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Frequently Asked Questions: Temporary Food Services (TFS)

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Q:  What is a Temporary Food Service license?

A:  A Temporary Food Service, or TFS, is a short-term food service operating at a fixed location in conjunction with a distinct event. It usually involves a non-permanent set-up, often outdoors, to serve food to the public.

Serving food in this way is inherently more challenging than in a permanent establishment in terms of food safety. Holding food at safe temperatures, operating without electricity in some cases, keeping dust and bird droppings out of food, the lack of plumbing and running water, lack of storage space, preventing cross-contamination between raw meats with foods that don’t require cooking, are just some of the challenges. What’s more, operating a TFS often involves individual components that can easily be altered, left-behind, or set-up differently with every event (hand wash station, food equipment, gloves, awning, etc.), making it critical that food safety remains intact with each event.

To help make food safety a priority, TFS menus should involve limited onsite prep and involve only quick cook and serve, or quick assemble and serve. All TFS operations must be supported by a licensed kitchen for food storage, cooking, dishwashing, and for sourcing hand-wash water and properly disposing of waste.

Q:  What is the difference between the TFS Plan Review application and the TFS?

A:  The plan review application is the Missoula County application that simply reviews the “when”, “where”, and “how” of the temporary food service event. We look at the location and times of the event, the menu, how foods will be prepared, and how your booth with be set-up. The plan review fee is $25 when submitted more than 5 business days in advance of the event.  The fee increases when submitted closer to the event date. Since the plan review process serves to assess food safety concerns, both for-profits and non-profits must complete a plan review and pay the appropriate fee. If you know you will be applying for multiple venues using the same menu and set-up, you may submit multiple applications at the same time for a single fee.

If approved for service to the public, you will be issued a Montana State TFS license. The state license fees are based on the number of employees in the food establishment. It is $85 for two employees or fewer, and $115 for more than two employees. Non-profits are exempt from obtaining a state license if they operate as a food service for less than 14 days in a calendar year.

Q:  How do I know if I need a TFS license?

A:  Basically, anytime food or open beverages are served to the public (regardless of whether there is a charge for the food) the Missoula City-County Health Department requires a state food license. There are specific exemptions for non-profit organizations, certain foods at Farmers’ Markets, and caterers in some cases. To help decide if you are a TFS, ask yourself the following questions:

If you answered “yes” to any of the above, then you need to complete a TFS plan review and license with the state.

Q: Are there any TFS license exemptions?

A:  Yes.

Q:  How many events does the TFS license cover?

A:  You must complete a plan review for each separate event at which you want to serve food or beverages.  A license is limited to a person and event at a certain location. Every license receives a health inspection. This is especially important for TFS establishments since operating a TFS often involves individual components that can easily be altered, left-behind, or set-up differently with every event (hand wash station, food equipment, gloves, awning, etc.), making it critical that food safety remains intact with each event.

If events are in a series (e.g. Griz games, Out to Lunch, farmers markets), you may apply for one license to cover the event.  The license however, is limited to 14 consecutive or 21 non-consecutive days in a calendar year. 

For an event license (commonly farmers’ markets) that contain more than 21 individual events in a calendar year, you must submit a list of days that you will not vend, in accordance with state law.

Vendors who want to be operate more than 21 licenses events throughout the year are no longer considered a temporary food service and can either apply for a mobile license or a retail food establishment license. While these licenses involve more of an initial investment and require more permanent equipment, these licenses are paid once each calendar year.

Q:  Can I prepare or store food at home?

A:  No. Food must be prepared and stored at a licensed commissary. All commissaries receive a minimum of one health inspection per year to insure that all necessary safety precautions are in place. The only current exemptions to this rule include the preparation of non-potentially hazardous baked goods and high sugar foods (jams, jellies, candy) for sale at Farmers’ Markets and non-profit bake sales.

Q:  What is a licensed commissary?

A:  A commissary is basically a kitchen that has been licensed with the state for food service to the public. Every licensed food service establishment by law gets a health inspection at least once per calendar year. In Missoula County we inspect over 800 licensed food establishments each calendar year. Every convenience store, bar, casino, coffee hut, grocery store, and restaurant gets inspected. You will use your commissary kitchen (depending on menu) for cold and dry food storage, preparation of menu items, washing of produce, dish washing facilities, potable water source, and an approved waste water disposal area. Using licensed and inspected facilities is one way you can be sure that minimum health standards are in place for you.

Q:  What are the safe temperatures for food?

