUMMARY: Considered a potentially hazardous food product which
must follow guidelines of model codes.
SUBJECT: Floor in Temporary Food Service Operations
BY: WPW
DATE: 9/3/86
SUMMARY: Setting up temporary food service operations on grass
without dust control measures does not meet intent of Section 9-
110 of code.
SUBJECT: Molluscan Shellfish Spray Tank Life Support Systems
BY: WPW
DATE: 8/26/86 & 7/25/86
SUMMARY: Can be safely used for display of molluscan shellfish in
retail food stores.
SUBJECT: Quaternary Ammonia Sanitizer
BY: WPW
DATE: 8/1/86
SUMMARY: Reviewed product never intended to be used on food service
utensils or food contact surfaces of equipment.
SUBJECT: Wood Burning Pizza Oven
BY: WPW
DATE: 7/31/86
SUMMARY: Would appear that only acceptable use of oven would be
cooking food in closed containers.
SUBJECT: Sample Sleeve Box for Frozen Foods
BY: WPW
DATE: 7/31/86
SUMMARY: Product does not meet intent of equipment construction
(design and fabrication) criteria of model code.
SUBJECT: Lobster and Clam Life Support System
BY: WPW
DATE: 7/28/86
SUMMARY: Cannot accept use of life support system where live
molluscan shellfish are mixed with crustacea or fin fish in same
tank or in common water system.
SUBJECT: Glasswasher
BY: RDB
DATE: 7/25/86
SUMMARY: Could be evaluated under NSF criteria C-2 for "Special
Equipment and/or Devices."
SUBJECT: Nacho Cheese
BY: TLS
DATE: 7/23/86
SUMMARY: Potentially hazardous once the can is open.
SUBJECT: Cheese Danish Pastry as Non-Potentially Hazardous
BY: WPW
DATE: 7/10/86 & 4/24/81
SUMMARY: Procedures used provide significant protection of food from
contamination.
SUBJECT: Plastics Cushion Tile Floor Mat
BY: WPW
DATE: 7/9/86
SUMMARY: Floor mat will meet intent of Section 7-105 Mats and
Duckboards of model codes.
SUBJECT: "Freshly Prepared Soup Procedures"
BY: WPW
DATE: 7/1/86
SUMMARY: Suggest that "Cleaning Procedure" indicate that all
utensils/equipment used must be washed, rinsed, and sanitized
between uses.
SUBJECT: Heat Treatment System in Dispensing Freezers
BY: RDB
DATE: 6/26/86
SUMMARY: Suggest testing equipment according to draft protocol
with one further swab sample.
SUBJECT: Probe Type Identification Tags
BY: WPW
DATE: 6/24/86
SUMMARY: Recommend that an alternate food sales identification
system be used.
SUBJECT: Proposed for Drain Line Connection for
Undercounter Dishmachine Models
BY: WPW
DATE: 6/11/86
SUMMARY: Appears that product would not be acceptable with intent
of Section 6-306 Drains of model codes; reason: siphon could be
potentially created in dishmachine drainline.
SUBJECT: Vertical Dough Mixer
BY: WPW
DATE: 6/9/86
SUMMARY: Mixer is not of design and fabrication that will permit
easy cleaning.
SUBJECT: Molluscan Shellfish Life Support Tank Spray System
BY: WPW
DATE: 6/9/86 & 6/10/86
SUMMARY: Can be safely used for display of molluscan shellfish in
retail food stores.
SUBJECT: Grill to Hold Drained Bacon
BY: WPW
DATE: 4/28/86
SUMMARY: Found not to comply with Section 4-201 of model code;
grid was not easily cleanable.
SUBJECT: Foreign Made Retail Market Hot/Cold Display Case
BY: WPW
DATE: 4/28/86
SUMMARY: Found not to comply with Section 4-201 of model code.
SUBJECT: Reconstitution Directions for Sandwich Filling for a Spinach
Vegetable Sandwich
BY: WPW
DATE: 4/25/86
SUMMARY: Instructions for safe cooking meet intent of Section 2-
201, 2-303, and 2-403 of model codes.
SUBJECT: Manual for Hot Soups and the Manual for Frozen Soups
BY: WPW
DATE: 4/14/86 & 3/26/86
SUMMARY: Pamphlet found to be acceptable with provisions of model
codes.
SUBJECT: Grid to Hold Bacon on the Grill
BY: WPW
DATE: 4/7/86
SUMMARY: Grid meets intent of Section 4-201 of model codes as to
design and fabrication for ease of cleanability.
SUBJECT: Molluscan Shellfish Life Support System
BY: ALB
DATE: 4/21/86
SUMMARY: System considered to be acceptable for use with molluscan
shellfish in retail food store contingent upon proper installation,
maintenance, and routine cleaning.
SUBJECT: Non Grade A Non-Fat Milk - Reconstitution
BY: WPW
DATE: 3/20/86
SUMMARY: Only source that could reconstitute process would one in
compliance with state milk program requirements.
SUBJECT: Oxine Sanitizer
BY: WPW
DATE: 3/25/86
SUMMARY: Use restriction was placed on sanitizer
SUBJECT: Fabricated Egg With Real Egg Shell
BY: RDB
DATE: 3/19/86
SUMMARY: Product is safely processed
SUBJECT: Mock Mayonnaise - Preparation Procedures
BY: WPW
DATE: 2/19/86
SUMMARY: No need to expose product to heat treatment before final
whipping, but instructions must follow time/temp. criteria.
SUBJECT: Centrifuge Egg Breaking Machine
BY: RDB
DATE: 3/6/86
SUMMARY: Because of potential contamination, product cannot be
recommended for evaluation and possible listing.
SUBJECT: Reuse of Plastic Containers
BY: WPW
DATE: 3/6/86
SUMMARY: "Single-use containers" cannot be recommended for reuse
with other foods.
SUBJECT: Videotape on Seafood - Review
BY: ALB
DATE: 3/5/86
SUMMARY: Feel video is an effective approach to meeting training
needs in fishery products area.
SUBJECT: Pre-Cooked Beef Procedures
BY: WPW
DATE: 2/24/86 & 8/12/85
SUMMARY: Both old and new procedures provide & sufficient public
health controls.
SUBJECT: Wild Game Meat
BY: WPW
DATE: 2/11/86 * 10/27/80
SUMMARY: Not considered an acceptable practice under model codes.
SUBJECT: Hot Dogs
BY: WPW
DATE: 2/14/86
SUMMARY: Could be safely served at any temperature on initial
reheating if served immediately.
SUBJECT: Acceptable Inspection/Slaughtering/Processing of Buffalo
BY: WPW
DATE: 1/22/86
SUMMARY: Must follow USDA/FISIS rule for voluntary inspection of
buffalo from a ranch.
