Thank you Chef JimmyJ.... You have provided exactly the information necessary to prove the FDA Food Code Rules are well intentioned....
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The FDA can provide no validation that the 6-hour cooling is necessary, or any scientific study as the source for the 6-hour standard. The only scientifically based safe cooling study, as found in the USDA 9 CFR 318.17 (2), is that reported by Juneja et al (4). This study showed that there was only about a 1 log multiplication of Clostridium perfringens when cooked hamburger was cooled continuously from 130 to 45°F during a 15-hour cooling period simulating cooling in a commercial retail food service refrigeration unit.
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So, the USDA / FDA / FSIS have been shown to "pick" non defensible positions for "safe food handling practices", yet those guidelines are "more than safe" due to their "leaning to the safe side"... I guess that opens the door to a contrary position with any member that suggests using the FDA recommendations....
It is good to know that if a member tries to suggest using the FDA food code guidelines, there is always the chance of a stab in the back from a well intentioned moderator citing outlier data.... Looking at the test results, the "outlier" data is correct and the food is safe.... however, the FDA chose to lean to the side of additional precaution... Making the storage time less than one additional "shift" so to speak in place of the "15" hours that may be perfectly safe seems reasonable... in some instances...
So, lets not extrapolate this information out to the point it is safe in all situations.... Lets stick to the basic FDA / USDA / FSIS guidelines as they are written...
We are not the makers of the law, we are the followers....