Cook-Chill HACCP Plan: Bagged Soups, Sauces and Braises

A cook-chill HACCP plan covers a kitchen that cooks food in batches, packages it in bags or sealed containers while hot, chills it fast and stores it for later service. It is how many commissaries, hotel kitchens, multi-unit restaurants and caterers make soups, sauces, braises and stocks once and serve them for days or weeks. Because the bags have little oxygen inside, the FDA Food Code treats cook-chill as a form of reduced oxygen packaging, with its own rules and a HACCP plan requirement.

This guide walks through those rules, the hazards, a full set of CCPs and the records you need. It is written for US kitchens following a state code based on the FDA Food Code 2022. Your plan is a draft for your health department to review before you start.

What counts as cook-chill under the Food Code

The Food Code defines cook-chill as a process that uses a plastic bag filled with hot cooked food from which air has been expelled and which is closed with a plastic or metal crimp. In practice the term covers:

• Pumping or ladling hot soup, sauce or braise into bags, expelling the air and clipping or heat-sealing them.
• Cooling the bags quickly in an ice bath, a tumble chiller or a blast chiller.
• Storing the bags cold and reheating portions as needed.

Two things it does not cover:

• Cooling food in open hotel pans and covering it in the walk-in. That is ordinary cooling under 3-501.14, with date marking under 3-501.17. You need a cooling log, not a cook-chill plan.
• Sous vide, where raw food is sealed and then cooked in the bag. The Food Code groups cook-chill and sous vide together in 3-502.12(D), so the storage rules are the same, but the cooking step is different. See our sous vide HACCP plan.

If you vacuum-seal cooked food after it is cold, that is reduced oxygen packaging under 3-502.12, covered in the ROP HACCP plan guide. Cook-chill specifically involves packaging hot food.

Why a cook-chill HACCP plan is required

Removing air from the bag stops the aerobic spoilage bacteria that normally make food smell and look bad. It does not stop anaerobic pathogens. The two the Food Code focuses on:

• Clostridium botulinum. Spores survive normal cooking. In a low-oxygen bag, nonproteolytic strains can grow and produce toxin at temperatures as low as about 38°F, without obvious spoilage. That is why the extended storage option requires 34°F.
• Listeria monocytogenes. Grows at refrigeration temperatures. Cooking kills it, but contamination after cooking, from bag handling or the chiller, can let it grow during long storage.

Spore-formers such as Clostridium perfringens and Bacillus cereus also matter during cooling, because large volumes of thick food cool slowly.

Section 3-502.11 says reduced oxygen packaging needs a variance unless it meets 3-502.12. Section 3-502.12(D) allows cook-chill without a variance if you follow its conditions, which include a HACCP plan. Section 8-201.13 lists this as one of the situations where a HACCP plan must be submitted. See when a HACCP plan is required for the broader picture.

The Food Code conditions for cook-chill

Under 3-502.12(D), a food establishment may package TCS food using a cook-chill or sous vide process if it meets several conditions. In plain language, the main ones are:

1. HACCP plan that is given to the regulatory authority before the process is used.
2. Same business entity. The food is prepared and consumed on the premises, or in a group of establishments under the same business entity, with no distribution or sale to another business entity or the consumer.
3. Cooking to the temperatures in 3-401.11 for the food in question.
4. Protection after cooking from contamination before and after packaging.
5. Cooling in accordance with 3-501.14, and then held according to one of these options:
   • Cooled to 34°F within 48 hours of reaching 41°F and held at 34°F until consumed or discarded within 30 days after the date of packaging.
   • Held at 41°F or less and consumed or discarded within 7 days after the date of packaging.
   • Cooled to 34°F, then held at 41°F, within a total of 30 days for the 34°F period and no more than 7 days at 41°F.
   • Held frozen with no shelf life restriction while frozen, until consumed or used.
6. Continuous electronic monitoring of the refrigeration unit, with the records checked at least twice daily.
7. Labeling with the product name and date packaged.
8. Records of monitoring kept at least 6 months and available to the regulator.

Check the exact text of your state's adopted code edition, since some states use older versions with different wording.

Hazard analysis for cook-chill

| Step | Hazard | Reasonably likely? | Control | |---|---|---|---| | Receiving | Pathogens on raw meat, poultry, vegetables | Yes | Approved supplier, receiving temps; killed at cooking | | Cold storage of raw ingredients | Pathogen growth | Yes | 41°F or below | | Cooking | Survival of vegetative pathogens | Yes | Cook to 3-401.11 temperature (CCP) | | Bagging | Recontamination; spores surviving | Yes | Fill hot, clean equipment, no hand contact | | Cooling | Growth of C. perfringens, B. cereus | Yes | 3-501.14 cooling limits (CCP) | | Cold storage | C. botulinum and Listeria growth | Yes | 34°F or 41°F with time limits (CCP) | | Reheating | Survival of pathogens that grew | Yes, if storage failed | Reheat to 165°F for hot holding (control) | | Allergens | Undeclared allergen on label | Yes for multi-product kitchens | Labeling and production order |

For the full method, see hazard analysis examples.