SUBJECT: Hamburger Patty Staging Platform
BY: WPW
DATE: 1/17/86
SUMMARY: Does not comply with Section 4-201a of model codes.
SUBJECT: Floor Cleaning Compounds
BY: RDB
DATE: 1/14/86
SUMMARY: Suggest that standard surface, standard soil, and the
procedure for testing soil removal should represent floor cleaning
conditions and operations in establishments.
SUBJECT: Program Materials - Review
BY: ALB
DATE: 1/10/86
SUMMARY: Feel materials cover important food protection and
sanitation issues.
SUBJECT: Storage of Stemware Over a Wet Bar
BY: WPW
DATE: 1/9/86
SUMMARY: Conditions noted violate Section 5-202(a) of model code.
SUBJECT: Packaged Pre-Cooked Meat and Cheese Sandwiches - Storage
BY: ALB
DATE: 1/6/86
SUMMARY: Individually wrapped sandwiches that have been properly
prepared and maintained at refrigeration temperature can be safely
eaten cold and will also be safe if consumed as soon as reheated.
SUBJECT: Revised Standards for Ice Industry - Review
BY: RDB
DATE: 1/2/86
SUMMARY: Comments follow of proposed standards.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1985
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Acceptable Condiment Containers for Table Service
BY: William P. Wollschlager
DATE: 12/18/85
SUMMARY: When two or more people are eating at one table the term
"individually portioned" could be extended to table as a single
unit.
SUBJECT: Insect Contaminated Food - Inspection Report Violations
BY: William P. Wollschlager
DATE: 12/18/85
SUMMARY: 1. Large amount of food contaminated and same type of insects, ie
grain beetles, found elsewhere - not appropriate to mark item 35 - mark item
01 for adulteration. 2. Fruit flies, mark as item 35 since they have
capability of being potential vector. 3. Insect contamination of non-human
food such as dog food - mark as item 1 -only if- it is established that it is
an imminent threat of potential adulteration of human foods stored in
immediate vicinity.
SUBJECT: Galvanized Surfaces in Establishments
BY: William P. Wollschlager
DATE: 12/17/85
SUMMARY: Acceptability is based on 10/9/65 memorandum.
SUBJECT: Self-Service of Potentially Hazardous Food (Salad Bars)
BY: Arthur L. Banks
DATE: 12/16/85 & 11/15/85
SUMMARY: Must be assured of food's safety both during preparation
and while display
SUBJECT: Unrefrigerated Cheese Croissants
BY: Raymond D. Beaulieu
DATE: 12/16/85
SUMMARY: Must be assured that product has a pH of 4.6 or less and
that such a pH can be maintained.
SUBJECT: Butcher Twine, Cord or Cheese Cloth
BY: William P. Wollschlager
DATE: 12/16/85
SUMMARY: If a material is made from virgin cotton and free from
any toxic additives it is acceptable for food contact in cooking
turkeys.
SUBJECT: Honey and Peanut Butter - Self Service
BY: William P. Wollschlager
DATE: 12/6/85
SUMMARY: Customers cannot bring in their own containers for self-
service of honey and peanut butter,
SUBJECT: Self-service of Potentially Hazardous Foods in Retail
Establishments (Salad Bars)
BY: Arthur L. Banks
DATE: 11/25/85
SUMMARY: Prohibition against customer self-service of these foods
may be waived under certain circumstances.
SUBJECT: Transfer of Illness Through Employee Health Practices
BY: Arthur L. Banks
DATE: 11/21/85
SUMMARY: Employee personal cleanliness and hygienic practices are
important in reducing possibility of transmitting diseases.
SUBJECT: Deli Wheel Cheese
BY: William P. Wollschlager
DATE: 11/7/85 & 7/25/85
SUMMARY: Will not be public health hazard from display of cubes of
product at temperature above 45 degrees F.
SUBJECT: Colored Lights to Enhance Product Appearance
BY: William P. Wollschlager
DATE: 11/6/85
SUMMARY: Model code requirements not intended for use in
regulating economic fraud.
SUBJECT: Coins and Currency as Potential Fomites
BY: Thomas L. Schwarz & Raymond D. Beaulieu
DATE: 11/5/85 & 3/26/80
SUMMARY: Not necessary for employees to wash their hands each time
they "handle money".
SUBJECT: Shellfish Display Tank System
BY: William P. Wollschlager
DATE: 11/4/85
SUMMARY: Brand should not be accepted for display of live
molluscan shellfish.
SUBJECT: Army Food Service and Sanitation Requirements
BY: William P. Wollschlager
DATE: 11/4/85
SUMMARY: Substantially equivalent to model code requirements.
SUBJECT: Plastic Coated Wall Panels
BY: William P. Wollschlager
DATE: 11/1/85
SUMMARY: Meets intent of Section 7-202 of model code.
SUBJECT: Line Cleaner
BY: Raymond D. Beaulieu
DATE: 11/1/85
SUMMARY: Suggestions made on label use instructions.
SUBJECT: Handwashing Sinks in Proximity to Equipment Washing Sinks
BY: William P. Wollschlager
DATE: 10/31/85
SUMMARY: Possible to install handwashing sinks adjacent to
equipment/utensil washing sink if easily cleanable.
SUBJECT: Buttons on Garments Worn by Employees
BY: William P. Wollschlager
DATE: 10/21/85
SUMMARY: No specific intent in codes or CFR to restrict use of
buttons on garments worn by employees.
SUBJECT: Dried Fruit Containing Sulfites - Labeling
BY: Darrell J. Schwalm
DATE: 10/18/85
SUMMARY: Product must contain some type of label which includes
list of ingredients and declaration of artificial color or flavor
and chemical preservative contained in product.
SUBJECT: Salad Bars in Fruit/Vegetable Markets and Large
Supermarkets
BY: Arthur L. Banks & William P. Wollschlager
DATE: 10/17/85 & 12/28/83
SUMMARY: If FDA recommendations are adopted by authorities, self-
service bulk foods and salad bars can be safely provided.
SUBJECT: Rinse Aids
BY: Raymond D. Beaulieu
DATE: 10/9/85
SUMMARY: Use of surfactant or defoamer as a rinse aid, without a
follow-up potable rinse, could be construed to constitute use
either as a direct or indirect food additive.
SUBJECT: Chain's Operations Manual - Review
BY: William P. Wollschlager
DATE: 10/8/85
SUMMARY: Sections appear to be positive approaches to operate
units in a sanitary manner.
SUBJECT: Push Cart Slide Series - Review
BY: Raymond D. Beaulieu
DATE: 10/3/85
SUMMARY: Example could be modified or expanded considerably.
