10.1 FIFO, Labeling, and Date Marking

FIFO is the storage rule that turns a receiving date into a use order. First in, first out means the oldest dated product is used first. New deliveries go behind or under older stock so a cook who reaches for a pan or a case automatically takes the product that must leave the house first. FIFO is not a slogan on a poster. It is a physical arrangement plus a date check. If the new case of milk is stacked in front of yesterday's case, the operation has already decided to waste the older milk or serve it after its date.

The Person in Charge (PIC) owns FIFO at every storage point: walk-in, reach-in, dry store, and freezer. Staff check use-by, expiration, and date-mark dates when they put product away and again when they pull it. Product past its date is discarded, not "used up on the line because it looks fine." A date is a control. Appearance is not a substitute for it.

Label Working Containers with the Common Name

FDA Food Code 3-302.12 requires working containers holding food or food ingredients that have been removed from their original packages to be identified with the common name of the food. A cambro of white powder on the prep table is not self-explanatory. Flour, sugar, salt, MSG, baking soda, and powdered sanitizer can look similar in a rush. The label is the common name — "all-purpose flour," "granulated sugar," "kosher salt" — not a station nickname and not a blank piece of tape.

Readily recognizable foods in their obvious form (dry pasta in a clear bin, for example) are the usual teaching exception. Do not stretch that exception to powders, liquids, sauces, or prepped TCS food. A working container of chicken salad, house vinaigrette, or portioned chili needs the name of the food. Date marking, covered next, is a separate requirement that often lives on the same label.

Date Marking: FDA Food Code 3-501.17

3-501.17 is the date-marking rule CFPM exams test by name. Ready-to-eat (RTE) time/temperature control for safety (TCS) food that is prepared on site and held refrigerated for more than 24 hours must be date marked. Commercially processed RTE TCS food that is opened on site and held more than 24 hours must also be date marked. The mark tells the operation the date or day by which the food must be consumed on the premises, sold, or discarded.

The holding limit is 7 days at 41°F (5°C) or below. The day of preparation or the day the commercial package is opened counts as Day 1. Food held past Day 7 is discarded. There is no "it still smells fine" extension and no extra day because the cooler ran at 38°F. Colder storage does not buy an eighth day under the standard Food Code teaching.

If the food is later frozen, the date-mark clock pauses while the product is frozen solid and resumes when the food is thawed. The original Day 1 does not reset. Count the refrigerated days already used, subtract them from 7, and the remainder is what is left after thaw. Write the preparation or opening date, the freeze date if the house procedure uses it, and a new discard date based on the remaining days. Thawing does not start a fresh 7-day clock.

Chicken Salad Made Monday

A cook prepares chicken salad on Monday and refrigerates it at 41°F or below. Monday is Day 1. The salad may be held through Sunday (Day 7) and must be discarded Sunday — at the end of Day 7, not first thing Monday morning as an eighth day. If the same salad is frozen on Wednesday (Day 3 used), four days remain after thaw. If it is thawed the following Thursday, those remaining days resume; they are not seven new days.

Commercially processed roast beef opened Tuesday is the same math: Tuesday is Day 1, discard Monday, unless the manufacturer's use-by date comes first. The earlier of the 7-day mark and the manufacturer's date is the discard date for opened commercial RTE TCS.

What Usually Does Not Need a Date Mark

Exams hammer the 7-day RTE TCS rule. They also expect you to know that exceptions exist. Uncut whole produce is not date-marked as RTE TCS. Shelf-stable packaged food is not date-marked until it becomes a refrigerated TCS leftover after opening or cooking. Food Code exceptions commonly include some hard cheeses (aged cheddar, Parmesan, Romano, and similar low-moisture cheeses) and some cultured dairy products such as yogurt, sour cream, and buttermilk. Individual meal portions prepared and served or displayed for immediate sale are another typical exception. Do not memorize a loophole list to dodge date marking. If the item is RTE TCS prepared or opened on site and held more than 24 hours, date-mark it and discard it on Day 7.

Date-Mark Examples

How the PIC Makes FIFO and Date Marks Stick

Put new product behind or under old product. Face date marks so they can be read without unstacking pans. Use one date format (day of week, calendar date, or a color-dot system that still states the discard day). Train staff that "prep date" and "discard date" are not interchangeable unless the house label defines which one is written. A pan labeled only "chicken salad" with no date is a 3-501.17 failure if it will be held past 24 hours.

Discard on Day 7. Do not combine two leftover pans of chicken salad from different prep days into one pan and keep the later date. The discard date of a combined product is the earliest date of the foods that went into it.

Exam Traps

The trap is treating Day 1 as the day after prep. Monday prep is Day 1; Sunday is Day 7. Another trap is restarting seven days when a commercial package is moved from the walk-in to a working container — opening was Day 1, not the transfer. A third trap is assuming freezing erases the clock. Freezing pauses it. A fourth is skipping labels on working containers because "everyone knows what is in the bin." The exam answer is the common name of the food.