Ftag of the Week – F812 Food Procurement, Store/Prepare/Serve – Sanitary (Pt 2)

This week’s Ftag of the Week on the CMSCG Blog is Part 2 of our review of F812 Food Procurement, Store/Prepare/Serve – Sanitary. If you missed Part 1, you can view it here. F812 requires that nursing homes have policies, procedures, training and monitoring systems in place to prevent the spread of foodborne illness and are responsible for ensuring food preparation and handling practices minimize the potential for contamination.

The regulatory guidance notes that effective food safety systems not only involve identifying hazards during food handling and preparation, but also identifying how those hazards can be prevented or minimized, particularly by identifying critical control points (CCPs) in the food preparation process. Food preparation includes washing, thawing, cutting/slicing, mixing ingredients, cooking, cooling, reheating, pureeing/blending, and diluting concentrates. CCPs allow staff to exercise controls to reduce/eliminate/prevent food safety hazards.

Safe Food Preparation

The regulatory guidance emphasizes the importance of identifying potential hazards in the food preparation process and adhering to the critical control points to reduce the risk of contamination, which reduces the risk of foodborne illness. There are three general categories of food contaminants, including biological, chemical and physical contaminants. In this blog post, we will look at food safety related to preventing biological contamination of food items.

Food Safety – Biological Contaminants

Biological Contaminants include bacteria, viruses, toxins and spores, as well as infrequently, parasites. The regulatory guidance identifies many factors which can influence the growth of bacteria, which is one of the most common types of disease-producing organism. CMS notes that acidic foods generally inhibit bacterial growth due to their pH, but foods that contain higher levels of water may encourage bacteria to grow, so staff need to understand these food safety principles.

Potentially hazardous foods (PHF) and Time/Temperature Controlled for Safety (TCS) foods are foods that are considered more hazardous than others, and include unpasteurized eggs, raw poultry such as chicken, seafood, raw ground beef, melon that has been cut, and dairy items such as milk, yogurt or cottage cheese. There is a table with recommended control strategies in the State Operations Manual (SOM) for:

  • Eggs (Raw or unpasteurized)
  • Raw Poultry
  • Raw Meat
  • Fresh Fruits and Vegetables
  • Ready to Eat Meat and Poultry
  • Pasteurized Dairy
  • Ice

TCS foods require time and temperature control to reduce the likelihood of microorganism growth/toxin formation. Bacterial growth can be encouraged by the moist environment of the danger zone and killed by heating to 165 degrees or higher. The danger zone for foods refers to temperatures between 41 degrees F and 125 degrees F. PHF/TCS foods that are held in the danger zone for more than four hours if being prepared with ingredients at an ambient temperature or more than six hours after being cooked and cooled may cause foodborne illness if they are consumed. Inadequate cooking and improper holding temperatures can promote pathogenic growth. Staff must use a clean, sanitized and calibrated thermometer to verify food temperatures accurately.


The process of thawing foods at room temperature may result in bacterial proliferation, and as such, may not be an acceptable food safety practice. The guidance at F812 recommends that staff thaw foods safely through four methods. These include thawing the item as part of a continuous cooking process or thawing the food in a microwave and then cooking and serving it immediately. Food items may also be thawed in the refrigerator in a drip-proof container or ensuring the item is completely submerged under cold, running water that can agitate and remove loose ice particles. Cold water must be at 70 degrees F or below.


It is necessary to cook foods to proper temperatures and for enough time to ensure that any dangerous organisms have been killed or sufficiently inactivated so the food can be safely served to residents. This requires internal food temperatures to reach the following levels:

  • Poultry – 165 degrees F
  • Stuffed foods – 165 degrees F
  • Ground meat or fish – 155 degrees F or more
  • Fish and non-ground meats – 145 degrees F
  • Fresh, frozen or canned fruits/vegetables – 135 degrees F or more for hot holding
  • Eggs held for service – 155 degrees F or more
  • Unpasteurized eggs – These must be cooked completely, regardless of resident requests for undercooked eggs . These may only be prepared using pasteurized eggs.

If raw foods will be prepared in the microwave, they must be rotated and stirred during cooking to ensure the entire item is heated to at least 165 degrees F. The items should stand for 2 minutes or longer to ensure that temperature equilibrium has been achieved.


PHF/TCS foods must be cooled within acceptable timeframes to reduce the likelihood that any microorganisms that survived the cooking process can grow. It is important to ensure that potentially hazardous foods that have been cooked and are subject to time and temperature control are cooled with the following in mind:

  • Rapid cooling should be occurring within 2 hours (from 135 degrees to 70 degrees F) and within 4 hours of cooling, the food should be approximately 41 degrees F.
  • The total cooling time from 135 degrees F to 41 degrees F should not be more than 6 hours.
  • Large/dense food items may require additional interventions to be chilled safely within allowable time frames due to their volume. This includes putting these foods in shallow pans, cutting large items into smaller pieces, using ice water baths and/or stirring periodically. Tightly-covered hot food containers may have slower cooling rates and measures should be taken to help lower the temperatures of these foods.


Not only are thawing, cooking, and cooling areas that are important to preventing foodborne illness, so is reheating those foods that have been prepared appropriately.

  • PHF/TCS foods that have been cooked and cooled must be reheated in a manner that ensures all parts of the food reach at internal temperature of 165 degrees F for a minimum of 15 seconds before the food can be held for hot service.
  • Ready to eat food items that need to be heated before consumption should be taken directly from the sealed container and heated to at least 135 degrees F for hot service holding.
  • Using a steam table for reheating foods is not permitted since foods are not brought to the proper temperature within acceptable timeframes.
  • Mechanically altered foods must be reheated to 165 degrees F for 15 seconds if holding for hot service.

Making Ice

Making ice can create a potential for contamination or waterborne illness, so facilities must ensure that staff are following safe handling practices. This includes:

  • Ice must be made using potable water
  • Ice used for cooling food items cannot be used for consumption

I am sure you are getting the idea that a lot of things are happening in your kitchen that could result in a wide-spread negative outcome if appropriate procedures are not followed. You just might want to take a look in the kitchen, if you know what you are looking for, or have qualified staff conduct appropriate auditing of kitchen food safety procedures.

The regulatory guidance at F812 provides very detailed information on expectations related to food preparation. In next week’s post, we will look at other potential areas of contamination, and food service/distribution.

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