SUBJECT: Self-Service Soup Bars
BY: Arthur L. Banks & William P. Wollschlager
DATE: 8/12/85 & 4/15/85
SUMMARY: Believe prohibition against customer self-service of
potentially hazardous foods may be waived under certain
circumstances.
SUBJECT: Wooden Duckboards in Walk-In Refrigerators
BY: William P. Wollschlager
DATE: 8/7/85
SUMMARY: Practice of storing food directly on wooden duckboards in
walk-ins violates Sections 2-301(b) and 7-105 of model code.
SUBJECT: Pumpkin Pie
BY: William P. Wollschlager
DATE: 9/20/85
SUMMARY: Meets intent of model codes if properly observed.
SUBJECT: Sushi Rice - Storage Temperature
BY: William P. Wollschlager
DATE: 7/31/85
SUMMARY: No longer than three hours at room temperature, unless
data is seen to the contrary.
SUBJECT: Food Service Operations in Remote Locations
BY: William P. Wollschlager
DATE: 7/25/85
SUMMARY: Model temporary food services standards are not
applicable to these operations.
SUBJECT: Management Training and Certification
BY: Arthur L. Banks
DATE: 7/24/85
SUMMARY: Judgement about which training materials to use are best
made locally,
SUBJECT: Wooden Pallets for Storing Packaged Food Commodities
BY: Arthur L. Banks
DATE: 7/16/85
SUMMARY: Pallets used in these applications would have to be
constructed of non-absorbent material or be suitably covered to
render them non-absorbent and cleanable.
SUBJECT: Epoxy Flooring Systems
BY: Raymond D. Beaulieu
DATE: 7/16/85
SUMMARY: Have no objection to use of product for formulating
flooring compounds.
SUBJECT: Probe Type Price Marker
BY: William P. Wollschlager
DATE: 7/9/85
SUMMARY: Does not comply with Section 4-201a of model code for
cleanability of food contact surfaces.
SUBJECT: Aluminum as Food Contact Surface
BY: William P. Wollschlager
DATE: 7/9/85
SUMMARY: There are limitations in use of aluminum for food contact
surfaces.
SUBJECT: Beverage Line Sanitizer System
BY: William P. Wollschlager
DATE: 6/26/85
SUMMARY: Complies with material, design and fabrication criteria
in Section 4-101, 4-104, and 4-201 of code.
SUBJECT: Ladles
BY: William P. Wollschlager
DATE: 6/26/85
SUMMARY: Particular product not in compliance with Section
4-201(a) of model code for cleanability.
SUBJECT: Egg Extraction Machine [NOTE: See Eggs as a PHF Interpretation for
latest information on pooling of eggs]
BY: William P. Wollschlager
DATE: 6/24/85
SUMMARY: Subject machine found to be designed and constructed to be easily
cleanable. Updated operating instructions needed. USDA Grade B, A and AA
eggs are washed and sanitized. Eggs must be clean, whole with shells intact
without cracks or checks.
SUBJECT: Food Price Tag System
BY: William P. Wollschlager
DATE: 6/20/85
SUMMARY: Although plastic price supports comply with model code,
advertising for product implies FDA "approval" which is not
acceptable.
SUBJECT: Pre-Cooked Beef Procedures - Review
BY: William P. Wollschlager
DATE: 6/17/85 & 8/12/85
SUMMARY: Procedures provide clarity from public health standpoint.
SUBJECT: Certification Training Project
BY: Arthur L. Banks
DATE: 6/11/85
SUMMARY: Materials were consistent with provisions of model code.
SUBJECT: Plastics/Polymers
BY: Raymond D. Beaulieu
DATE: 5/28/85
SUMMARY: Appears that migration is not a problem when using food
grade polymers; rather, problems relate more to improper use of
non-food grade plastics.
SUBJECT: Hot Nacho Cheese Dispensing
BY: William P. Wollschlager
DATE: 5/21/85
SUMMARY: Use of this reviewed system will not result in a
significant microbiological problem.
SUBJECT: Egg Wash Procedure - Review
BY: William P. Wollschlager
DATE: 5/21/85
SUMMARY: System considered to comply with applicable provisions of
model code.
SUBJECT: Salad Bar Research and Development
BY: Arthur L. Banks
DATE: 5/20/85
SUMMARY: List of available information was provided.
SUBJECT: Ceramic Glazed Dinnerware
BY: Ray Duffill
DATE: 5/7/85
SUMMARY: Sample dinnerware was found to be acceptable with regard
to construction, durability and cleanability as a food contact
surface.
SUBJECT: Training Guidelines for Safe Food Handling in Hotels,
Restaurants and Similar Establishments - Review
BY: DJS
DATE: 5/2/85
SUMMARY: Found document to be well formatted and comprehensive.
SUBJECT: Plastic Bags
BY: Raymond D. Beaulieu
DATE: 4/29/85
SUMMARY: Bread wrap reviewed considered acceptable under Section
2-503 of model code.
SUBJECT: Egg Wash Procedure - Review
BY: William P. Wollschlager
DATE: 4/24/85
SUMMARY: If time/temp. criteria is followed closely, there may not
be significant opportunity for rapid bacterial growth.
SUBJECT: Roast Beef Handling and Heating Methods - Review
BY: William P. Wollschlager
DATE: 4/11/85
SUMMARY: Instructions should be revised so as to provide user with
safe temperature guidelines in reheating of full roasts.
SUBJECT: Aluminum Cast Alloy Pizza Pan
BY: William P. Wollschlager
DATE: 4/5/85
SUMMARY: Pizza utensil would not present a public health hazard.
SUBJECT: Procedure for Cleaning and Sanitizing - Review
BY: William P. Wollschlager
DATE: 4/5/85
SUMMARY: Procedure complies with Section 5-103 of model code,
however, use of two compartment bucket for demountable parts of
slicer does not comply with Section 5-103 of model code.
SUBJECT: Dispensing of Sour Cream Via Portion Gun
BY: William P. Wollschlager
DATE: 4/5/85
SUMMARY: As long as pH is below 4.6 sour cream may be dispensed by
gun.
SUBJECT: Reconstituted Dry Mixes in Soft Serve Ice Cream Machines
BY: William P. Wollschlager
DATE: 4/2/85
SUMMARY: Reconstitution in clean and sanitized utensils and rapid
cooling should preclude growth of organisms.
SUBJECT: NSF Standard 26 (Pot, Pan and Utensil Washer) - Review
BY: Raymond D. Beaulieu
DATE: 3/27/85
SUMMARY: Have no significant changes to add.