A:  Chicken must be cooked to >165oF, ground pork and beef to >155oF, and whole muscle pork and beef to >145oF. Hold hot foods at > 135oF, and cold foods at < 41oF. lids). Foods held between 41oF-135oF are considered to be in the “Temperature Danger Zone” as they are the temperatures that actively support bacterial growth. The only way to know food is at a safe temperature is to use accurate calibrated thermometers. Thermometers should be available on-site.

Documented time-control can be used as an alternative to using temperature as a safety control. In this case, foods cannot be out of temperature for more than 4hrs and the operator must demonstrate a documented system for determining how much time food has been out of temperature.

Q:  What are requirements in terms of food reheating and cooling?

A:  TFS menus should involve limited onsite prep and involve only quick cook and serve or assemble and serve. Reheating and cooling should be kept to a minimum when possible.

Reheat foods on the grill or propane stove to bring food temperature to 165oF within 30 minutes.  Do not attempt to heat foods in crock pots, steam tables or other hot holding devices, or over Sterno.  These slow-cooking mechanisms may encourage rapid bacterial growth and never reach killing temperatures.  Use approved equipment, no enameled pots or pans.

Foods that require refrigeration after preparation at the commissary (i.e., potentially hazardous foods such as potato salad, egg salad, chili, taco meats, cut melon, etc.) must be cooled to 41oF within 4 hours.  Use an ice water bath, stirring the product frequently, or place the food in shallow pans no more than 2 inches deep and store in a refrigerator.  Check temperature frequently to ensure quick cooling.

Q:  How do I transport food from commissary to event?

A:  If food needs to be transported from one location to another, you must provide adequate temperature controls, such as using refrigerated trucks or insulated containers to keep hot foods hot (135oF) and cold foods cold (41oF).

Q:  Are there certain ways I need to handle ice?

A:  Ice is both a coolant and a food, but the two functions must not be confused.  Keep ice for drinks separate from ice used to cool foods and beverages. Ice used as food must be drained. Packaged food in contact with water or undrained ice is prohibited.  Wrapped sandwiches must not be stored in direct contact with ice.  Ice scoops must have handles and handles need to stay out of the ice. All ice must be from an approved ice manufacturer or come from the licensed commissary kitchen.

Q: What about utensils and dishes?

A:  Customer food service items must be single service.  Utensils used in food preparation and service must be washed in hot soapy water, rinsed in hot water, sanitized in solution of proper strength (test strips required) and air dried prior to use.  All dishes must be done at your approved commissary, and enough clean utensils shall be stored in the food booth to provide clean utensils at least every 4 hours.

Q:  I am setting up outdoors, what are the basic booth requirements?

A:  Design your booth with food safety in mind.  The booth must have an overhead covering and the floors must be a cleanable, removable material in good repair. If cooking cannot take place under cover of tent, all food must be covered while cooking (e.g. BBQ lid and pan lids). Sides will be required on the booth if the weather (wind, dust, rain) poses a contamination risk to your food.  Only food workers will be permitted inside the booth.  No animals are permitted. 

ach booth must have at least one hand wash station as described below.  All wastewater from hand washing and food service must be disposed of by a lawfully constructed and operated public sewage disposal system. Waste water cannot be dispensed onto the ground.

A garbage container with a plastic liner and tight fitting lid must be available for garbage.  Proper management of wastes will reduce insect problems and keep your booth attractive to customers.

Q:  If I am set up outdoors, how do I wash my hands?

A:  Hands are probably the most common vehicle for the transmission of pathogens and can become contaminated in a variety of ways during routine operations. From the biggest restaurant chain to the smallest coffee hut, hand washing is one of the most effective ways for food handlers to prevent the spread of communicable disease. The spread of Staphylococcus aureus, Hepatitis A, Norovirus, E.Coli, and others can be prevented by thoroughly washing hands prior to food service and whenever hands become unclean and potentially contaminated. Outbreaks involving all of these pathogens have occurred as a result of insufficient hand washing.

Because hand washing is such an important factor in the prevention of food borne illness, sufficient hand washing stations must be set-up to not only make hand washing a possibility, but likely. At a minimum, the station must have:  a five gallon container of WARM water from your commissary, a water spigot/spout that allows both hands to be under the running water (i.e. no push button containers), a catch bucket below to catch hand wash water, hand soap in a dispenser, and disposable paper towels. Common towels for hand-drying are prohibited. The hand wash station must be conveniently located for use by food service workers and a trash receptacle should be nearby. All  wastewater from hand washing and food service must be disposed of by a lawfully constructed and operated public sewage disposal system.

Q:  When do I need to wash hands?

