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Work group debates 'hot liquid' definition, including whether 110°F threshold is practical
Summary
At the July 8 Bulletin 137 review, providers, public-health inspectors and LDOE staff disputed a proposed 110°F threshold for 'hot liquids,' raising enforcement and food-safety concerns and asking that heated foods be handled separately; the department will rework language.
Brandon Carter, assistant superintendent in the Office of Early Childhood Care and Education at the Louisiana Department of Education, opened discussion on a proposed definition of “hot liquid” as part of Bulletin 137 chapter revisions. The draft, recommended by the Child Care Association of Louisiana, would allow some warm beverages in classrooms if they meet a temperature threshold.
Supporters said a clear temperature-based definition would reduce inconsistent citations and give centers the option to serve warm beverages safely. “So the recommendation is any liquid or semiliquid substance with a temperature sufficient to cause a burn injury upon contact with the skin, generally considered to be at or above a 110 degrees Fahrenheit,” said Jennifer Stevenson, a work group member who spoke for several provider recommendations.
Public-health and licensing participants pushed back on the 110°F threshold. A public-health inspector noted that a 120°F standard commonly appears in sanitary codes and that cooking and food-safety requirements often call for much higher temperatures for safe preparation. A provider with recent inspection experience said faucets are commonly limited to about 110°F and that enforcement practices already treat 110°F as a critical threshold in some inspections.
Panelists raised practical questions about day-to-day compliance and enforcement: who would test beverage temperatures, whether thermometers used for food preparation must be sanitized, and whether inspectors would be expected to test individual teachers’ thermoses. Several participants urged excluding heated foods and soups from the proposed definition to avoid conflicting with food-safety cooking temperatures.
Given the technical and implementation concerns, LDOE staff said the department would rework the definition and return with revised language. The work group identified hot-liquids wording, sanitary testing procedures and whether to exclude heated food items as items for further legal and operational review ahead of the next meeting.
The work group will revisit this item at future meetings; the next review session is scheduled for July 29, 2026.
