Cooling Processes Without a Written Operational Policy Isn’t So Hot

See what I did there?


In my work over a decade as a local public health regulator, and more recently, as a Food Safety Consultant, I have found that one of the biggest challenges that retail food operations, like grocery stores and restaurants face, is the development and consistent execution of a standard procedure for cooling food down quickly. The data reflects this too; Tri-County Health Department, which serves over 1.3 million people in the Denver-metro area, reported 567 cooling violations during inspections at Retail Food Establishments between January and December of 2019.


Complicating matters further, a correct cooling procedure requires frequent staff monitoring and reliable logging of food temperatures during the cooling process, requiring both attention and time, something that owners, managers, chefs, or kitchen staff will attest they never have enough of during operating hours.


Even writing a policy for cooling foods correctly can take quite a bit of time and can be an onerous process for individuals who are not used to developing policies given the detail that is needed. Further, once the policy is developed time (and patience) is needed to train staff to the policy and provide corrective action once the policy is in place and being applied.


The result of the combination of the challenges mentioned (certainly not all-inclusive of all of the food safety challenges that an operation faces - the list is long) is often a haphazard operational approach to cooling food down that is not based on a consistent policy, if one exists at all. This is just the reality - I've seen it in one-too-many operations where I inspected or I have been called in to assist with food safety compliance and training.


So why bother?


You shouldn't be lulled into a false sense of security because the approach you have been using so far has only yielded a few violations from the Health Department (which you always correct before they come back) and, as far as you know, you haven't killed anyone yet - congratulations.


Here's the facts:


Improper cooling practices are a major cause of foodborne illness. According to the Centers for Disease Control and Prevention (CDC), between 1998 and 2008, improper cooling practices in retail food operations in the United States contributed to 504 outbreaks linked to restaurants and delis. Research conducted in 2010 by the CDC and several state health departments shows the data collected indicate that many restaurants are not meeting the recommended cooling processes. A total of 420 restaurants participated in the study.


Microorganisms grow well in the temperature danger zone, 41°F-135°F; within this range, temperatures between 125°F and 70°F allow for the most rapid growth of microorganisms, including pathogenic (harmful) microorganisms that can cause illness. Food must pass through this temperature range quickly to reduce the chance for these microorganisms to grow and reproduce to numbers that can make your customers very, very sick. The initial 2-hour cooling period is the most critical time period since the food is passing through the temperature range that supports the most rapid microorganism growth. If food has not reached 70°F from 135°F within two hours, it must be reheated to 165° F for 15 seconds and then cooled again correctly, or it must be thrown away.



Spore-forming organisms such as Clostridium perfringens or Bacillus cereus will continue to persist and grow rapidly in foods that are being cooled incorrectly. Other pathogens such as Salmonella or Listeria monocytogenes may be reintroduced during the cooling process in kitchens with poor sanitary conditions and will be happy to reproduce in a warm environment that improper cooling creates. All of these organisms can lead to severe illness with symptoms including diarrhea, vomiting, stomach cramps, or in the case of high-risk individuals, deadly infections, from which you may find yourself, or your business rightly liable for failing to protect the safety of the food prepared and served to your customers. Ask Marler Clark, the leading national law firm dedicated to prosecuting foodborne illness cases. If you make someone, or a group of people sick, they'll remember, and so will their friends and family.


Cooling food correctly, using an approved process, is required in the Colorado Retail Food Establishment Rules and Regulations/ 2013 FDA Food Code, sections 3-501.14 and 3-501.15. If found out of compliance during a health inspection, the associated violation would likely be cited in the Priority category, meaning the cooling procedure being employed (or lack therof) contributes directly to the hazards associated with foodborne illness or injury; there is no other provision that more directly controls the hazard. In 2020, the Colorado Revised Statues around health department enforcement activities will change (more info here); if there is an accumulation of violations that are uncorrected upon follow-up by the Health Department, it could result in an Order to Close and/or assessment of civil penalties and fines. Additionally, accumulation of violations can lead to an increased inspection frequency and/or a lower inspection score that many local departments will be adopting and publishing in the near future - none of which is good for repeat customer visits. And neither is foodborne illness caused by improper cooling practices, by the way.


Policy Writing 101: Start With the Basics


You may be able to find some general cooling policy templates by doing a Google search, but you’ll likely find that they aren’t specific enough to address your operation’s needs/context, and they can definitely be unreliable when calling out specific regulation requirements. The Food Safety Management Systems section in the ServSafe Manager book as well as the other course content in the book will give you a good start in developing an outline and you can build out the SOPs from there.


