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SOUS VIDE/COOK-CHILL ROP HACCP REQUIREMENTS

California Health and Safety Code Section 114419 (b) (2) requires retail food
facilities that utilize a reduced oxygen packaging (ROP) method for potentially
hazardous foods to submit a Hazard Analysis Critical Control Point (HACCP)
plan to the California Department of Public Health (CDPH) for review and
approval. This document addresses the elements that must be included in
HACCP plans submitted to CDPH when a retail food facility is utilizing sous vide
or cook-chill processing methods. Please see the separate requirements for
utilizing reduced oxygen packaging methods for cheese products and for vacuum
packaging potentially hazardous foods other than cheese.

A HACCP plan is a written document that delineates the formal procedures for
following the Hazard Analysis Critical Control Point principles developed by the
National Advisory Committee on Microbiological criteria for foods. A HACCP plan
is developed using the following 7 steps:
1. Completion of a hazard analysis identification by identifying the likely hazards
to consumers presented by a specific food.
2. Determination of critical control points in receiving, storage, preparation,
display, and dispensing of the food.
3. Setting of measurable critical limits for each identified critical control point.
4. Developing and maintaining monitoring practices to determine if critical limits
are being met.
5. Developing and utilizing corrective action plans when failure to meet critical
limits is detected.
6. Establishing and maintaining a recordkeeping system to verify adherence to
the HACCP plan.
7. Establishing a system of audits to verify that the HACCP plan is being
followed as written. Record keeping should be as simple as possible to
facilitate accurate data collection by the designated food worker. Records to
be kept as part of the HACCP system include:
a. HACCP plan and support documentation used in developing the plan
b. Records of CCP monitoring
c. Records of corrective action
d. Records of verification activities including:
 Receiving Logs,
 Damaged and Discarded Product Log,
 Daily Storage Temperature Log,
 Thermometer Calibration Log,
 Daily Cooking and Reheating Log
 Cooling Temperature Log
 Food Worker Training Records

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HACCP plans submitted to CDPH for review and approval must address the 7
steps identified above and must also include the following information:
8. A list of specific foods that will be processed using sous vide and/or cook-
chill methods for on-site consumption (or for off-site consumption if served
by the same business entity)*.
9. Food must be fully cooked as per California Health and Safety Code
(Section 114004) final cooking temperature requirements.
10. Food must be protected from contamination before, during, and after
cooking.
11. Food must be placed in the oxygen barrier bag and sealed before cooking
(sous vide) or placed in bag and sealed after cooking but before the
product temperature falls below 135ºF (cook-chill).
12. Food packages must be labeled with the product name and date/time
packaged.
13. Food must be cooled in the bag to 41ºF within 6 hours as per California
Health and Safety Code (Section 114002) cooling requirements and then:
a. Cooled to 34ºF within 48 hours of reaching 41ºF, then held at no more
than 34ºF for no more than 30 days from date of packaging; food must
be either consumed or discarded after 30 days, or
b. Cooled to 34ºF within 48 hours of reaching 41ºF, then removed from
34ºF refrigeration, then held at no more than 41ºF for no more than 72
hours from time of removal from 34ºF refrigeration; food must be
either consumed or discarded after 72 hours, or
c. Cooled to 38ºF within 24 hours of reaching 41ºF, then held at no more
than 38ºF for no more than 72 hours from time of packaging; food
must be either consumed or discarded after 72 hours, or
d. Frozen with no time restriction while frozen.
14. Food packages must be held in a refrigeration unit equipped with a
continuous electronic temperature monitoring system that is visually
examined at least twice a day.
15. If product is transported off-site to a satellite location of the same business
entity, the transport vehicle must be equipped with electronic temperature
monitoring devices to ensure time/temperature monitoring during
transport.
16. Food facility must maintain records that document and confirm cooling
and cold holding time/temperature requirements have been met
17. Description of the standard operational procedures that:
a. Prohibit bare hand contact with ready-to-eat food prior to being
vacuum packaged,
b. Identify a designated vacuum packaging work area,
c. Delineate measures to prevent cross contamination between raw and
ready-to-eat foods prior to and during vacuum packaging,
d. Delineate cleaning and sanitizing procedures for food contact surfaces
and the vacuum packaging machine,
e. Limit access to the vacuum packaging area to trained staff that are
familiar with the hazards associated with the operation.

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f. Assure each ROP food is stored in accordance with a “First-in/First-
out” storage rotation procedure and is discarded in accordance with
the HACCP plan.
18. Description of the training program for the employees responsible for the
preparation of the foods that are to be processed using sous vide and/or
cook-chill methodology to include a supervisory training plan that
addresses the food safety issues of concern.
19. A flow diagram of the specific foods for which the HACCP plan is required,
identifying critical control points and providing information on the following:
a. Ingredients, materials, and equipment used in the preparation of that
food.
b. Formulations or recipes that delineate methods and procedural control
measures that address the food safety concerns involved.
20. A statement of standard operating procedures for the plan under
consideration including clearly identifying the following:
a. Each critical control point.
b. The critical limits for each critical control point.
c. The method and frequency for monitoring and controlling each critical
control point by the food employee designated by the person in charge.
d. The method and frequency for the person in charge to routinely verify
that the food employee is following standard operating procedures and
monitoring critical control points.
e. Action to be taken by the person in charge if the critical limits for each
critical control point are not met.
f. Records to be maintained by the person in charge to demonstrate that
the HACCP plan is properly operated and managed.
21. Record retention procedures to ensure that
a. Applicable HACCP training is provided and documented for food
employees who work in the preparation of food for which an HACCP
plan has been implemented. Training given to food employees shall be
documented as to date, trainer, and subject.
b. The person operating a food facility pursuant to a HACCP has
designated at least one person to be responsible for verification of the
HACCP plan. Training for the designated person shall include the
seven principles of HACCP and the contents of the HACCP plan.
HACCP training records of the designated person shall be retained for
the duration of employment, or a period of not less than two years,
whichever is greater.
c. Critical limit monitoring equipment is suitable for its intended purpose
and is calibrated as specified by its manufacturer. All calibration
records must be maintained for a period not less than two years.
d. All other records need to be kept on site for at least 90 days after
consumption of the food prepared pursuant to the HACCP plan to
demonstrate that the HACCP plan has been followed as written.
e. All records must be made available to regulatory agency upon request.

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*Note: Sous vide and cook-chill products prepared at a retail food facility can
not be sold to consumers or sold/distributed to an independent
business entity.