Flow diagram

Draw one diagram per product group. Soups and sauces usually share one; braised meats in their liquid may need another because cooking and portioning differ. See HACCP flow diagram examples.

CCP 1: Cooking

Critical limits. The 3-401.11 temperature for the food. For a mixed soup containing poultry, 165°F for under 1 second. For a beef braise, the braise will far exceed the 155°F or 145°F options. For a vegetable soup with no animal products, the 135°F hot holding temperature for cooked plant foods applies under 3-401.13. In practice most kitchens set a single kettle limit of 165°F for simplicity and record the temperature of every batch.

Monitoring. Probe the center of the kettle or the thickest piece of meat at the end of cooking, and record the time, temperature and batch code.

Corrective action. Keep cooking until the limit is reached. Do not fill bags until the batch is recorded as passing.

Filling and sealing

Fill bags while the food is still hot, ideally 180°F or above for pumped soups (a common operating target, not a code number). Hot filling reduces recontamination risk. Expel air, clip or seal, and label each bag with the product name, date packaged and batch code. Use clean, sanitized pumps, hoses and funnels. Staff should not touch the food or the inside of the bag.

Check every seal. A leaking bag lets chill water or air in and makes the batch unreliable.

CCP 2: Cooling

Critical limits. Under 3-501.14, cooked TCS food must be cooled from 135°F to 70°F within 2 hours, and from 135°F to 41°F or less within a total of 6 hours. Some kitchens set tighter internal limits, such as 135°F to 41°F in 4 hours, to leave room for the later move to 34°F.

Monitoring. Probe a bag from the center of each load at the start, at 2 hours and at the end of cooling. Use a thermometer that can read through or into the bag without breaking the seal, or sacrifice one bag per batch for the check.

Corrective action. If a bag is above 70°F at 2 hours, the Food Code allows reheating to 165°F and starting the cooling again, or discarding. Many cook-chill kitchens choose to discard because reheating bagged food is impractical. If a bag is above 41°F at 6 hours, discard.

Making cooling work

• Keep bags flat and thin. A bag filled to 2 inches thick cools much faster than a round 4-inch bag.
• Use an ice bath with plenty of ice and circulating water, or a tumble chiller.
• Do not stack hot bags.
• Move bags to the 34°F storage unit promptly after they reach 41°F.

See food cooling rules for more on cooling methods.

CCP 3: Cold storage

Critical limits. Choose one storage option and write it into the plan:

| Option | Storage temperature | Maximum shelf life | |---|---|---| | A | 41°F or below | 7 days from packaging | | B | 34°F or below, reached within 48 hours of reaching 41°F | 30 days from packaging | | C | 34°F, then moved to 41°F | 30 days total, no more than 7 days at 41°F | | D | Frozen | While frozen |

Option A is simplest and fits most restaurants. Option B is what commissaries use to cook once a week or less. It requires a refrigerator that can hold 34°F reliably, which ordinary reach-ins often cannot.

Monitoring. Continuous electronic monitoring of the storage unit, examined at least twice a day. A data logger or a connected temperature sensor with alerts is the usual way. Keep the printouts or exports.

Corrective action. If the unit goes above the limit, check how long and how high. For Option B, product that warms above 34°F for an extended time may have to move to the 7-day rule from the date of packaging, or be discarded. Write the specific rule into your plan and get it approved by your regulator, rather than deciding during a failure.

Reheating and service

Cook-chill product that is reheated for hot holding must reach 165°F for 15 seconds within 2 hours under 3-403.11. Reheating is not a CCP for the pathogens controlled by cold storage, but it is a control. Record reheating temperatures on your hot holding log. See reheating food to 165°F.

Once a bag is opened, the contents are no longer under reduced oxygen conditions. Treat leftover product as ordinary date-marked food, without extending the original use-by date.

Labeling and traceability

Each bag needs a label with:

• Product name.
• Date packaged.
• Batch code tied to the cooking and cooling records.
• Use-by date based on your storage option.
• Allergens.

If a cooling record fails, the batch code lets you find and discard every bag from that batch.

Records

| Record | Frequency | Keep | |---|---|---| | Cooking log | Every batch | 6 months | | Cooling log | Every batch, at 0, 2 and 6 hours | 6 months | | Continuous storage monitoring | Continuous, reviewed twice daily | 6 months | | Corrective actions | Every event | 6 months | | Thermometer calibration | Weekly or as planned | 6 months | | Equipment cleaning and sanitizing | Daily | Per plan | | Training | Each staff member | While employed | | Plan verification | Monthly review, annual reassessment | Per plan |

Use our restaurant temperature log and thermometer calibration log as starting points.

Prerequisite programs

• Cleaning and sanitizing of kettles, pumps, hoses, fill stations and chillers. Pumps and hoses are hard to clean, so take them apart.
• Allergen control. Schedule production so allergen-free products are made first, and clean between.
• Employee health and hygiene.
• Supplier approval.
• Pest control.
• Equipment maintenance, especially for the chiller and the storage unit.

See sanitation SOPs for restaurants and the food allergen control plan.

