12.1 Minimum Internal Cooking Temperatures

Cooking is the last reliable kill step for many vegetative pathogens on raw animal food. FDA Food Code 3-401.11 (2022, January 18, 2023 version) does not say “cook until it looks done.” It says heat all parts of the food to a listed temperature for a listed time. Time is part of the legal standard. A hamburger that kissed 155°F and came off the grill a second later has not met 17 seconds. A chicken breast that reached 165°F in the thickest part has met the poultry standard because that standard is instantaneous — less than 1 second.

The Person in Charge (PIC) matches the food category, not the plate name. A turkey burger is poultry. A stuffed pork chop is stuffed meat. Pooled scrambled eggs on a buffet are not eggs broken for immediate service. If you memorize three numbers without the foods and the times, you will miss the item.

The Three Animal-Food Groups in 3-401.11

165°F (74°C) for less than 1 second (instantaneous)

Heat all parts to 165°F (74°C) for <1 second for:

• Poultry — chicken, turkey, duck, and other domesticated birds, ground or whole
• Baluts
• Wild game animals
• Stuffed fish, meat, pasta, poultry, or ratites
• Stuffing that contains fish, meat, poultry, or ratites

Stuffing is on this list because it sits in a cavity and lags. If the stuffing is 140°F while the breast reads 165°F, the dish is not done. Probe the stuffing and the thickest part of the meat. A stuffed pasta shell filled with meat or a chicken roulade stuffed with cheese and ham is the same 165°F instantaneous group, not the 145°F intact-meat group.

155°F (68°C) for 17 seconds

Heat all parts to 155°F (68°C) for 17 seconds for:

• Non-intact meat — the 2022 Code's umbrella term, which by definition covers comminuted (ground, chopped, minced) meat such as hamburger, meatloaf, and sausage; injected or stitch-pumped meat; and mechanically tenderized meat (needled, bladed, pinned, or Jaccard-style piercing)
• Comminuted fish and comminuted commercially raised game — fish cakes, ground venison from an inspected supplier
• Ratites (ostrich, emu, rhea)
• Raw eggs not prepared for immediate service — pooled eggs, buffet scrambled eggs, and eggs cooked and held

Comminuting and piercing move surface bacteria into the interior, so the center needs a stronger time-temperature treatment than an intact steak. Watch the vocabulary here, because the 2022 edition changed it: 3-401.11(A)(2) now reads “RATITES, and nonINTACT MEATS”, plus comminuted fish and game animals and raw eggs not prepared for immediate service. FDA's Summary of Changes says it “delete[d] the terms ‘mechanically tenderized’ and ‘injected’ and replace[d] [them] with the term ‘nonIntact meat’,” and also “removed the term ‘meats’ from the listing of comminuted meats as it is already included by definition under the term nonIntact meat.” Nothing about the kitchen answer changed — ground beef, a stitch-pumped pork loin, and a Jaccarded steak are all 155°F for 17 seconds — but the 2022 Code gets there through one umbrella term instead of a list. “Intact Meat” is the defined term: “a cut of whole muscle(s) meat that has not undergone comminution, mechanical tenderization, vacuum tumbling with solutions,” or similar processing. Anything that fails that definition is non-intact and belongs in the 155°F group. “Mechanically Tenderized” is separately defined to include injection, blade tenderizing, jaccarding, pinning, and needling. 3-401.11(A)(2) also prints an equivalent chart (145°F for 3 minutes, 150°F for 1 minute, 155°F for 17 seconds, 158°F instantaneous). The number the exam expects for a hamburger is still 155°F for 17 seconds. Do not invent a different tenderized temperature.

145°F (63°C) for 15 seconds

Heat all parts to 145°F (63°C) for 15 seconds for:

• Intact steaks and chops of meat — pork, beef, veal, and lamb
• Fish, including intact seafood that is not comminuted
• Commercially raised game animals that are intact
• Raw eggs broken and cooked for immediate service in response to a consumer’s order

A salmon steak is intact fish: 145°F / 15 seconds. A salmon burger is comminuted fish: 155°F / 17 seconds. Eggs over-easy cooked to order can legally stop at 145°F / 15 seconds if the operation is allowed to serve them that way. The same eggs pooled at 6 a.m. for a buffet must reach 155°F / 17 seconds. Wild game and commercially raised game are not interchangeable: wild game is 165°F instantaneous; intact commercially raised game is 145°F / 15 seconds.

