How long is a limited period, and who has to justify it?

The containers are still at the ramp, the vehicle has not backed in yet, and lunch service starts in forty minutes. The trays that came out of the kitchen sit beside the bench while everyone runs the same sum in their head: how long can this food stay here without anyone having to answer for it afterwards?

Article 18, paragraph 5 of the Food Hygiene Regulation looks straight at that moment, and the order of its sentences repays attention. The prohibition comes first: raw materials, ingredients and finished products that allow pathogens to multiply or toxins to form must not be held at temperatures capable of creating a health risk, and the cold chain must stay unbroken. Only afterwards, in conditional language, does the permission arrive, allowing such products to be held at ambient temperature for limited periods so as to accommodate practices such as preparation, transport, storage, display and food service, provided that no risk to health is created. Nowhere does a figure appear: neither forty minutes nor two hours.

The rule leaves the number open and asks you for the reasoning. Two details in that paragraph work in the operator's favour, and one works squarely against him. The list of practices ends with "such as", so it was never meant to be closed, and the wording puts the clock in the plural, limited periods, which leaves room for a separate figure per product and per step. The condition attached to all of it has no give whatsoever: the absence of a health risk governs the list and the clock alike, and the job of showing that absence stays with the operator.

Everything that holds the explanation together sits around one subtraction. You take the time the product reached service, deduct the time it left refrigeration, note the temperature measured at each end of that gap, and hold the result against the limit you accepted for that product. At an inspection the argument tends to settle on where the limit came from rather than on the gap itself, so whatever produced that limit, your own measurement, the holding time given in the product's technical file or the guide you work to, is the sheet that belongs beside the record.

Time you cannot account for rarely stays with a single tray. Article 21, paragraph 1(d) of Law No. 5996 provides that where part of a batch or consignment of the same class or description is unsafe, and safety cannot be shown for the remainder through a more extensive assessment, the whole batch or consignment is taken to be unsafe. Two containers forgotten at the ramp therefore put the entire lunch run from that batch into question.

Where the clock enters the written procedure

On paper the limit you will have to defend has a place of its own. Article 22, paragraph 1 of the same Regulation obliges the food business operator to put in place, implement and maintain procedures based on hazard analysis and critical control point/HACCP principles, or a permanent procedure, while paragraph 2(c) calls for critical limits to be established at critical control points, separating what is acceptable from what is not. Time at ambient temperature is precisely such a limit, and the moment its minutes go into the procedure, the question shifts from how long the food was held to whether the limit you set for yourself was respected. Point (ç) of the same paragraph then requires effective monitoring at that point, and point (d) a corrective-action procedure kept ready for the occasions when the point slips out of control.

A duration written into the procedure once is not a right acquired for good. Article 22, paragraph 3 requires the operator to review that procedure and amend it as necessary whenever a change is made to the product, to the processing method or to any stage of production. Put a heat-treated tray on the menu in place of a cold salad, move the service point out to a distant district, replace the boxes with new ones, and the minutes you defended last season no longer stand by themselves. Frozen goods sit under a different paragraph altogether: thawing is governed by paragraph 7 of the same article, which asks for it to be carried out at temperatures that minimise the risk of pathogen growth and toxin formation and for the liquid released to be drained properly, so a pallet left to its own devices at the ramp never falls under the limited-period flexibility.

Time inside a closed body is a measurable quantity. There are places where the legislation does measure time directly. In the ATP text published with the amendments of 22 June 2024, Annex 1, paragraph 4 defines heated equipment as insulated equipment able to raise the inside temperature of the empty body and then keep it from falling below +12 °C for at least 12 hours without renewal of supply, with the mean outside temperature varying by class. How long a closed, insulated box holds without any energy input can be written down that way, while the minutes an open tray spends on a bench stay an estimate.

It is worth saying what those values do not describe: they are the conditions of a test run on an empty body, so they characterise the box rather than your loaded round. No certificate records for you the temperature the box was loaded at, how often the lid was opened, or how long the vehicle waited at the ramp; that territory belongs to the procedure and the log. Even so, time spent inside a closed box turns into a very different record from the same time spent on an open tray at the counter, because what you end up holding is measured behaviour in place of an estimate.

We set out step by step how a line that reaches lunch service on time is built on our ready-meal distribution page.

Running the clock by feel costs you legal cover as well: Article 886, paragraph 1 of the Turkish Commercial Code states that the provisions limiting liability do not apply where it is proven that the damage arose from an act done with intent, or recklessly and with knowledge that damage would probably result. The regulation hands you the flexibility, and in exchange it asks you to justify how long the period ran, where that figure is written down, and why you treated it as safe.