SUBJECT: Difference Between Cooking Beef Brisket and Beef Roasts
BY: William P. Wollschlager
DATE: 3/27/85
SUMMARY: Beef brisket should not be compared to rare roast beef in
cooking procedures.
SUBJECT: Color Designs on Single Service Articles - Safety
BY: William P. Wollschlager
DATE: 3/22/85
SUMMARY: Plastic coating must be applied to prevent leaching of
ink.
SUBJECT: ASTM Standard for Food Service Equipment Hoods - Review
BY: Raymond D. Beaulieu
DATE: 3/19/85
SUMMARY: New Section 10 of proposed standard resolves initial
negative response to earlier revision of document.
SUBJECT: Beverage Dispensing System
BY: L. Robert Lake
DATE: 2/27/85
SUMMARY: Complies with code provisions.
SUBJECT: Hot Water Sanitization at 160 degrees F
BY: William P. Wollschlager
DATE: 2/25/85
SUMMARY: Reading of at least 160 degrees F or a color change in
thermopaper should be acceptable for sanitization of utensils.
SUBJECT: Handling of Food Minimized
BY: William P. Wollschlager
DATE: 2/22/85
SUMMARY: Food may be considered to be "excessively handled" if
manual handling of food occurs when there is a practical method to
minimize contact.
SUBJECT: Self-Closing Devices on Outside Doors
BY: William P. Wollschlager
DATE: 2/21/85
SUMMARY: Intent of Section 6-702 of model codes require self-
closures for doors opening to the outside.
SUBJECT: National Foodhandler's Test - Review
BY: Sanford A. Miller
DATE: 2/20/85
SUMMARY: Believe new food protection certification program
provides the opportunity to assure that managers have acquired
necessary knowledge in food protection sanitation.
SUBJECT: Standard for Carts - Review
BY: Raymond D. Beaulieu
DATE: 2/4/85
SUMMARY: Have no objection to proposed standard, however, we are
considering code revisions which would base equipment requirements
on menu of food cart.
SUBJECT: Pets in Dining Rooms of Long Term Health Care Facilities
BY: William P. Wollschlager
DATE: 1/29/85
SUMMARY: Animal exclusion requirement could be modified to allow
a pet program to be conducted if it meets certain conditions.
SUBJECT: State's Regulations for Food Establishments - Review
BY: William P. Wollschlager
DATE: 1/24/85
SUMMARY: Regulations are not equivalent to recommended model code.
SUBJECT: Quaternary Ammonium Compounds
BY: William P. Wollschlager
DATE: 1/24/85
SUMMARY: Compound complies with CFR 21 Part 178.1010(b)(22).
SUBJECT: Safe Product Temperature in Cooking Prefabricated Beef
Roasts
BY: William P. Wollschlager
DATE: 1/18/85
SUMMARY: Recommend the same minimum safe cooking criteria for
beef roasts regardless of whether the roasts are solid, deboned or
prefabricated.
SUBJECT: Coated Incandescent Lamps
BY: Raymond D. Beaulieu
DATE: 1/18/85
SUMMARY: Lamps meet intent of Section 7-402 of model codes.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1984
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Ceiling / Wall Material
BY: William P. Wollschlager
DATE: 12/26/84
SUMMARY: Material meets requirements of Section 7-202 of model
codes.
SUBJECT: "On-Table" Dispensing of Acidified Dressings
BY: Raymond D. Beaulieu
DATE: 12/24/84
SUMMARY: Squeeze bottle dispensing is acceptable as
long as pH is maintained below the 4.6 level.
SUBJECT: New Hamburger Refrigeration Methods
BY: William P. Wollschlager
DATE: 12/20/84
SUMMARY: Procedures meets intent of model codes although
suggestions were made for clarifying or improving sections of
subject procedure.
SUBJECT: Sanitation Management Book - Review
BY: Robert F. Hendrickson
DATE: 12/14/84
SUMMARY: Found book to be comprehensive and consistent with
provisions of model codes.
SUBJECT: Study on Institutional Processing Procedures for Roast
Beef - Review
BY: William P. Wollschlager
DATE: 12/10/84
SUMMARY: Study should provide data needed to answer questions
previously posed by food and equipment representatives at 7/7/83
meeting.
SUBJECT: Pre-Cooked Beef Procedures
BY: William P. Wollschlager
DATE: 12/10/84
SUMMARY: Recommend that clear instructions be added to procedures
to assure that total time of beef exposure to temp. above 45
degrees F will exceed 7 hours.
SUBJECT: Stuffed Croissants
BY: William P. Wollschlager
DATE: 12/10/84
SUMMARY: Additional bacteriological research data on process
should be submitted.
SUBJECT: Sauce Dispensing
BY: Raymond D. Beaulieu
DATE: 11/16/84
SUMMARY: No time frame needs to be considered provided squeeze
bottles are emptied, washed and sanitized on a routine basis.
SUBJECT: Drip / Collect Pan
BY: Raymond D. Beaulieu
DATE: 10/25/84
SUMMARY: Equipment is not acceptable for use in food service
establishment or retail food stores.
SUBJECT: Review of Section 2-102 of Retail Food Store Code
BY: Thomas L. Schwarz
DATE: 10/25/84
SUMMARY: Word "pasteurized" should be added to this requirement.
SUBJECT: Country Cured Products - Refrigeration or Not
BY: William P. Wollschlager
DATE: 10/23/84
SUMMARY: May not be considered a potentially hazardous food
depending on whether it requires special handling.
SUBJECT: Egg Nog Mix
BY: William P. Wollschlager
DATE: 10/15/84
SUMMARY: "Batch" preparation of reconstituted dry milk or dry milk
products may create significant potential of contamination for
high risk patients.
SUBJECT: Temperature Requirements for Country Cured Products
BY: William P. Wollschlager
DATE: 10/23/84
SUMMARY: Dry cured ham (country ham, country style ham, dry cured ham,
country pork shoulder, country style pork shoulder or dry cured pork shoulder
processed and packaged, whole or sliced, and labeled in plants under USDA
FSIS or equivalent state inspection service as defined in Title 9 CFR 318.10
(c)(1v) and 319.06 will not be considered a potentially hazardous food. FSIS
considers dry cured bacon processed as above to be non-potentially hazardous.
If package label recommends "special handling", i.e. refrigeration, the
product would be considered potentially hazardous per Title 9 CFR 3172(k).
Violations of special handling instructions for temperature would be marked
under item 3.
SUBJECT: Pasta Machines - Review
BY: William P. Wollschlager
DATE: 9/24/84 & 9/21/84
SUMMARY: Model does not comply with criteria sanitary construction
of equipment in model codes.