Roasts and the 135°F Plant and RTE Lines

Whole meat roasts — beef, corned beef, lamb, pork, and cured pork such as ham — are not the 15-second steak rule. 3-401.11(B) uses a time-temperature chart. The common teaching pair is 145°F (63°C) for 4 minutes. The same chart allows lower temperatures held much longer; 130°F (54.4°C) for 112 minutes is one listed combination. Oven type and roast weight also have preheat rules. You do not need to memorize every row. You do need to know that a table exists, that 145°F for 4 minutes is the usual exam pair, and that a roast pulled at 145°F with no hold has not met the roast standard.

Plant foods cooked for hot holding — fruits, vegetables, grains, and legumes — must reach 135°F (57°C) under 3-401.13. That is a hot-holding cook, not a raw-animal kill step. Vegetables roasted and sent immediately to the line without hot holding are a different service pattern; the 135°F line is the one the exam uses when those plant foods will sit on a steam table.

Commercially processed ready-to-eat (RTE) foods taken from an intact package from an inspected plant and heated for hot holding must reach 135°F under 3-403.11(C). Leftover TCS food that was cooked in the house and cooled is a different rule: reheat that to 165°F for 15 seconds. Do not apply the 135°F commercial-RTE line to leftover chicken soup you made yesterday.

Measure the Thickest Part; Color Is Not a Substitute

Insert a cleaned, calibrated probe into the thickest part of the food. Avoid bone, fat pockets, and the pan bottom. For a hamburger, that is the center of the patty. For poultry, that is the innermost part of the breast or thigh, not the grilled surface. For a casserole or stuffed item, check more than one place, including the stuffing.

Color is not a substitute for temperature and time. Pink poultry can be done; brown hamburger can be undercooked. Smoke, curing salts, myoglobin, and grill marks fool the eye. Juices that run clear are not a Food Code measurement. If the PIC is deciding whether the food may be served, the decision is a thermometer reading held for the required time, not a glance at color.

Scenario: Hamburger, Chicken Breast, Salmon Steak

Saturday grill line. Three tickets land together.

1. Hamburger (comminuted beef). Probe the center. Hold 155°F for 17 seconds. A mid-rare 130°F patty has not met 3-401.11 unless a lawful consumer advisory and a non-HSP population apply — and even then the kitchen is serving undercooked comminuted meat, not “a steak cooked as a burger.”
2. Chicken breast (poultry). Probe the thickest part. 165°F instantaneous. 155°F is the hamburger number, not the poultry number. Do not split the difference.
3. Salmon steak (intact fish). Probe the thickest part. 145°F for 15 seconds. Do not “just to be safe” force every animal food to 165°F on the exam if the question asks for the Code minimum.

Same shift, same grill, three legal answers. Mixing them is the most common cooking miss on CFPM items.

Exam Traps

• All meat is 145°F ignores non-intact meat (comminuted, injected, tenderized), stuffed foods, and poultry. 145°F is for intact steaks and chops.
• Quoting the 2017 wording of 3-401.11(A)(2) — “mechanically tenderized and injected meats” — as if it were the 2022 text. The 2022 Code says non-intact meat, which covers all of it.
• 165°F for everything is not the Code and will miss hamburger, fish, and egg items.
• 155°F with no time fails the 17-second hold.
• Stuffing cooks with the bird is wrong until the stuffing itself is 165°F.
• Pooled eggs equal eggs to order is wrong: buffet or pooled eggs are 155°F / 17 seconds; immediate-service eggs are 145°F / 15 seconds.
• Wild game equals commercially raised game is wrong: wild is 165°F; intact commercially raised game is 145°F / 15 seconds.
• Brown juices mean done is never the legal standard.
• Leftover house-cooked chili reheated for hot holding is 135°F confuses commercial intact RTE with leftover TCS food that must return to 165°F.