A:  The short answer is every time they become soiled. At a bare minimum, wash hands prior to beginning food service and after any interruption in service. There are many examples of times when a hand wash is needed. If you leave the booth, handle money, handle garbage, use your phone, itch your nose, scratch your head, wipe hands on pants, apron, or other unclean surface, cough, sneeze, eat, drink, or use tobacco, handle raw meat, or handle dirty dishes, wash your hands before returning to food service. Always wash hands prior to donning gloves, otherwise, hands can contaminate the outer portion of the glove.

Q: How do I wash my hands?

A:  Bacteria and other pathogens wedge themselves into the oily folds of our skin and hold fast to our hands. To be effective, hand washing should always be performed with warm water. Scrub your hands and exposed portions of your arms with soap for at least 20 seconds prior to rinsing and drying.  Hands become soiled with a variety of food particles, raw meat juices, oils, liquids, etc. during food prep and therefore a bottle of hand sanitizer does not serve as a replacement for but only an addition to a complete hand wash.

Q: Am I required to wear gloves?

A:  Not necessarily, but bare hand contact with any ready-to-eat foods is STRICTLY prohibited. Whatever works easiest for the food operator to eliminate bare hand contact is what is required. This could be disposable gloves, tongs, tissue paper, etc.  As much as possible, foods must be packaged in individual servings at the commissary.  Common bowls that allow customers to contact food with bare hands is also prohibited. Contacting ready-to-eat foods with bare hands has been know to lead to the transmission of pathogens such as Hepatitis A, Staphylococcus aureus, Norovirus, and E.Coli

Q:  Why do I need surface sanitizer and what kind is effective?

A:  Surface sanitizer effectively reduces the numbers of pathogens that could get someone sick. Every food service must have a sanitizing solution in a bucket with an available wiping cloth.  The solution can be either chlorine (bleach) at 50-100 ppm or quaternary ammonia at 200 ppm.  Operators must have test strips to ensure proper concentration. Keep wiping cloths in the buckets when not in use, otherwise these damp cloths simply lose sanitizing strength and can become a site for bacterial growth. At a minimum, surfaces should be sanitized prior to operating and whenever food spills occur.

Q:  Why does the Health Dept do inspections? Don’t they trust me?

A:  The public has an expectation that the food/drink that they eat is safe.

While it is the responsibility of the operator to be aware and knowledgeable of food safety and the rules that are in place to keep the public from getting sick, the health inspection is often the best way to insure that safe food is being served.

The Health Dept is probably the most visible in the eyes of the public when a food borne illness outbreak occurs or when there are large nationwide food recalls. However, responding to these public health issues is only a small part of what we do.

Before any food service opens or makes significant changes to it’s menu or operation, we review the plans, menu, and equipment and work with businesses to insure the set-up errs on the side of safety. In Missoula County we inspect over 800 licensed food establishments each calendar year, not including the over 200 TFS inspections we do each summer. This means that on a daily basis, our inspectors are visiting restaurants, convenience stores, outdoor food booths, and anyplace that food is served to the public to assess whether or not food handlers/establishments are serving food safely. Our inspections are unannounced and focus on risk, that is, on what is likely to get someone sick. In addition, we also inspect child care facilities, group homes, hotels, motels, and pools. What pays for us to be in an establishment are the state license fees and tax dollars. That is how we fund this public service.

Think about what it would be like to go out to eat at a restaurant where the chicken or hamburger was undercooked, where food was being stored at improper temperatures, where employees didn’t have access to a hand sink, where bare-hands contacted your food, where the glass your child drinks out of has not been sanitized, or where there was no way to track the sources of the foods served.

We insure these very basic food safety guidelines are understood, and are being followed. Even something as simple as lemon wedges at a bar or unpackaged candies can lead to illness if they are handled improperly or if food-contact surfaces are not being washed, rinsed, and sanitized.  Without proper hand washing, Hepatitis A, Staphylococci, Norovirus, and E.Coli are all easily transmitted to customers and staff.

We are not the food police. Our role is primarily one of education. We work with food operators to understand the rules and achieve safe food service. We can’t be everywhere all the time however, and feel that all those who want to feed the public should be equally concerned about doing it safely.

Q: What do I do when the health inspector shows up?

A:  The health inspector is your ally. Be polite and friendly, and don’t be afraid to ask questions. The interaction does not have to be contentious. We will arrive, use and inspect your hand wash station, confirm safe food temperatures, food sources, and sanitizer levels. We will observe hand washing practices and help you identify and eliminate the potential for cross-contamination during food service. Inspectors can help you find ways to make your food service safer which is good for the public and for business. We are often seen as a cheap insurance policy by restaurant operators, as preventing a food borne illness (and the potential for subsequent lawsuits and bad press) should be everyone’s goal.

Have more questions?  Contact Us!

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