HACCP plan vs. health inspection

Q.

At my last health inspection, I was nearly shut down for not having a HACCP plan for the soups I was cooking, bagging and chilling. I never knew I needed one. When do I really need a plan?

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Restaurant Owner, New York, NY
Answer

HACCP, which stands for Hazard Analysis Critical Control Point, is a system you can use to minimize food safety risks for various products by identifying potential hazards at key points in the process and making sure you take steps to minimize those hazards. HACCP takes the form of a written plan with a metric at those critical points.  For example, “Reheat item to 165 degrees Fahrenheit for 15 seconds,” would be one step in a HACCP plan for one menu item.

While HACCP is used widely in food manufacturing, it is not required for most menu items in restaurants. General good food safety practices are usually sufficient. However, there are definite instances where a municipal health department will require that you keep and follow a formal, approved HACCP plan. Laxman Kanduri, a food safety consultant based in Princeton, NJ, says that while requirements vary by municipality, HACCP plans are often required for, “Hazardous foods kept in the danger zone. For example, if you want to hold sushi rice at 108 or 110 degrees [Fahrenheit] you may need a HACCP plan to get a variance to hold it below 135 or 140. If you are making your own yogurt, you need a variance. You will need a written HACCP Plan or process schedule done by someone whose credentials are approved by the health department.”

Because you are bagging and sealing your soups and sauces, you are technically doing reduced oxygen packaging (variations include modified atmosphere packaging or vacuum sealing), which commonly requires a HACCP plan due to increased risk of botulism and other anaerobic pathogens. Other restaurant-made products often requiring HACCP plans include charcuterie such as fermented sausages, sous vide cooking, and packaging food items like sauces, beverages or condiments for distribution or retail sales on site.

Finally, while it is good practice to use HACCP plans for many potentially hazardous items on your menu, it is vital that they are in place when required. The items that require a HACCP plan needn’t come as a surprise. Ask for a meeting with the health department to describe your processes and ask them if they anticipate any concerns so that you can be as proactive as possible.

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Jonathan Deutsch

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