SUBJECT: Ceiling Covering Material for Dining Areas
BY: William P. Wollschlager
DATE: 9/14/84
SUMMARY: Does not comply with Section 7-206 of model codes.
SUBJECT: Bulk Milk Dispenser Spouts
BY: Raymond D. Beaulieu
DATE: 9/12/84
SUMMARY: Plastic film must be removed from plastic spout and spout
must be cut diagonally as close as possible to bottom of sleeve.
SUBJECT: Proposed Draft Code of Hygiene Practice for Pre-Cooked
and Cooked Meals in Mass Catering - Review
BY: William P. Wollschlager
DATE: 9/16/84
SUMMARY: Proposed criteria is generally equivalent to model code.
SUBJECT: Salad Bars in Retail Markets
BY: Arthur L. Banks
DATE: 8/23/84
SUMMARY: Recommended that agency providing inspection apply more
flexible criteria of model code as it pertains to salad operation
bar.
SUBJECT: Interpretation of Term "New" in Model Code
BY: Arthur L. Banks
DATE: 8/21/84
SUMMARY: "New" refers to construction of establishment and not to
changes in ownership.
SUBJECT: Section 900 - Water Vending Machines Review
BY: Raymond D. Beaulieu
DATE: 8/8/84
SUMMARY: Lists specific suggestions for improvements in standard.
SUBJECT: Proposals to Adjust Sample Size for Evaluations
BY: Thomas L. Schwarz
DATE: 7/30/84
SUMMARY: Does not look favorably on any of the options proposed by
states.
SUBJECT: Standard 3 with Respect to Glass Washers and Chemical
Sanitizing -Review
BY: Raymond D. Beaulieu
DATE: 7/27/84
SUMMARY: Main concern involves actual sanitizing spray rinse
contact time as applied to equipment and utensils during rinse
cycle.
SUBJECT: Two-Compartment Sinks Under 1976 Food Service Manual
BY: Arthur L. Banks
DATE: 7/26/84
SUMMARY: Must never lose sight of responsibility to assure "equal
protection under the law."
SUBJECT: Self-Cleaning Process for Soft Ice Cream Machines -
Review
BY: Raymond D. Beaulieu
DATE: 7/15/84
SUMMARY: Such practice is not to be encouraged.
SUBJECT: Nacho Cheese Pumps
BY: William P. Wollschlager
DATE: 7/20/84
SUMMARY: Use of an unheated food pump for dispensing of hot nacho
cheese is unacceptable.
SUBJECT: "Home-Type" Mechanical Dishwashers
BY: William P. Wollschlager
DATE: 7/20/84
SUMMARY: Not normally considered acceptable because or design and
construction features and time needed for completion of operational
cycle.
SUBJECT: Standard 51 - Review
BY: Raymond D. Beaulieu
DATE: 7/19/84
SUMMARY: Deals with various sections separately.
SUBJECT: Salad Program Procedures - Review
BY: William P. Wollschlager
DATE: 6/27/84
SUMMARY: Procedures must clarify existing sanitary guidelines.
SUBJECT: Telecourse on Food Protection - Review
BY: Arthur L. Banks
DATE: 6/22/84
SUMMARY: Consider it to be integral part of developing national
test.
SUBJECT: Transmission of Warts by Foods
BY: Robert F. Hendrickson
DATE: 6/22/84
SUMMARY: Should encourage workers to have warts removed by
dermatologist.
SUBJECT: Low Temperature Cook-and Hold Ovens
BY: Raymond D. Beaulieu
DATE: 5/29/84
SUMMARY: Cannot accept ambient air cooking temp of less than 250
degrees F in dry heat ovens.
SUBJECT: Glass and Plastic Cleaner
BY: Raymond D. Beaulieu
DATE: 5/22/84
SUMMARY: Product can be used to clean exterior non-food-contact
surfaces of plexiglass containers.
SUBJECT: Food Store Sanitation Manual - Review
BY: Raymond D. Beaulieu
DATE: 5/15/84
SUMMARY: Suggest that the number of sink compartments to be used
is indicated.
SUBJECT: Toxic Substances in Food Service Establishments - Review
BY: Thomas L. Schwarz
DATE: 4/26/84
SUMMARY: Article includes information on too many subjects to be
cohesive.
SUBJECT: Mirrors and Mobile Food Service
BY: Arthur L. Banks
DATE: 4/16/84
SUMMARY: Should institute "like requirements for like food service
processes."
SUBJECT: Operational Procedures for Chicken Program - Review
BY: William P. Wollschlager
DATE: 3/16/84
SUMMARY: Suggestions were made to eliminate conflicts with model
code and technical criteria was provided.
SUBJECT: pH of Sauce
BY: Raymond D. Beaulieu
DATE: 3/16/84
SUMMARY: Has pH below 4.6; refrigeration of sauce is unnecessary
as it is not considered a potentially hazardous food.
SUBJECT: Plastic Spoons and Forks for Multi-Use - Review
BY: Raymond D. Beaulieu
DATE: 3/16/84
SUMMARY: Models submitted need to correct lack of smoothness on
outer edges of spoons and forks.
SUBJECT: Training Series, Hot Trucks Sanitation and Safety -
Review
BY: Raymond D. Beaulieu
DATE: 2/10/84
SUMMARY: Series definitely covers an area that needs to be
addressed in local or state training.
SUBJECT: Reconstitution of Dry Milk and Dry Milk Products for
Drinking Purposes
BY: William P. Wollschlager
DATE: 2/8/84
SUMMARY: Leads to unnecessary potential for contamination and risk
to patients.
SUBJECT: Prevention of Foodborne Illness in Food Service
Operations - Review
BY: William P. Wollschlager
DATE: 1/26/84
SUMMARY: Generally training course materials were found to be
excellent.
SUBJECT: Instructions for Cheese Brand
BY: William P. Wollschlager
DATE: 1/25/84 & 12/15/83
SUMMARY: Label instruction revision with deletion of word
"lightly" will meet intent of food supply labeling criteria in
model codes.
SUBJECT: Mushrooms in Sauce Procedure
BY: William P. Wollschlager
DATE: 1/20/84
SUMMARY: After changes are made for reheating, procedure will be
acceptable in meeting intent of model code.
SUBJECT: Truth-in-Menu Laws or Requirements
BY: William P. Wollschlager
DATE: 1/31/84
SUMMARY: FDA does not require truth-in-menu statements;
jurisdictions may choose to regulate truth-in-menu statements.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1983
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Nacho Cheese Dispensing Pump
BY: William P. Wollschlager
DATE: 12/29/83
SUMMARY: Cannot be considered acceptable in safe temperature
criteria for protection of potentially hazardous foods in model
codes.
