Making it work: the application of time as a public health control in the field

Time as a public health control (TPHC) is increasingly being recognized as a viable alternative to temperature control for potentially hazardous foods in the developed world. This is reflected by recent changes to food regulations and other pertinent health legislation in both Canada and abroad. Considerable ambiguity remains, however, as to when and how TPHC should be applied at the field level. The author reviewed pertinent legislation, regional standards, and guidelines in various jurisdictions. The author did not identify standardized methods for having health departments receive applications from food vendors, for evaluating such applications for approval or rejection once received, or for monitoring food products subsequent to such an approval. A 4-step process was then designed to help ensure a standardized application of TPHC principles at the field level. Applications, representing a variety of potentially hazardous food products from both ethnic and North American cuisines, were reviewed and processed according to stated criteria. A structured format for the application, approval, monitoring, and evaluation of potentially hazardous ready-to-eat foods by management and field personnel helps improve consistency in the application of TPHC principles, demonstrate due diligence (for environmental public health departments), and relieve district environmental health officers (EHOs) from the pressures of having sole responsibility over the approval process.