The curing HACCP plan

Why curing needs a variance

Most of what a kitchen does is covered by the normal Food Code rules: cook to a temperature, cool on a schedule, hold hot or cold. Curing is different. The safety of a cured belly or side of salmon depends on salt, sugar, nitrite, time and temperature working together, and the Food Code treats that as a special process. You ask permission first.

FDA Food Code 2022, 3-502.11

A FOOD ESTABLISHMENT shall obtain a VARIANCE from the REGULATORY AUTHORITY as specified in § 8-103.10 and under § 8-103.11 before:

FDA Food Code 2022, 3-502.11(B)

Curing FOOD;

Once a variance is required, section 8-201.13(A)(2) says you submit a HACCP plan for approval before you start. Annex 6, the Food Code's guidance on processing at retail, says the same thing in plain words, twice:

FDA Food Code 2022, Annex 6, 2(H)(3)

Curing using nitrite or nitrate always requires a variance.

FDA Food Code 2022, Annex 6, 3(F)(3)

A HACCP plan is needed for all curing operations.

Why the extra step? The Food Code's own reasoning is short:

FDA Food Code 2022, Annex 3, 3-302.14

However, if this process is done incorrectly, it could cause illness or death because of excessive nitrite or because the food is insufficiently preserved.

Too much nitrite poisons people. Too little, or an uneven cure, leaves the meat without the protection you think it has against Clostridium botulinum. Both mistakes are invisible: the bacon looks and smells fine. That is why the plan is built around the scale, not the eye.

The restaurant cures we cover

ClearHACCP builds curing plans for whole-muscle cures that a restaurant makes in a walk-in and cooks or serves cold under refrigeration. Annex 6 groups cured meats into categories; the ones a restaurant usually makes fall into two of them: uncomminuted smoked products such as bacon, and uncomminuted unsmoked products such as corned beef and pastrami.

Pancetta deserves a line of its own. If you serve it raw, Annex 6 has a rule that applies to any raw pork product:

FDA Food Code 2022, Annex 6, 3(E)

At retail, products which contain raw pork and which are not subsequently cooked must be produced from certified trichina-free pork or treated to destroy trichinae.

What needs a process authority, not a template

Some cures are not safe because of refrigeration. They are safe because of a fermentation step that drops the pH, or a drying step that pulls out water, and they are often kept at room temperature. The Food Code describes the goal of fermentation like this:

FDA Food Code 2022, Annex 6, 3(E)

The purpose of fermentation is to reduce the pH to below 4.6 and inhibit bacteria harmful to health as well as bacteria which can cause spoilage.

Getting a salami under pH 4.6 on schedule, and proving it, takes a starter culture, a calibrated pH meter, humidity control and often lab validation. Annex 6 also warns about a hazard that cooking cannot fix later:

FDA Food Code 2022, Annex 6, 3(E)

Sanitary practices in the production of these products are extremely important because Staphylococcus aureus can be introduced.

The nitrite math, in plain words

There are two nitrite numbers, and people mix them up.

• Ingoing nitrite is how much sodium nitrite you add, compared with the weight of the raw meat. It is what you control with the scale.
• Residual nitrite is what is left in the finished product. It is lower than ingoing, because nitrite reacts with the meat during the cure.

Annex 6 gives the residual ceiling and a typical working level:

FDA Food Code 2022, Annex 6, 3(A)

The maximum residual sodium nitrite in the finished product is limited to 200 ppm by the USDA Food Safety and Inspection Service (FSIS).

FDA Food Code 2022, Annex 6, 3(A)

A sodium nitrite concentration of 120 ppm is usually sufficient for most purposes.

The ingoing limits come from USDA, not the Food Code. They are in 9 CFR 424.21(c), they depend on the method (dry rub, immersion, pumped) and the product, and bacon has its own rules. Your plan names the line it uses. We do not print those figures here because they are not in the Food Code text.

In the kitchen it works like this. Commercial curing salts are mostly salt with a small, stated share of sodium nitrite, dyed pink so nobody mistakes them for table salt. Multiply the weight of cure you add by that share and you get the weight of nitrite. Divide by the weight of the meat and you have the ingoing concentration. Write the answer down as a schedule: so many grams of cure for each kilogram of belly. The cook never does the math at the bench; they weigh the belly, read the schedule, weigh the cure.

FDA Food Code 2022, Annex 6, 3(F)(3)

A schedule or recipe must be established for determining the exact amount of curing formulation to be used for a specified weight of meat or meat mixture.

Annex 6 lists the cure itself as a critical control point. Buy a prepared cure, or if you blend your own, weigh with calibrated scales:

FDA Food Code 2022, Annex 6, 3(F)(3)

If cure mixes are blended on the premises instead of acquired pre-mixed, mixing must be carefully controlled by using calibrated weighing devices.

FDA Food Code 2022, Annex 6, 3(F)(3)

Cure must be discarded if the package is wet or appears to have been wetted.

Cure temperature and time

For dry cures on whole muscle, Annex 6 sets a product temperature band, and explains both ends:

FDA Food Code 2022, Annex 6, 3(F)(3)

The application of salt during dry curing of muscle cuts requires that the temperature of the product be strictly controlled between 1.7°C (35oF) and 7.2°C (45oF).

FDA Food Code 2022, Annex 6, 3(F)(3)

The lower temperature is set to limit microbial growth and the upper temperature is set for the purpose of ensuring cure penetration.

In practice that means a walk-in or a dedicated cure fridge you trust, a reference piece you can probe, and a log. If your walk-in runs colder than 35°F, the cure slows and the time in your recipe is no longer enough; the plan should say how you extend it.

