The sous vide and cook-chill HACCP plan, line by line

When a sous vide HACCP plan is required

If you seal time/temperature control for safety food in a bag and cook it, or cook it and chill it in the bag, the Food Code treats it as reduced oxygen packaging. Paragraph 3-502.12(D) is written for exactly that kitchen, and its first line is the one that matters: the plan goes to your regulatory authority before you start. Not after the first inspection. Before the first bag.

FDA Food Code 2022, 3-502.12(D)(1)

Provide to the REGULATORY AUTHORITY prior to implementation, a HACCP PLAN that contains the information as specified under ¶¶ 8-201.14 (C) and (D);

Section 8-201.13(B) says the same thing from the other side: before engaging in reduced oxygen packaging without a variance, you submit a properly prepared HACCP plan. Your regulator reviews it and may ask for changes. Only they can accept it.

You do not need a variance just to cook sous vide. A variance comes in when you want to step outside the code: cooking below the 3-401.11 times and temperatures, for instance. More on that below.

What the Food Code counts as sous vide and cook-chill

Both are named in the Food Code's definition of reduced oxygen packaging. The difference is when the food goes into the bag.

FDA Food Code 2022, 1-201.10(B), Reduced oxygen packaging (2)(e)

Sous vide PACKAGING, in which raw or partially cooked FOOD is vacuum packaged in an impermeable bag, cooked in the bag, rapidly chilled, and refrigerated at temperatures that inhibit the growth of psychrotrophic pathogens.

Why the extra rules? Removing oxygen stops the spoilage bacteria that would normally warn you food has turned, while Clostridium botulinum grows fine without oxygen and its spores survive normal cooking. Listeria monocytogenes keeps growing at fridge temperatures. A sous vide plan is mostly about those two organisms: cook enough, cool fast, keep it cold, and do not keep it too long.

The 8 rules in 3-502.12(D)(2), in plain words

Paragraph (D)(2) lists what must be true of the food itself. Your plan needs to show how each one is met.

FDA Food Code 2022, 3-502.12(D)(2)(d)

Placed in a PACKAGE with an oxygen barrier and sealed before cooking, or placed in a PACKAGE and sealed immediately after cooking and before reaching a temperature below 57°C (135°F)

Cooking: the time and temperature your plan states

Rule (b) points straight at 3-401.11. Your plan names a category for every menu item and the limit that goes with it. These are the ones that come up in sous vide kitchens.

The roast chart is why long, low sous vide cooks work for whole-muscle beef and pork roasts: lower temperatures are allowed, as long as the food is held there for the time the chart gives. A few rows:

Cooling the bag: 2 hours, then 6 hours

Rule (e) sends you to the standard cooling rule, 3-501.14, applied to the sealed bag. Two checkpoints, and the clock starts when the food is at 135°F:

FDA Food Code 2022, 3-501.14(A)(1)

Within 2 hours from 57ºC (135ºF) to 21ºC (70°F)

FDA Food Code 2022, 3-501.14(A)(2)

Within a total of 6 hours from 57ºC (135ºF) to 5ºC (41°F) or less

The first stage is the one that bites. Between 135°F and 70°F bacteria grow fastest, so the code gives you only 2 hours there. A bag in a walk-in will not make it. An ice bath does, as long as the bags are not stacked and the water stays iced: that is "using containers that facilitate heat transfer" and "rapid cooling equipment" from the 3-501.15 methods list. A blast chiller does it with room to spare.

How to monitor it: probe a sacrificial bag (a bag of the same size and thickness, sealed with a probe port or opened for the reading) at the start, at 2 hours and at 6 hours, and log the clock time with each reading. If your circulator or chiller has a probe that logs on its own, your plan can say so.

See the full method, a worked clock-time example and what to do on a miss in two-stage cooling.

The 4 storage options, and how to pick one

Once the bag is at 41°F, your plan picks exactly one way to hold it. The option sets the shelf life your labels and discard dates follow.

FDA Food Code 2022, 3-502.12(D)(2)(e)(i)

Cooled to 1°C (34°F) within 48 hours of reaching 5°C (41°F) and held at that temperature until consumed or discarded within 30 days after the date of PACKAGING

Fridge monitoring, transport and labels

This is where most plans get stuck before they are written. Rule (f) is not satisfied by a dial thermometer on the shelf.

FDA Food Code 2022, 3-502.12(D)(2)(f)

Held in a refrigeration unit that is equipped with an electronic system that continuously monitors time and temperature and is visually examined for proper operation twice daily

In practice that means a data logger or a connected sensor in the unit that records time and temperature without anyone pressing a button, plus a twice-daily check written on a log. Many kitchens add a cheap wireless logger to an existing reach-in. If you do not have one yet, your plan cannot honestly say you do: ClearHACCP stops the build there and tells you to add one first.

Labels under rule (h) need the product name and the date packaged. Add the discard date your storage option gives; the reviewer will look for it, and your line cooks will thank you. Our label and discard log does the date math.

Example: the 72-hour short rib plan

A beef short rib, seasoned, bagged on a chamber sealer, cooked for three days, cooled in an ice bath, held in a 34°F unit with a data logger, then reheated and finished to order. Here is the flow diagram the plan carries (8-201.14(C)) with its three critical control points:

And the CCP summary (8-201.14(E)). This is the page your plan reviewer reads first.

Whether a short rib is cooked to the whole-roast chart or to (A)(1) depends on how it is cut and handled; your plan states the category and your reviewer may ask why. The full sample plan is free: sous vide short rib sample plan.

Operational procedures, training and records

Paragraph (D)(4) pulls in the same written procedures and training that a vacuum-packing plan needs, from 3-502.12(B)(5) and (B)(6):

• No bare-hand contact with ready-to-eat food (3-301.11(B)). Gloves or utensils after cooking.
• A designated work area and how raw and ready-to-eat food are kept apart; access to the sealer limited to trained staff.
• Cleaning and sanitizing of food-contact surfaces, including the sealer bar and the bath.
• A training program so whoever runs the process understands the concepts, the equipment and the procedures.

Records: cooling and cold-holding time and temperature records are part of the plan, available to the regulator on request, and kept at least 6 months:

FDA Food Code 2022, 3-502.12(D)(3)(b)

Hold such records for at least 6 months

What plan reviewers send back

From public health department templates and checklists (Minneapolis, Northern Nevada, Oregon), these are the gaps that most often bounce a sous vide plan:

1. No continuous monitoring on the holding unit, or no twice-daily check on the log.
2. A storage option that does not match the equipment. Claiming 30 days at 34°F in a reach-in that runs at 41°F.
3. Cooling with no method and no checkpoints. "Cooled in walk-in" is not a method.
4. Menu items without a category, so the cook limit cannot be checked.
5. Bags sealed after cooling below 135°F.
6. No corrective action for a missed limit, or "notify manager" as the only action.
7. No blank logs attached (8-201.14(F)(2)) and no training plan.
8. Selling bags to go, which (D)(2)(a) does not allow.

Every one of these is a check ClearHACCP runs while you answer, so the plan you submit does not have them. Your reviewer still decides, and if they ask for changes we make them free for 12 months.

Frequently asked questions

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