SUBJECT: Glass Cleaner - Exemption of Hot Detergent Solution
Temperature Requirement
BY: William P. Wollschlager
DATE: 11/21/83
SUMMARY: Acceptable with regard to model code.
SUBJECT: Reheating of Roast Beef
BY: Raymond D. Beaulieu
DATE: 11/21/83
SUMMARY: Recommends that current position of reheating of roast
beef not be changed.
SUBJECT: Plastic Flatware - Review
BY: William P. Wollschlager
DATE: 11/21/83
SUMMARY: Comply with acceptable criteria in model code.
SUBJECT: Procedures for Heating Fresh Mushrooms - Review
BY: William P. Wollschlager
DATE: 11/21/83
SUMMARY: Meet requirements for food protection storage and
preparation contained in model code.
SUBJECT: Halon Fire Extinguishers
BY: Thomas L. Schwarz
DATE: 10/25/83
SUMMARY: Little chance of food adulteration, although food
directly exposed to Halon should be discarded.
SUBJECT: Question of Pet Food Inclusion in Bulk Food
Interpretation
BY: Robert F. Hendrickson
DATE: 11/1/83
SUMMARY: Does not include pet food.
SUBJECT: Reservice of Food
BY: William P. Wollschlager
DATE: 10/17/83
SUMMARY: Cannot recommend endorsement of reserving of food.
SUBJECT: Plastic Flatware
BY: William P. Wollschlager
DATE: 8/23/83
SUMMARY: Flatware meets criteria of model codes.
SUBJECT: Infra Red Lamps in Popcorn Machine Enclosures - Location
BY: Raymond D. Beaulieu
DATE: 8/4/83
SUMMARY: Lamps must be protected by a shield surrounding and
extending beyond lamp as specified in model codes.
SUBJECT: Griddle Blocks
BY: Raymond D. Beaulieu
DATE: 5/13/83
SUMMARY: Griddle blocks would be acceptable provided that grill or
griddle surface is thoroughly washed and heated for several minutes
prior to cooking.
SUBJECT: Ceiling Coating
BY: Raymond D. Beaulieu
DATE: 5/11/83
SUMMARY: If ceiling is smooth, nonabsorbent and cleanable, it
would comply with construction requirements of model codes.
SUBJECT: Three-compartment Sink Modification
BY: William P. Wollschlager
DATE: 4/18/83
SUMMARY: Sink "D" cannot be considered for use as an optional sink
in the manual three-compartment warewashing operation.
SUBJECT: Refrigerator Deodorizer
BY: Raymond D. Beaulieu
DATE: 3/9/83
SUMMARY: Product is acceptable as long as container is free-
standing on a rack or hung from a rack.
SUBJECT: Non-Dairy Vanilla Bavarian Creme-Filled Donuts
BY: William P. Wollschlager
DATE: 3/9/83
SUMMARY: "Bavarian creme" filling should not be considered a
potentially hazardous food.
SUBJECT: Glasswasher
BY: Raymond D. Beaulieu
DATE: 3/4/83
SUMMARY: Glasswasher model does not meet criteria of model codes.
SUBJECT: Wicker Plate Holder and Identification of Plastic Bags
BY: William P. Wollschlager
DATE: 2/14/83
SUMMARY: Holder does not meet criteria of model codes. Company will furnish
statement providing formal assurance of safe materials when "food" bags are
shipped.
SUBJECT: Bulk Mayonnaise in Cardboard Boxes and Underground
Cooking of Meats
BY: William P. Wollschlager
DATE: 1/26/83
SUMMARY: Food product packaging must protect product from
contamination; outdoor pit cooking method is not recommended for
feeding the public.
SUBJECT: Voluntary Seminar for Store Managers - Review
BY: Robert F. Hendrickson
DATE: 1/10/83
SUMMARY: Course is well written, well researched and well
organized.
SUBJECT: Cutlery - Review
BY: William P. Wollschlager
DATE: 12/29/82
SUMMARY: Plastic utensils can only be considered as single service
articles.
SUBJECT: Wood Container Treated With Pressure Treating Wood Preservative
Process
BY: William P. Wollschlager
DATE: 10/28/82
SUMMARY: Solution of chemicals used in process are not listed as
acceptable for wood preservation in the CFR.
SUBJECT: Minimum Final Rinse Temperature
BY: Raymond D. Beaulieu
DATE: 9/23/82
SUMMARY: Minimum final rinse temperature must be 75 degrees F or
above.
SUBJECT: Filled Pastry
BY: William P. Wollschlager
DATE: 9/27/82 & 8/20/82
SUMMARY: Identified product not considered to be a potentially
hazardous food.
SUBJECT: Procedure for Bacon
BY: William P. Wollschlager
DATE: 9/1/82
SUMMARY: Finished cooked bacon is not considered to be a
potentially hazardous food.
SUBJECT: Imitation Lowfat Dry Milk
BY: William P. Wollschlager
DATE: 7/7/82
SUMMARY: Product is considered to be an "imitation milk product"
which would be applicable to Section 2-101 of the model codes.
SUBJECT: Metal Sponges
BY: William P. Wollschlager
DATE: 5/26/82 & 3/4/81
SUMMARY: These utensils and equipment must be rinsed free of
detergent and abrasives after use.
SUBJECT: Plastic Flatware - Review
BY: William P. Wollschlager
DATE: 5/19/82
SUMMARY: Flatware does not meet design and construction criteria
of model codes.
SUBJECT: Dishwashers - Review
BY: William P. Wollschlager
DATE: 5/18/82
SUMMARY: Dishwasher model does not meet acceptable sanitary
standards.
SUBJECT: Broiling/Frying Equipment Ventilation
BY: Raymond D. Beaulieu
DATE: 5/13/82
SUMMARY: Equipment need not be vented provided that units do not
create excessive vapors, odors, smoke, fumes or steam.
SUBJECT: Porcelain Enameled Cookware
BY: Raymond D. Beaulieu
DATE: 5/6/82
SUMMARY: Recommended use of alternative types of cookware.
SUBJECT: Pre-Blanched Fried Chicken - Storage
BY: William P. Wollschlager
DATE: 3/25/82
SUMMARY: Chicken should comply with either Section 2-302(b) or
Section 2-303(b) of model code.
SUBJECT: Trained Monkeys to Serve Persons
BY: William P. Wollschlager
DATE: 2/25/82
SUMMARY: No reason found to expand intent of Section 7-806 of
model code at the present time.
SUBJECT: Pizza Screen
BY: William P. Wollschlager
DATE: 2/25/82
SUMMARY: Use of pizza screen as a multi-use food-contact surface
does not comply with Sections 4-101 and 4-102(a) of model code.