Sample cook-chill HACCP plan summary

| CCP | Hazard | Critical limit | Monitoring | Corrective action | Record | |---|---|---|---|---|---| | 1 Cook | Vegetative pathogens | 165°F at center of kettle, every batch | Probe at end of cook | Continue cooking | Cooking log | | 2 Cool | Spore-former growth | 135°F to 70°F in 2 h; to 41°F in 6 h total | Probe center bag at 0, 2, 6 h | Discard if limits missed | Cooling log | | 3 Store | C. botulinum, Listeria | 41°F or below, 7 days from packaging | Continuous logger, review twice daily | Evaluate time and temperature; discard per plan | Logger export and review sheet |

Verification and validation

• Manager reviews cooking and cooling logs daily and signs them.
• Thermometers calibrated weekly by ice point.
• Storage logger checked against a reference thermometer monthly.
• The plan is reviewed when you add a product, change bag size, or change the chiller.
• A full reassessment at least once a year.

Validation for cook-chill mostly comes from the Food Code limits themselves. If you want limits outside them, such as a longer shelf life, you need a variance and scientific support. See HACCP verification and record keeping and the NACMCF HACCP principles and application guidelines.

Training

Everyone who fills, chills or stores cook-chill bags should know the three CCPs, how to take a temperature in a bag, what to do if cooling is slow, and how to read the use-by date. Keep signed training records. See HACCP training for restaurant staff.

What inspectors usually ask

Expect questions about where the plan is kept, who is trained, how you check cooling inside a sealed bag, what the storage logger showed over the last week, and what you did the last time something went wrong. Have the logs and corrective action records ready in one binder or folder.

Common mistakes

• Using an ordinary walk-in for 30-day storage. Most do not hold 34°F reliably.
• Thick, round bags that miss the 2-hour cooling limit.
• No continuous monitoring. A twice-daily hand check is not what the code asks for.
• Selling bags to other businesses. That falls outside 3-502.12(D).
• Restarting the date after opening.
• Starting before the plan is submitted.

Product examples

• Chicken stock and soups. Cook to 165°F, fill hot into 1 or 2 quart bags, chill flat in an ice bath. Thin liquids cool quickly and fit Option B well.
• Tomato sauce and marinara. Acidic sauces are lower risk for C. botulinum, but the Food Code conditions still apply when they are bagged by cook-chill unless your regulator agrees otherwise.
• Braised short rib or pulled pork in liquid. Thick and dense. Portion into flat bags, make sure the meat is covered by liquid, and verify cooling with a probe in the thickest piece.
• Rice and cooked grains. B. cereus is the main concern during cooling. Spread thin and chill fast.
• Mashed potatoes and purées. Very thick, cool slowly. Fill bags no more than about 2 inches thick.

Equipment choices for small kitchens

A full commissary setup with a pump station, clip machine and tumble chiller costs real money. Smaller kitchens often start with:

• A chamber vacuum sealer for portion bags of sauce or braise filled hot.
• A large ice bath in a prep sink with ice delivered or made on site.
• A dedicated reach-in set to 34°F, or Option A storage at 41°F for 7 days.
• A wireless temperature sensor in the storage unit that logs continuously and sends alerts.

Whatever you use, test cooling with your actual bag size and recipe before you submit the plan, and keep that test data. It shows the health department your method works.

Writing and submitting your plan

1. Describe your operation and the products you will cook-chill.
2. Choose a storage option for each product.
3. Draw flow diagrams.
4. Do the hazard analysis.
5. Fill in the CCP table with limits, monitoring, corrective actions and records.
6. Attach blank logs, cleaning SOPs and training records.
7. Submit the plan to your health department and wait for acceptance before using the process.

Our guide to writing a HACCP plan and the HACCP plan example show the full layout.

Build your cook-chill HACCP plan

The HACCP builder includes a cook-chill process with Food Code 2022 limits and section numbers already filled in, plus printable cooking, cooling and storage logs. Your first process is free, and the Plan Pack adds every process your kitchen runs. Whatever you produce is a draft for your health department to review and accept before you start cook-chill.

Frequently asked questions

Does cook-chill need a HACCP plan?

When cooked TCS food is packaged in reduced oxygen bags by a cook-chill process, yes. Food Code 2022 section 3-502.12(D) requires a HACCP plan provided to the regulatory authority before you start. Cooling food in open pans and storing it covered is ordinary cooling, not cook-chill packaging.

How long can cook-chill food be kept?

Under 3-502.12(D), up to 7 days at 41°F or below, or up to 30 days from packaging if it is cooled to 34°F within 48 hours of reaching 41°F and held at 34°F. Frozen product is held frozen. Your health department may set shorter limits.

What monitoring does cook-chill storage need?

The Food Code requires continuous electronic monitoring of the refrigeration unit holding cook-chill product, with the records examined at least twice daily, and records kept at least 6 months.

Can a commissary send cook-chill bags to other restaurants?

Section 3-502.12(D) limits cook-chill product to consumption within the food establishment or within a group of establishments under the same business entity. Selling the bags to other businesses moves you outside that provision. Ask your regulator.