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Hydrated Pancake/Waffle Batter Mix

In response to questions the Ohio Department of Health Food Safety Program has received regarding pancake/waffle mix preparing and handling procedures in hotel breakfast settings, the Ohio Department of Health Food Safety Program is providing the following clarification. 

Various hotel chains offer pancake and/or waffles for breakfast, and at times may add the hydrated pancake/waffle batter mixes to a dispensing machine for holding at ambient temperature. The hydrated batter mix is considered a time temperature controlled for safety food (TCS), and therefore, must be held at required temperature of 41°f and below or 135°f and above.

If there is a question as to the status of the batter mix (i.e., TCS vs. non-TCS), the onus is on the operator and/or manufacturer to prove that the hydrated pancake/waffle batter mix is a non-TCS product.

Some hotel chains have provided scientific challenge study results for the pancake/waffle batter mix to ODH. The findings show that pathogen growth is limited for a specified period of time, but do not conclude that the hydrated batter mix is a non-TCS food. The ODH Food Safety Program consulted with U.S. Food and Drug Administration, Retail Food Safety Team regarding these specific studies and they concur with our opinion that the hydrated
pancake/waffle batter mix product must be treated as a TCS food.

The ODH Food Safety Program recommends that local health districts re-evaluate these types of operations prior to the next license renewal period to determine the exact preparing and handling procedures for the pancake/waffle batter mix. Operations identified as holding the batter mix at ambient temperature for up to four hours in the dispensing machine and discarding would be considered as using time as a public health control. If the
operation is identified as using time as a public health control, the operation must be licensed as a risk class level IV operation, as per OAC 3701-21-02.3 (D). These facilities must also comply with OAC 3717-1-3.4 (I): Time as a public health control.

In summary, if the operation is holding the pancake/waffle batter mix at the proper temperature prior to service, the risk level classification should be considered with other food handling procedures to determine the proper risk level category. If the TCS (i.e., hydrated pancake/ waffle batter mix) product is being held at ambient temperature prior to service, then time as a public health control may be considered. Therefore, the food service
operation must be licensed as a risk level IV.

Please contact the ODH Food Safety Program Staff at 614-466-1390 if you should have any questions regarding this matter.

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