SUBJECT: Chili Meat Segment of Chain's Program Manual - Review
BY: William P. Wollschlager
DATE: 2/23/82
SUMMARY: Will probably need to restructure manual to accommodate
FDA recommendations.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1981
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Raw Eggs Consumption - Review [NOTE: RESCINDED BY INTERPRETATION
AND LATER LETTER WHEN SE PROBLEM BECAME EVIDENT]
BY: William P. Wollschlager
DATE: 12/10/81
SUMMARY: There will be no public health hazard in preparing an
individual glass of fluid drinking product fortified with raw egg
ingredient if beverage is to be served for immediate consumption.
SUBJECT: Drink With Egg Procedures - Review [NOTE: RESCINDED BY
INTERPRETATION AND LATER LETTER WHEN SE PROBLEM BECAME EVIDENT]
BY: William P. Wollschlager
DATE: 12/8/81
SUMMARY: Product complies with provisions of model code.
SUBJECT: Stainless Steel Treatment Product Containing Petroleum
Distillates Safety
BY: Thomas L. Schwarz
DATE: 12/1/81
SUMMARY: Product is acceptable under certain conditions noted. Label and
store as provided in Model Code Sections 7-702 and 703. Use on non-food
contact equipemt in a way which prevents conatamination of food, equipment or
utensils (7-704). Use on a food contact surface would not be acceptable
since the petroleum distillates in this product may constitute an unapproved
Food Additive under FD & C Act.
SUBJECT: Pre-Cooked Beef Procedures - Review
BY: William P. Wollschlager
DATE: 11/16/81 & 10/27/81
SUMMARY: Procedures appear to comply with provisions of model
code.
SUBJECT: Making Buttermilk from Nonfat Dry Milk
BY: Raymond D. Beaulieu
DATE: 10/22/81
SUMMARY: Practice considered to be unacceptable under any
conditions.
SUBJECT: Sanitary Guidelines for Operating Outdoor Cookers -
Review
BY: William P. Wollschlager
DATE: 10/21/81
SUMMARY: Appears that guidelines cover basic sanitation
requirements.
SUBJECT: Sanitizer Review
BY: William P. Wollschlager & Raymond D. Beaulieu
DATE: 9/22/81 & 7/5/80
SUMMARY: Quaternary ammonium compounds found in product are
considered to be safe in a solution for use in food-contact
surfaces.
SUBJECT: Unprotected Display of Mints and Candy
BY: William P. Wollschlager
DATE: 9/14/81
SUMMARY: Food must be protected from contamination.
SUBJECT: Plastic Syringe Used for Patient Feeding
BY: William P. Wollschlager
DATE: 8/28/81
SUMMARY: Syringe will not comply with cleanability criteria for
design and fabrication of multi-use utensils contained in model
code.
SUBJECT: Chlorine Treatment of Raw Vegetables
BY: Thomas L. Schwarz
DATE: 8/19/81
SUMMARY: Recommended that a potable rinse be used before serving.
SUBJECT: Cast Iron Skillets Serve Food
BY: William P. Wollschlager & C. Phillips
DATE: 8/14/81
SUMMARY: Skillets are not in compliance with provisions of model
code.
SUBJECT: Fortification/Reconstitution of Fluid Milk
BY: William P. Wollschlager
DATE: 8/5/81
SUMMARY: "Batch" fortification of fluid milk leads to an
unnecessary potential for contamination and risk to patients.
SUBJECT: Raw Fish
BY: William P. Wollschlager
DATE: 8/3/81
SUMMARY: Appears that customer eating raw fish is exposed to a
significant public health hazard.
SUBJECT: Brass in Drinking Cups
BY: Raymond D. Beaulieu
DATE: 7/20/81
SUMMARY: Do not encourage manufacture of brass drinking cups as
there is possibility of migration or leaching of components of
brass into contents of cup.
SUBJECT: Glasswashing Machine
BY: William P. Wollschlager
DATE: 7/9/81
SUMMARY: If glasswasher can meet specific testing criteria and
meets Sections 4-101 and 5-104 of model code, it would be
acceptable.
SUBJECT: Frozen Dessert Dipper Storage
BY: Raymond D. Beaulieu
DATE: 6/5/81
SUMMARY: Do not interpret Section 9-102 of model code as
prohibiting the dipping of ice cream in temporary establishments.
SUBJECT: Handling of Food With Bare Hands
BY: Raymond D. Beaulieu
DATE: 5/18/81
SUMMARY: Food can be properly protected from contamination by
employees using good hygienic practices and suitable utensils to
minimize manual contact of food.
SUBJECT: Minimum Safe Cooking Temperature for Pork
BY: William P. Wollschlager
DATE: 5/2/81
SUMMARY: Minimum product cooking temperature for pork is 150
degrees F.
SUBJECT: Iced Carrot Cake
BY: William P. Wollschlager
DATE: 5/8/81
SUMMARY: There should be no public health hazard with respect to
time/temperature considerations.
SUBJECT: Boiler Water Treatment Containing Cyclohexylamine and
Morpholine
BY: Thomas L. Schwarz
DATE: 5/5/81
SUMMARY: Product containing both of these chemicals is not in
accordance with FDA regulations.
SUBJECT: Sanitizing Rinse
BY: Thomas L. Schwarz
DATE: 4/13/81
SUMMARY: Specified product rinse meets applicable criteria for sanitizing
solutions in model code.
SUBJECT: Baked or Broiled Potatoes Considered To Be Potentially
Hazardous
BY: Arthur L. Banks
DATE: 3/24/81
SUMMARY: Baked or boiled potatoes are considered to be a
"potentially hazardous" food.
SUBJECT: Conversion of Warewashing Machines from Hot Water to
Chemical Sanitization Machines
BY: Raymond D. Beaulieu & William P. Wollschlager
DATE: 3/18/81 &/9/80
SUMMARY: Machines meet requirements of model code provided they
meet certain conditions listed in opinion.
SUBJECT: Acceptability of Plastic Bags Intended for Food Usage
BY: William P. Wollschlager
DATE: 3/13/81
SUMMARY: Need to establish voluntary system of uniform
identification tags.
SUBJECT: Foil Pans Re-Use
BY: William P. Wollschlager
DATE: 3/1/81
SUMMARY: Pans do not meet applicable design and construction
criteria in model code to be considered as multi-use food-contact
utensils.
SUBJECT: Spot Floor Cleaning of Spills or Drippage
BY: William P. Wollschlager
DATE: 3/10/81
SUMMARY: Spot floor cleaning of non-liquid spills is acceptable
without use of dust arresting compound; for liquid floor spills or
drippage a small amount of absorptive floor compound may be applied
to spill.