1. Read the Regulations


The Colorado Retail Food Establishment Rules and Regulations may read like stereo instructions in some parts (ok, every part), but if you ease into it, and try to apply the requirements to the context of your own operation, they will begin to make sense, and you will find this is an incredible resource. The regulation requirements will give you the baseline of what your cooling policy needs to accomplish, giving you the minimum and maximum thresholds, as well as the correct/approved procedures that you can incorporate into your policy. Additionally, the annex to the regulations gives you the "why" behind the "because I said so"; this information can be useful to incorporate into the policy as well as it will provide meaning for the staff that will be executing the policy.

Colorado Retail Food Establishment Rules and Regulations - See Section 3-501.14 and 3-501.15 for cooling requirements.


2. Develop a Tracking Method

To ensure consistency, the ability by management to monitor performance and action taken by staff during cooling processes, and for general record keeping to reduce risk and liability, all foods entering a cooling process, need to be monitored and tracked to ensure they move from 135°F to 70°F in two (2) hours and 70°F to 41°F or below in four (4) hours or less. This also includes tracking foods that have been warmed during a preparation process or foods that have been stored following delivery from a supplier; these foods have four (4) hours maximum to cool to 41°F or below.


A cooling log doesn’t need to be fancy, but should have some specific components. A cooling log should be developed that captures the date, the product, an hourly interval to record food temperatures of the product being cooled, as well as specific columns to note when the food reached 135°F, 70°F and 41°F. This cooling log developed by the Minneapolis Health Department (Cooling Log) is a great example of what is needed; it is offered in a variety of languages as well.


There are hardware and software options available to track and monitor food safety processes like cooling. However, in my experience, unless you have a staff member dedicated to overseeing food safety in the operation, the software set up can be tedious, and training staff how to use the equipment can be challenging, which likely will result in them not using the equipment at all, leaving you back at square-one for your improvement process.


Whichever option you decide to use, paper logs or electronic, be sure to maintain the records for at least 90 days, or longer. You never know when these records may come in handy, or when they'll be requested, so you will be glad that you saved them once they are!



3. Provide the Needed Tools

Staff members who have been designated to accomplish this task will need a calibrated thermometer and a cooling log. Additionally, you may find that a combination of products that can be used as cooling aids, like ice wands or ice from an ice machine will be a valuable investment in controlling the cooling process. If you are cooling large quantities of food frequently, an (big) investment in a blast chiller, could also be considered. Walk-in coolers and reach-in coolers should NOT be used to cool foods down - they are meant to keep cold foods cold. Adding warm food to these areas will likely increase the air temperature of the cooler, as well as the temperature of the other foods stored in these areas. Using ice, ice wands, or a combination, will get the food cold enough to store once they have moved through the cooling process. Metal pans or freezer (gel) pans should also be considered in your assessment of cooling equipment. Metal pans, trays, and sheets will help to conduct the heat out of the food; plastic storage equipment will only help to insulate the heat in the food and will take longer to cool.


4. Write the Policy

After reviewing the regulations on cooling, developing a cooling log, and purchasing the needed tools for staff to monitor cooling processes, you will need to identify all foods in your operation that will be cooked, then cooled prior to storage for further preparation or storage after remaining warm (like on a steam table or buffet line). Additionally, you will need a general policy section on cooling of any foods that have been warmed during a preparation process or during a delivery-storage process. Set the minimum and maximum standards for both time and temperature, what method or combination of methods should be used to cool foods down, specifying how to reduce the size of the food product to aid in the cooling process, as well as how to address corrective actions: what to do if the food is not cooling quickly enough or if the food has exceeded any critical limits you have set based on the regulatory requirements. Include in the policy how long the logs should be kept, and where, as well as who and how often the logs will be reviewed by management to ensure compliance with the policy. Specific requirements around staff training should also be included (see the next section). Finally, include a periodic review requirement to revisit the policy and test how effective it is; if you find it needs adjustment, make those changes, update your policy and re-train staff as needed.



5. Train Staff

A written policy does absolutely no good if staff are not trained on it. And don't expect staff to sit on their breaks or at home with the policy to make sure they understand it. An active training program will need to be developed - who, what, where, when, how will all need to be addressed in this training program in regards to monitoring and logging foods that are actively cooling. The training program you develop for cooling may be part of your overall training policy that you have developed for your operation - if you haven't developed that yet, now is the time!


This certainly is not an all-inclusive list on how to develop a policy for cooling in your operation, nor does it cover all the aspects of what should be included in a cooling policy; you will need to reflect on the context of your operation and how it cools food to capture the nuances that exist. If you find that you need some assistance in writing these policies and/or training staff on food safety policies in general, we are here to help! Contact us at: schevalier@cloudbreakadv.com to set up a consultation appointment!.






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