When is a HACCP Plan Required in a Food Service Operation?

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According to the FDA Model Food Code, certain processes in food service operations require both a HACCP (Hazard Analysis Critical Control Point) plan and a variance due to the higher risk of foodborne illness associated with these practices. Here are some key processes that generally require both:

Reduced Oxygen Packaging (ROP)

This includes methods like vacuum packaging, sous vide, and cook-chill processes. ROP limits oxygen, potentially promoting the growth of harmful anaerobic bacteria like Clostridium botulinum.

Smoking Food for Preservation (Not Just Flavor)

If smoking food is intended for preservation (e.g., smoked meats), it requires a HACCP plan to monitor temperature control and prevent contamination.

Curing Food

Curing involves adding nitrates or nitrites to food for preservation, which can alter its pH and water activity level. A variance is required to ensure these factors are adequately controlled to prevent pathogenic growth.

Using Food Additives or Adding Components to Change pH or Water Activity

This includes acidifying foods (e.g., using vinegar to pickle), as it alters food safety parameters by creating an inhospitable environment for pathogens. A HACCP plan is necessary to monitor these changes.

Custom Animal Processing (e.g., smoking whole fish on-site)

If processing or custom-butchered animals are served in a way that affects their preservation, food safety must be rigorously controlled.

Sprouting Seeds or Beans for Use as Food

Since sprouting can lead to the rapid growth of bacteria, careful monitoring is essential. A variance ensures adherence to food safety standards due to the risk of Salmonella and E. coli contamination.

Live Molluscan Shellfish Tank Operation for Display and Sale

If molluscan shellfish are displayed in a live tank for sale, a HACCP plan monitors water quality and other safety parameters to prevent contamination.

These processes all involve changes in critical control points (like pH, oxygen levels, or temperature), which is why both a HACCP plan and a variance are essential for managing and ensuring food safety.

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