SUBJECT: Wooden Paddles as Food-Contact Utensils
BY: Raymond D. Beaulieu
DATE: 3/9/81
SUMMARY: Appears that use of paddles in confectionery operations
is acceptable when paddles are constructed of hard maple or the
equivalent.
SUBJECT: Self-Adhesive Strips Containing Chlorpyrifos (Dursban)
BY: Thomas L. Schwarz
DATE: 2/26/81
SUMMARY: If strips are stored and used in accordance with the
label they meet requirements of model code.
SUBJECT: Temperature Maintenance Food Service System
BY: William P. Wollschlager
DATE: 2/9/81
SUMMARY: As long as system can obtain and maintain safe time
temperature relationships for potentially hazardous food, it is
acceptable for usage.
SUBJECT: Hush Puppy Batter Mix - Review
BY: William P. Wollschlager
DATE: 2/5/81
SUMMARY: Should establish a 10-hour maximum use time for batter
mix rather than current company criteria of 14 hours.
SUBJECT: Food Shields Review
BY: Raymond D. Beaulieu
DATE: 1/19/81
SUMMARY: Have no objection to proposed NSF standard No. 2, Section
4.41 and 7.41.1.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
1980
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
SUBJECT: Cheese Refrigeration
BY: Raymond D. Beaulieu
DATE: 12/2/80
SUMMARY: Cheeses should be treated as potentially hazardous when
original packaging has been removed or broken.
SUBJECT: Donut Shells Filled With Synthetic Fillings
BY: Raymond D. Beaulieu
DATE: 12/2/80
SUMMARY: Growth of S. aureus is possible in filled shells.
SUBJECT: System for Dispensing Salad Dressings
BY: Raymond D. Beaulieu
DATE: 11/24/80 & 11/21/80
SUMMARY: Dressing dispenser complies with applicable non-food-
contact criteria in model code.
SUBJECT: Conveyorized Chemical Sanitizing Dishwashers
BY: Raymond D. Beaulieu
DATE: 11/24/80
SUMMARY: Dishwasher is acceptable based on results of NSF
evaluation.
SUBJECT: Plastic Drinkware
BY: Raymond D. Beaulieu
DATE: 11/24/80
SUMMARY: Drinkware meets applicable sanitary criteria for safe
materials.
SUBJECT: Wearing of Shorts by Employees Handling Food
BY: Raymond D. Beaulieu
DATE: 10/21/80
SUMMARY: Adherence to Sections which prohibit insanitary personal
practices and requires restraint of hair products necessary
criteria for maintenance of acceptable personal practices.
SUBJECT: Sodium Hypochlorite Compound for Cleaning Ceilings in
Food Markets
BY: Raymond D. Beaulieu
DATE: 8/26/80
SUMMARY: Compound is acceptable for cleaning ceilings provided
there is no dripping of solution onto food or food-contact
surfaces.
SUBJECT: Whipped Margarine
BY: William P. Wollschlager
DATE: 8/15/80 & 3/10/80
SUMMARY: Margarine in general is not supportive to rapid growth of
progressive and toxigenic bacteria.
SUBJECT: Soap Dispensing Valve
BY: 8/4/80
DATE:
SUMMARY: By itself this device does not provide backflow
prevention capability. If found installed without properly installed
blackflow prevention device, it would be a violation of Section 6-303 of
Model Code.
SUBJECT: Reconstitution of Dry Ingredients with Fruit Juice
BY: Raymond D. Beaulieu
DATE: 7/23/80 & 6/26/80
SUMMARY: Product complies with dry milk and dry egg product
criteria of model code.
SUBJECT: Insecticide Fogger
BY: William P. Wollschlager
DATE: 7/11/80
SUMMARY: If label instructions are closely followed product meets
provisions of model code.
SUBJECT: Low Temperature Dishwashers
BY: Raymond D. Beaulieu
DATE: 5/20/80
SUMMARY: Visual and dependable flow indicating device located on
machine will provide safeguard similar to thermometers.
SUBJECT: Fried Chicken Batter
BY: William P. Wollschlager
DATE: 4/9/80
SUMMARY: Batter is considered to be potentially hazardous;
therefore, it must be kept at 45 degrees F.
SUBJECT: Chemical Sanitizer
BY: William P. Wollschlager
DATE: 4/4/80
SUMMARY: Compound meets applicable criteria of CFR Section
178.1010.
SUBJECT: Family-Style Food Service at Day Care and Head Start
Centers
BY: William P. Wollschlager
DATE: 3/19/80
SUMMARY: Strongly recommend individual portioned food service to
preclude possibility of spread of communicable disease.
SUBJECT: Brass or Bronze Food Contact Surfaces
BY: William P. Wollschlager
DATE: 3/7/80
SUMMARY: Brass or bronze food contact surfaces of equipment are
generally recognized as safe (GRAS).
SUBJECT: Rolled Beef Roasts Cooking
BY: William P. Wollschlager
DATE: 2/8/80
SUMMARY: Not considered to be a stuffed meat; cooking of roast
must be in accordance with Section 2-403(c) of model code.
SUBJECT: Non-Dairy Coffee Lighteners
BY: Raymond D. Beaulieu
DATE: 2/6/80
SUMMARY: Products must be refrigerated.
SUBJECT: Definition of "Meat"
BY: WFB
DATE: 1/23/80
SUMMARY: Intent of Section 2-403(a) refers to all edible parts of
meat, poultry, and seafood.
SUBJECT: Toilet Rooms - Mechanical Ventilation
BY: William P. Wollschlager
DATE: 1/22/80
SUMMARY: In all new or extensively remodeled establishments
mechanical ventilation will be needed for toilet rooms.
SUBJECT: Mechanical Chemical Dishwashing Machines
BY: William P. Wollschlager
DATE: 1/8/80
SUMMARY: Answers to specific questions are contained in opinion.
SUBJECT: Styrofoam Cups
BY: John Thomas
DATE: 1/17/80
SUMMARY: Current evidence of potential carcinogenicity is neither
convincing nor relevant to warrant action prohibiting use of the
styrofoam cups.
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
FDA PRIME CONNECTION USERS NOTE:
THIS IS THE END OF THE 1992 - 1980 OPINION INDEX PROVIDED THROUGH THE FDA
PRIME CONNECTION TECHNICAL BULLETINS. AS OTHER WORK ALLOWS, ADDITIONAL YEARS
WILL BE ADDED.
Return to FDA Prime Connection Retail Food Protection references
Go BACK to the
CFSAN/FDA Food and Consumer Information pages
Hypertext updated by ear, 11/18/96