Time is set by the recipe and the thickness of the piece. That is why Annex 6 asks for uniform pieces:

FDA Food Code 2022, Annex 6, 3(F)(3)

Pieces must be prepared to uniform sizes to ensure uniform cure penetration.

For dry cures, the plan also says how often the pieces are turned and rubbed (overhauled) so every surface takes cure. For brines (corned beef, pastrami), it says how the brine is mixed and when it is thrown out:

FDA Food Code 2022, Annex 6, 3(F)(3)

Curing solutions must be discarded daily unless they remain with the same batch of product during its entire curing process.

Hot curing, where the cure is applied at warm temperatures to speed things up, is a processing-plant technique. Annex 6 says it must be performed above 120°F. ClearHACCP sends any hot-cure answer to a person for review.

And one rule the cure cannot change:

FDA Food Code 2022, Annex 6, 3(F)(3)

Curing may not be used to salvage meat that has excessive bacterial growth or spoilage.

What happens after the cure

A cured belly is still raw pork. Everything after the cure follows the normal Food Code rules, and the plan writes them down for your product:

• Cook. Pork is cooked to 145°F for 15 seconds under 3-401.11(A)(1). A smoker counts as cooking only if the internal temperature gets there; probe the thickest piece. See the smoking guide for the smoke itself.
• Cool. From 135°F to 70°F within 2 hours and to 41°F within 6 hours total (3-501.14(A)(1)). Slabs of bacon cool faster on racks than stacked in a hotel pan. See two-stage cooling.
• Hold and date mark. Cold hold at 41°F or below. Ready-to-eat items made in house and kept more than a day are date marked for up to 7 days at 41°F (3-501.17(A)).
• Packaging. Vacuum packing cured meat or fish is reduced oxygen packaging, with its own rules. See the ROP guide before you bag anything for storage.

Gravlax and parasites

Salt and sugar change the texture of salmon. They do not kill parasites. Gravlax is still raw fish served ready to eat, so 3-402.11 applies. Its scope covers fish that is:

FDA Food Code 2022, 3-402.11(A)

raw, raw-marinated, partially cooked, or marinated-partially cooked FISH shall be:

The fish must be frozen first using one of three options:

A home freezer or a reach-in rarely holds the colder settings, so most restaurants buy fish already frozen by the supplier and keep the supplier's written statement. That counts under 3-402.12(B). Aquacultured salmon raised on formulated feed with no live parasites is exempt under 3-402.11(B)(4), but you still need a written statement from the supplier, kept for 90 days after service. Looking at the fish is not a control:

FDA Food Code 2022, Annex 3, 3-402.11

Candling or other visual inspection techniques are not adequate to avoid the risk of parasites from fish which have not been frozen.

FDA Food Code 2022, 3-402.12(A)

shall retain the records of the FOOD ESTABLISHMENT for 90 calendar days beyond the time of service or sale of the FISH

Gravlax made in house is also date marked like any ready-to-eat food. The Food Code's date marking exemption for some commercially preserved fish does not reach it:

FDA Food Code 2022, Annex 3, 3-501.17

This exemption does not apply to hot or cold smoked fish products, nor does it apply to fish products that are dried, marinated, or otherwise preserved on-site, in a food establishment, such as ceviche.

See the full plan in the salmon gravlax sample plan.

The plan: flow diagram and critical control points

Here is how a house bacon plan reads. Section 8-201.14 asks for a flow diagram that marks every critical control point, and a table that gives each one its limit, monitoring, corrective action, verification and records.

A corned beef plan swaps the dry cure for a brine step (brine made to the schedule, kept cold, discarded daily unless it stays with one batch) and the smoke for a simmer. A gravlax plan swaps the cook for a parasite control at receiving. The full worked versions are in the house bacon sample plan and the gravlax sample plan.

Labels, the posted list, and records

Annex 6 asks for three things that are easy to forget because they are not temperatures:

FDA Food Code 2022, Annex 6, 3(F)(1)

A list of products approved by the regulatory authority, or by an approved knowledgeable authority on curing acceptable to the regulatory authority, must be posted in the processing area of the establishment.

FDA Food Code 2022, Annex 6, 3(F)(2)

Employees assigned to cure meat or poultry must demonstrate familiarity with these guidelines and the potential hazards associated with curing foods.

And under 8-103.12(A), once the variance is granted:

FDA Food Code 2022, 8-103.12(A)

Maintain the approved variance at the food establishment;

For each batch, label the tub or bag with the product, batch number, cure date, the cure used and the date it comes out. The cure log holds the green weight, the cure weight, who weighed it and the temperature checks. If your health department asks how much nitrite went into last Tuesday's bacon, you can answer from one page. With a ClearHACCP Process Plan, these logs run on your phone for 12 months and export any time.

What plan reviewers look for

The variance request itself follows 8-103.11: a statement of the variance with the Code sections, the rationale for how the hazards are controlled another way, and the HACCP plan.

FDA Food Code 2022, 8-103.11(B)

An analysis of the rationale for how the potential public health HAZARDS and nuisances addressed by the relevant Code sections will be alternatively addressed by the proposal;

When a reviewer reads a curing plan, these are the questions that come back most:

• Which cure, exactly? Brand, nitrite share, and whether it contains nitrate.
• Show the math. Cure per weight of meat, the ingoing nitrite it gives, and the 9 CFR line it is held to.
• How do you know the scale is right? A calibration check with a known weight, and a log.
• What temperature is the product during the cure? A range with both ends, a way to measure it, and a corrective action.
• What happens to a bad batch? Discard is a valid answer. "Use it anyway" is not.
• For fish: where is the parasite paperwork? Freezer logs or a supplier letter, kept 90 days.

Frequently asked questions

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